(together the “Platform”, “Service”, “Website” )
Contact information Four Dots
Four Dots DOO, Mileticeva 28, 21000 Novi Sad, Serbia
Email: [email protected]
Contact information Base
Personal data – is any information relating to an identified or identifiable natural person (‘data subject’). In a nutshell, any data that can identify or point in the direction of a living person.
Usage Data – is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Processing – is any operation or set of operations that are performed on personal data or on sets of personal data, whether or not by automated means.
Authorized Users – employees, agents, consultants, or independent contractors of the client who are authorized by the client to use the Services and the documentation
Controller – can be the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Base is a controller when handling data provided by our newsletter subscribers; data needed to communicate with our clients; and usage data meant to help us optimize the Website for our users.
Processor – can be a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. Base is a processor, for instance, when analyzing User/Client Data to provide our clients with the services they requested.
Using Base to manage your data means that you have engaged Base as a data processor to carry out certain processing activities on your behalf.
This Policy sections and details:
What personal information do we collect?
How do we collect your information?
How long will Base retain your data?
How do we use the collected data?
Base as a processor of User/Client Data
Who processes your information?
Third-party service providers
How do we protect your data?
What do we do in case of data breach/loss?
Where and how is your data stored?
What are your rights regarding your personal data we process or control?
Our policy regarding minors and data relating to them
Links to other websites
Do Not Track
We collect several different information types for various purposes in order to provide and improve our service to you.
1) Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
If you have previously opted in to receive these types of communiqués from us, we may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
2) Usage Data
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
This data is not shared with others and is only used to help us provide our users with a better browsing experience. The data is periodically reviewed and erased or anonymized when no longer needed.
3) Tracking & Cookies Data
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. They are used to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
4) Integration Data
When authorizing any of the integrations offered with the service, our code will have access to any data made available by the integrations API. If the integration requires a specific set of permission scopes to be authorized by the user, the API data accessed will also be limited to these scopes.
Data retrieved from certain integrations may be cached for a short period and may be stored on our servers to improve the deliverability of data with the service. The data obtained from integrations will only be used in the dashboard and reports that you and your users have access to. The data is not used internally or in any place that you do not have access to.
We use this data to provide you with information and services that you request or subscribe to; to send you information about our company or our products or services, or to contact you when necessary (i.e. notices relating to the Service; service alerts; respond to your questions and concerns). We also use your personal data to bill you for our paid Services. While we reserve the right to send you an email concerning your account billing status and service alerts, you may opt out of our general marketing and promotion emails.
Depending on the context of the personal information you provide, Base may be the data controller (“controller”) or data processor (“processor”) of your personal information under this policy. Base is a processor of Client Data, personal information submitted to the Service or collected through the Service on behalf of or at the direction of subscribers.
We may disclose your personal data to the following persons:
1. Disclosure of information within Base: We limit access to your personal data to employees who reasonably need to process such information as described under this policy. In this situation we:
2. Disclosure of information to particular third parties: We may disclose your personal data to the following third parties:
3. Disclosure of information in certain circumstances: We may also disclose your personal data:
Beyond this, we will not share your personal data with any other person without your consent.
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers for:
1) Monitoring and analyzing the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy
Hotjar is used to track and record user behavior on our Website and is meant to help us improve our service. You can view their GDPR compliance page here https://www.hotjar.com/legal/compliance/gdpr-commitment
2) Payments processing
We may provide paid products and/or services within the Service. In that case, we use a third-party service for payment processing – FastSpring.
3) Customer management and communication
We use Intercom to communicate with our customers and provide them with the necessary support. You can review their GDPR compliance info here.
In order to ensure the correct use of information, we have put in place physical, electronic, and managerial procedures to safeguard and secure the information we collect in association with the Service. Please be aware, however, that no data transmissions over the Internet or other networks can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security or integrity of any information you transmit to us or that you authorize us to collect on your behalf. You transmit information to us and authorize us to collect information on your behalf, at your own risk. Once we receive your information, we make reasonable efforts to protect it from unauthorized access, disclosure, alteration, or destruction. If you have any questions about security on our Site, you can contact us at [email protected].
