CENOS Privacy & Data Policy

This Privacy & Data Policy governs the use of the websites of CENOS SIA (“CENOS”) such as cenos-platform.com, including any related services offered on such websites (collectively, “Websites”).

This Privacy Policy gives details of which information is collected by and provided to CENOS, how CENOS may use such information and whether such information constitutes personally identifiable information (“Personal Data”).

When visiting our home page, we consider it as very important to protect your personal data when collecting, processing and using it.

Your data is protected according to the requirements of the legal provisions. Please find below some information indicating which data is recorded during your visit on our home page and how it is used.

1. Name and contact data of the data processing person

This data protection information is applicable for data processing orders carried out by:

CENOS SIA

• (hereinafter: CENOS)
• Zeļļu iela 23
• Riga, LV-1002
• Latvia
• +371 27 819 253
• info@cenos-platform.com

2. Collection and storage of personal data as well as kind and purpose of use

a) When visiting the website

When entering our website https://www.cenos-platform.com, the browser of your terminal device automatically sends information to our website’s server.

This information is temporarily stored in a so-called log file. The following information is automatically collected and stored until the automated deletion starts:

• IP address of the contacting computer,
• date and time of the access,
• name and URL of the retrieved file,
• website allowing the access (referrer-URL),
• used browser and maybe the operating system of your computer as well as the name of your access provider.

We process the above mentioned data for the following purposes:

• to guarantee a smooth connection to our website,
• to guarantee a comfortable use of our website,
• to assess the system’s security and stability as well as
• for further administrative purposes.

The legal basis for data processing is laid down in art. 6 seq. 1 S. 1 lit. f of the of the General Data Protection Regulation (GDPR).

b) When registering for our newsletter

After you have given your explicit consent pursuant to art. 6 sec. 1 S. 1 lit. a of the GDPR, we use your email address to send you our newsletter regularly. The indication of your email address is sufficient to receive our newsletter. The cancellation is possible at any time, e.g. through a link at the end of each newsletter. Alternatively, you can send your cancellation by email to info@cenos-platform.com at any time (simply write UNSUBSCRIBE in message subject line).

​
c) When using our contact form

You can pose questions of any kind through our contact form, which is available on our website. This requires the indication of your email address, enabling us to know the sender of the email and to answer it. Further indications can be made voluntarily.

The data processing for contacting purposes is made pursuant to art. 6 seq. 1 S. 1 lit. a of the GDPR based on your voluntarily given consent. The collected personal data indicated on the contact form will be deleted automatically after your question has been answered.

​
d) When creating an account

In order to use CENOS platform, you are required to create an account, which will involve providing personal information, such as your name, email address, phone number, company name or job title. In such case, we may send you an email or other electronic message confirming your account creation (or otherwise instructing you how to confirm it).

​
e) When purchasing subscription to CENOS

If you make a purchase of a CENOS paid plan, you will be required to provide account and billing information, invoice related information, and other data required to process and fulfill the purchase. We may also update such data should you grant us permission to bill you or your credit card for recurring charges, such as monthly (or other periodic) payments.

​
f) When creating a community profile

Creating an account with CENOS will enable you to build a public community profile in connection with your account. Your public profile will include your user name and your geographic location but you may choose to provide other personal information, such as a profile picture, and other information that we may offer you to present.​

3. Transfer of data

A transfer of personal data to third parties is not made for other purposes than indicated as follows. We only pass on your data to third parties when:

• you have given your explicit consent, pursuant to art. 6 seq. 1 S. 1 lit. a GDPR
• the disclosure, pursuant to art. 6 seq. 1 S. 1 lit. f GDPR, is required for the assertion, exercise or defense of legal claims and no reason is evident to have a predominantly legitimate interest of not disclosing your data.
• in case that, pursuant to art. 6 seq. 1 S. 1 lit. c GDPR, the transfer is required by a legal obligation as well as
• it is admissible by law and, pursuant to art. 6 seq. 1 S. 1 lit. b GDPR, required to process the contractual relationship with you.

Our legitimate interest arises from the above listed data collecting purposes. In no case we use the collected data for the purpose of drawing conclusions to your person.

Moreover, we use cookies as well as tracking tools and social media plugins when visiting our website. Further explanations are given in clause 8, 9 and 10 of this privacy statement.

4. Rights of data subjects

You have the right to:

• enquire information about the processed personal data, pursuant to Art. 15 GDPR. You can especially enquire information about processing purposes, the category of personal data, the categories of receivers of your personal data the planned storage time, insisting on the right of correction, deletion, restriction of processing or contradiction, the right to complain, origin of your data as far as it was not collected by us as well as the existence of an automated decision making including profiling and, if required, meaningful information on details;
• pursuant to Art. 16 GDPR, to enquire an immediate correction of incorrect or incomplete personal data stored with us;
• pursuant to Art. 17 GDPR, to enquire the deletion of the stored personal data as far as the data processing is not required for exercising the right of free expression and information, to fulfil a legal obligation, for reasons of public interest or for the assertion, exercise or defense of legal claims;
• pursuant to Art. 18 GDPR, to insist on a restricted processing of the personal data as far as the correctness of the data is denied by you or the processing is unlawful. This also applies in case you refuse to have the data deleted and we are not in further need of them, but you need them for the assertion, exercise or defense of legal claims or in case you have filed an objection against the processing, pursuant to art. 21 GDPR;
• pursuant to Art. 20 GDPR, to receive your submitted data in a well-structured, common and machine-readable format or the request to have the data submitted to another responsible person („data portability“);
• pursuant to Art. 7 seq. 3 GDPR, to revoke your initial consent with us. As a consequence we are not allowed to execute the data processing based on this consent in the future and
• pursuant to Art. 77 GDPR, to complain with the supervisory authority. As a rule, you can address to the supervisory authority of your usual abode or workplace or our association location.

5. Right of objection

As far as your personal data is processed on the basis of legitimate interests pursuant to Art. 6 seq. 1 S. 1 lit. f GDPR you have the right to file an objection against processing your personal data as far as there are reasons arising from your special situation or the objection is directed against direct advertisements.

In the latter case you have a common right to appeal which does not require a special situation. If you want to make use of your right of cancellation or right of objection an email to info@cenos-platform.com is sufficient.

6. Data security

When visiting our website we use the wide-spread SSL procedure (Secure Socket Layer) in connection with the highest encryption grade, depending on what your browser supports.

As a rule, it is a 256 Bit encryption. In case your browser does not support a 256-Bit encryption we use the 128-Bit v3 technology instead. When you see a closed symbol showing a key resp. a lock on the lower status bar of your browser you can see if a single page of our website is transferred with encryption.

We use adequate technical and organizational safety measures in order to protect your data from incidental or intentional manipulations, partial or complete loss, destruction or against unauthorized access of third parties.

Our precaution measures are continuously improved in accordance with the technological development.

7. Changes to this Privacy Policy

This privacy statement is currently valid with status of December 2018. The development of our website could entail an adjustment of this privacy statement due to related offers or due to modified legal resp. official stipulations.

You can retrieve and print the current privacy statement on our website at https://www.cenos-platform.com/data-privacy/ at any time.

8. Cookies

We use cookies on our site. These are small files that your browser automatically creates and that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our site. Cookies do not harm your device, do not contain viruses, Trojans or other malicious software. In the cookie, information is stored, each resulting in connection with the specific terminal used.

However, this does not mean that we are immediately aware of your identity. On the one hand, the use of cookies serves to make the use of our offer more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages on our website. These are automatically deleted after leaving our page.

In addition, to improve usability, we also use temporary cookies that are stored on your device for a specified period of time. If you visit our site again to take advantage of our services, it will automatically recognize that you have already been with us and what inputs and settings you have made, so you do not have to re-enter them.