If we are the data controller, when Base learns of a security systems breach that is likely to result in a high risk to their rights and freedoms, we will attempt to notify the data subject electronically within 72 hours so they can take appropriate protective steps. If we are the data processor, we will attempt to inform the controller of the breach, without undue delay. Base may post a notice through the Service if a security breach occurs. If this happens, you will need a web browser enabling you to access the Service. Base may also notify you via email in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
Your information collected through Base Services may be stored and processed in the United States, Europe, or any other country in which Base or its subsidiaries, affiliates or service providers maintain facilities. Base may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Economic Area (EEA) or other regions with laws governing data collection and use, please note that we will generally not transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.
If such transfers to countries without an adequate decision by the European Commission turn out to be necessary, Base puts appropriate safeguards through contractual obligations.
As a data subject, ie. someone whose personal data we are using, you have the following rights (some of which are relevant to us only when we are in the position of the data controller):
Refer to your right to be informed if we start collecting your data, why we are collecting it and where the data is coming from, in a timely and clear fashion. As consent or contract is the most common basis for our data collection, in most cases, where required, we will ask for your consent before starting to keep any kind of track of your data. Depending on the data we need and the type of our relationship with the data subject in question, we will ask for their consent through a site pop-up, an email, or another appropriate method.
Should you send a request to access your data, held by us, we have one month to comply. You can make the request verbally, or in writing, and are to be granted access to your data without having to pay us a fee. You can make the request at [email protected].
If you feel that some of your personal data that we are storing are incorrect, you can make a verbal or written request to have us make the necessary corrections. We maintain a procedure in order to help you confirm that your Personal Information remains correct and up-to-date. We have one month to respond, but can also contest that the data is accurate and that there is no need for correction, should we determine there are grounds for such refusal to comply.
If you want your data removed from our database, you have the right to demand it be erased. If your written or verbal request is valid, we will have one month to comply with it. You can ask for data to be erased if we obtained it on the grounds of your consent and you are no longer willing to provide it; if we no longer need it for whatever it was originally needed for, and in a number of other cases. The only exception to this being us keeping your email address in a separate database to prevent abuse, on the grounds of legitimate interest lawful basis.
Base will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods. You can make the request at [email protected].
Where personal information is subjected to restriction in this way we will only process it with your consent or for the establishment, exercise, or defence of legal claims. This right includes restricting the processing of your personal information to only include storage of your personal information (e.g. during the time when Base assesses whether you are entitled to have personal information erased). You can make the request at [email protected].
If we are using your personal data, you have the right to expect us to be prepared to safely and promptly send that data to you, or, if technically feasible, to a third party of your choice, in a machine-readable format. This right only applies to us when we are in the position of a data controller. You can make the request at [email protected].
Where we are relying upon legitimate interest to process personal information, you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the personal information for the establishment, exercise, or defence of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis. You can notify us of your objection at [email protected].
Mostly related to profiling and automated marketing campaigns. Data subjects have the right to demand to be exempt from such practices, while we are obliged to give them means of easily communicating their desire to be excluded.
Where you have provided us with your consent to process personal information, you have the right to withdraw such consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
You can do this by:
Despite us doing everything in our power to ensure the safety of your personal data, intrusions are always possible. In order to maximize the privacy of your data, and to minimize the impact of possible breaches, we are required to:
Our Websites and Services are not intended for children under 16 years of age. No one under the age of 16 years old may provide any personal information to or on the Websites and Services.
We do not knowingly collect personal information from children under 16 years old. If you are under 16 years old, do not use or provide any information on our Websites or Services including on or through any of their features, register on the Websites or Services, make any purchases through the Websites or Services, use any of the interactive or public comment features of our Websites or Services, or provide any information about yourself to us, including your name, address, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 years old, we will delete that information without undue delay.
If you believe we might have any information from or about a child under 16 years old, please contact us at [email protected].
The Site contains links to other websites. We are not responsible for the privacy practices or the content of such websites. We also make our blog and our social media accounts available to you. Please understand that any information that is disclosed and/or shared on these platforms becomes public information. We have no control over its use and you should exercise caution when deciding to disclose your Personal Information and any other information you consider private.
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Base reserves the right to make any and all necessary changes to this Policy at any time and for any reason. We will notify you of any changes and/or modifications to the Policy by updating the “Last Modified” date on this Policy, or when required, directly by asking for your consent. You are encouraged to periodically review this Policy to stay informed of updates. You shall be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Policy by your continued use of Base services after the date such revised Policy is posted, except in cases where your explicit consent is required.