On the other hand, we use cookies in order to statistically record the use of our website and to evaluate it for the purpose of optimizing our offer (see Section 5). These cookies allow us to automatically recognize when you visit our site again that you have already been with us. These cookies are automatically deleted after a defined time.

The data processed by cookies are for the purposes mentioned in order to safeguard our legitimate interests as well as third parties according to Art. 6 seq. 1 sentence 1 lit. f DSGVO required.

Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or always a hint appears before a new cookies created. However, disabling cookies completely may mean that you can not use all features of our website.

9. Tracking Tools

The tracking measures listed below and used by us are executed on the basis of Art. 6 seq. 1 sentence 1 lit. f of the GDPR. We want to use the tracking measures to ensure that our website is designed in accordance with needs and is optimised on an ongoing basis.

Secondly, we use tracking measures to statistically record usage of our website and evaluate this for the purpose of optimising the services we offer.

These interests are to be considered legitimate in the meaning of the aforestated stipulations. The respective purposes of data processing and data categories can be found in the respective tracking tools.

a) Google Analytics
We use Google Analytics, a web analysis service provided by Google Inc. (https://about.google/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; referred to in the following as “Google”), to design our website in line with needs and to optimise our sites on an ongoing basis.

In this connection, pseudonymised usage profiles are produced and cookies (see section 4) are used. Information on your use of this website generated by the cookie such as

• the browser type/version,
• the operating system used,
• the referrer URL (the previous site visited),
• the hostname of the accessing computer (IP address),
• the time of day when the server enquiry is made,
• is transferred to a Google server in the USA and stored there.

The information is used to evaluate the use of the website, compile reports on website activities and provide further services associated with the use of the website and Internet for the purposes of market research and demand-oriented design of these Internet sites.

This information may also be transferred to third parties if this is required by law or if third parties process are commissioned to do process this data. Under no circumstances will your IP address be combined with other data of Google.

IP addresses are anonymised so that it is not possible to associate them with certain parties (IP masking). You can prevent installation of cookies by selecting appropriate settings on your browser software. We note, however, that this may prevent you from being able to fully use the functions of this website.

You can furthermore prevent Google from collecting the data generated by the cookie relating to your use of the website (including your IP address) as well as its processing of this data by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=en). As an alternative to the browser add-on, in particular with browsers on mobile devices, you can prevent Google Analytics from collecting data by clicking on this link.

An opt-out cookie will then be placed to prevent your data from being collected when you visit this website in the future. The opt-out cookie only functions in this browser and only for your website and is stored on your device. If you delete the cookies in this browser, you have to place the opt-out cookie here.

b) Google Tag Manager
For the purpose of supporting other web analysis tools we use the Google Tag Manager, a tag management system of Google Inc. (https://about.google/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter „Google”). In this context different scripts of these web analysis tools are adjusted for web analyses and remarketing purposes. This enables a quick realization of changes of the website without involving the IT or changing the source code.

The information generated by the cookie about your use of the website such as

• browser type/version,
• used operating system,
• referrer URL (the previously visited website),
• hostname of the accessing computer (IP address),
• time of the server request
• are transmitted to a server of Google in the USA and stored.

The information is used to assess the use of the website, to issue reports about the website activities and to render further services linked with the website use and the internet use for the purpose of market research and the needs-based design of these websites. If necessary and/or if prescribed by law resp.

If third parties process these data on a contractual data processing basis, this information is transmitted to third parties. In no case your IP address will be brought together with other data of Google. The IP addresses will be anonymized avoiding an assignment (IP masking).

Please find further information about privacy protection in connection with Google Tag Manager at: https://privacy.google.com/businesses/processorterms/.

c) Drift.com
Drift.com is an administrative service for user databases of Drift.com Inc. In order to optimize the customer service, to answer the upcoming queries as quick as possible, to prepare payments, to control unauthorized use, to analyse trends and to prepare advertisements, Drift.com is activated when the data subject is in the log in area.

A limited part of the data (e.g. name, email address, phone number, abode, photos and time of registration) is submitted to Drift.com Inc. (Drift.com, Inc. 222 Berkeley Street, Suite 600
, Boston, MA 02116). In order to extend the comprehension about our customer, publicly available information (e.g. the company of a customer, professional designation, physical address, website or social networks) is collected.

Additionally, cookies are used to generate an analysis of the user behaviour. The collected information of the cookies is stored on a server in the USA. This information serves as usage assessment of the platform and to optimize our products.

You can avoid the use of private data by selecting the opt-out procedure, however, we want to point out that, in this case, possibly not all functions can fully be used of this website. Please find further information on the privacy policy of Drift Inc. at https://www.drift.com/privacy-policy/

d) Quora
Quora is a free of charge knowledge platform of Quora Inc., which tries to give answers to any possible question placed by our customers. Cookies are used. They are little files with a clear identification being transmitted through our website to your browser.

They enable us to remember logged in users, to understand how users navigate through the Quora platform and how they use it and to display personalized contents and targeted advertisements (including websites and applications of third-party providers). Additionally, browser information such as IP address, location, date stamp and timestamp, Quora cookies ID, URL, clear identifications of advertisements or contents, time zones and other information about user activities are collected.

The data are also stored outside the EU, e.g. in the USA. There is the possibility to choose the opt-out procedure which avoids that data about the surfing behaviour are transmitted. Please find further information on the privacy policy of Quora Inc. at https://www.quora.com/about/privacy.

e) Track.js
In order to identify errors in JavaScript within our web application we use Track.js of TrackJS LLC. This program offers an error tracking service in order to identify errors and bugs early before they are signalled.

Cookies are used to identify visitors, to retrace their steps and to understand their preferences for accessing the website. You can avoid the installation of the cookies by a certain setting, however, we point out that, in this case, you possibly cannot fully make use of all functions of this website. Please find further information on the privacy policy of TrackJS LLC at https://trackjs.com/privacy/.

f) AddtoAny
In order to conveniently share contents of our site with our users through social networks we use AddToAny. This is a bookmark and share button program. No personal data are sent to social networks, personal data are collected only when the person itself visits these social networks and logs in (being subject to the respective privacy statements).

For this reason no transfer of personal data is made when AddtoAny is used. Only log information is collected from the technical server and stored for 30 days. There is the possibility to opt out avoiding that data about the surf behaviour are transmitted.

Please find further information on the privacy policy of AddtoAny at https://www.addtoany.com/privacy.

​
g) DoubleClick
In order to optimize our homepage we use DoubleClick, a service of Google (1600 Amphitheatre Park-way, Mountain View, CA 94043, USA; hereinafter „Google”). DoubleClick offers online marketing solutions which enable to display tailor made advertisements.

Cookies observing the user behaviour with regard to switches from one website to another and displayed and clicked advertisements are used. This requires that technical data such as IP address, domain, browser, local time, operating system and view of sites are stored. The collected data are transmitted to a server in the USA and stored.

Google uses the gained data for the statistical assessment of the user behaviour in connection with the advertisements placed by DoubleClick. Regarding the cookies there is the possibility to use an opt-out procedure avoiding that no personalized advertisements are displayed any more. Please find further information on the privacy policy of DoubleClick at www.google.com/intl/de/policies/privacy/.

​
h) Hotjar
In order to improve our website we use Hotjar, a service of Hotjar Ltd. (Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe; hereinafter „hotjar“). Hotjar analyses user trends, assists in determining technical problems and allows offering a better service.

Hotjar helps us to make our website more user-friendly and to make the site easily operable. We therefore make use of cookies and tracking codes. For this reason technical data are stored such as the IP address of your device (collected and stored in an anonymized format), your email address including your first name and your family name, as far as you put them at our disposal through our website, screen size of your device, type of device and browser information, geographic abode (only the country), the preferred language in order to display our website.

Furthermore, Hotjar generates the following log data on our server: referring domain, visited sites, geographic abode (only the country), the preferred language in order to display our website, date and time of access to our website. In order to render these services, Hotjar also makes use of third companies’ services (e.g. Google Analytics, Optimizely).

Information sent in form of cookies or IP requests by your browser during your visit on our website are stored. The data collected by Hotjar are transferred to a server in Europe and are stored there. With regard to the cookies there is the possibility to make use of the opt-out procedure (https://www.hotjar.com/legal/compliance/opt-out). Please find further information on the privacy policy at https://www.hotjar.com/legal/policies/privacy.

Based on art. 6 seq. 1 S. 1 lit. f. DSGVO (GDPR), we insert social plugins of the social networks Facebook, Twitter, YouTube, Google+, Xing and LinkedIn on our website with the aim to make our association known to the public. The connected advertising purpose has to be seen as legitimate interest in the sense of DSGVO (GDPR).

The responsibility for a business in conformity with privacy has to be guaranteed by the particular service provider. The insertion of these plugins is made through the so-called two-click-method in order to give the visitors of our website a best possible protection.

a) Facebook
Social-Media Plugins of Facebook are used on our website to have a more personal use with the „LIKE“ or „SHARE“ button which is offered by Facebook. When you visit a page of our website containing such a plugin your browser directly connects with servers of Facebook. The content of the plugin is directly transferred to your browser by Facebook and linked with the website.

The link to the plugins makes Facebook receive the information that your browser has visited the respective page of our website. This is also the case if you do not have a Facebook account or if you are not logged in your Facebook account. This information (including your IP address) is directly transferred to a server of Facebook in the USA and stored.

If you are logged in your Facebook account Facebook is able to allocate your visit on our website directly to your Facebook account. When interacting with the plugins, e.g. by using the „LIKE“ or „SHARE“ button this information is also transferred to a server of Facebook and stored. Furthermore, this information is published at Facebook and displayed to your friends at Facebook.

Facebook can use this information for the purpose of advertisements, market research and design of Facebook sites, as needed. Facebook generates profiles of usage, interest and relations, e.g. in order to evaluate the use of our website with regard to displayed advertisements on your Facebook account, to inform other Facebook users about your activities on our website and to render other services linked with the use of Facebook.

If you disagree that Facebook allocates the data collected through our website to your Facebook account, you have to log out prior to visiting our website. Please refer to Facebook‘s privacy information (https://www.facebook.com/about/privacy/) regarding purpose and extent of the data collection, further processing and use of data by Facebook as well as your rights and setting possibilities to protect your privacy.

b) Twitter
Our internet pages contain plugins of the short messages network Twitter Inc. (Twitter). You recognize the Twitter plugins (tweet buttons) by means of the Twitter logo on our website. Please find below an overview of the tweet buttons:

(https://about.twitter.com/resources/buttons). When visiting a page of our website containing such a plugin a direct connection between your browser and the server of Twitter is established. Twitter receives the information that you have visited our website with your IP address. When you click on the Twitter „tweet button“ while being logged in your Twitter account you can link the contents of our pages on your Twitter profile. This enables Twitter to allocate the visit on our pages to your user account. We point out that we as service provider do not acquire knowledge of the contents of the transferred data as well as their usage through Twitter.

If you do not want Twitter to allocate the visit on our website, please log out of your Twitter user account.

Please find further information in the privacy statement of Twitter (https://twitter.com/privacy).

c) YouTube
So-called social plugins of YouTube are used on our website, which are run by YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066, USA. („YouTube“). These plugins are marked with a YouTube-Logo, e.g. in form of a „YouTube camera“.

When visiting a page of our website containing such a plugin your browser establishes a direct connection to the servers of YouTube. The content of the plugin is directly transferred to your browser and inserted in the page. This insertion makes YouTube receive the information that your browser has visited the corresponding page of our website, even if you do not have a YouTube profile or you are not logged in at YouTube.

This information (including your IP address) is directly transferred from your browser to a server of YouTube in the USA and stored. If you are logged in your YouTube account YouTube is able to allocate the visit on our website directly to your YouTube account. When interacting with the plugins, e.g. by pressing the „YouTube“ button this information is directly transferred to a server of YouTube and stored. Furthermore, this information is published on your YouTube account and displayed to your contacts.

If you do not agree that YouTube directly allocates the data collected through our website you have to log out from YouTube prior to visiting our website.

Please find further information in the privacy statement of YouTube (https://www.youtube.de/t/privacy).

d) Xing
Our website uses social media plugins from Xing SE, Dammtorstraße 30, 20354 Hamburg, Germany to personalise their use. To this end we use the “SHARE” button. This is a service offered by Xing. When you call up a site on our web presence that contains such a plugin, your browser sets up a direct connection with Xing servers. The content of the plugins is transmitted directly by your browser by Xing and integrated by it into the website.

By integrating the plugins, Xing is informed that your browser has called up the respective site of our web presence, even if you do not have a Xing account and do not happen to be currently logged into Xing. This information (including your IP address) is sent directly to a Xing server by your browser and stored there.

When you are logged into Xing, Xing can directly associate your visit to our website with your Xing account. If you interact with plugins, for example by pushing the “SHARE” button, the respective information is also transmitted to a Xing server and stored there. The information is furthermore published on Xing and displayed to your Xing contacts.

Xing may use this information for the purposes of advertising, market research and to design Xing sites to accord with needs. For this purpose, Xing creates usage, interest and relationship profiles, e.g. in order to analyse the use of our website with regard to the advertisements displayed to you on Xing, to inform other Xing users about your activities on our website and to render other services associated with use of Xing.

If you do not want Xing to associate the data collected via our web presence with your Xing account, you must log out of Xing before visiting our website. The purpose and scope of the data collection and further processing and use of the data by Xing as well as your rights and setting options to protect your privacy can be found in Xing’s data protection policy (https://www.xing.com/privacy/).

e) LinkedIn
Our website uses social media plugins from LinkedIn Ireland U.C., Wilton Place, Dublin 2, Ireland to personalise their use. For this purpose, we use the “SHARE” button. The plugins are marked with a LinkedIn logo, for example in the form of an “in” in an underlying square. This is a service offered by LinkedIn. When you access a site on our web presence that contains such a plugin, your browser sets up a direct connection with the LinkedIn servers. The content of the plugin is transmitted by LinkedIn directly to your browser and integrated into the website by it.

By integrating the plugins, LinkedIn is informed that your browser has called up the respective site on our website, even if you do not have a LinkedIn account or are not currently logged into LinkedIn. This information (including your IP address, your proxy server, your browser, your add-ons, your device identification and the functions of your Internet service provider or mobile network operator including location identification) is transmitted directly from your browser to a LinkedIn server in the USA and outside the USA and stored there.

If you are logged into LinkedIn, LinkedIn can directly assign your visit to our website to your LinkedIn account. If you interact with the plugins, for example by pushing the “SHARE” button, the respective information is also transmitted directly to a LinkedIn server and stored there. The information is also published on LinkedIn and displayed to your LinkedIn contacts.

LinkedIn may use this information for the purposes of advertising, market research and to design the LinkedIn sites to meet needs. For this purpose, LinkedIn creates usage, interest and relationship profiles, e.g. to analyse your use of our website with regard to the advertisements displayed to you on LinkedIn, to inform other LinkedIn users about your activities on our website and to render additional services associated with the use of LinkedIn.

If you do not want LinkedIn to associate the data collected via our website with your LinkedIn account, you have to log out of LinkedIn before visiting our website. The purpose and scope of data collection and the further processing and use of your data by LinkedIn as well as your rights and setting options for the protection of your privacy in this context can be found in LinkedIn’s data protection policy (https://www.linkedin.com/legal/privacy-policy).