1. Identity of Cybot
Phone: + 45 50 333 777
E-mail: [email protected]
Company registration number DK34624607
Our customers may submit inquiries regarding personal data protection, privacy and security matters to CEO Daniel Johannsen, Cybot A/S, [email protected]
2. What information do we collect?
You may visit our site anonymously.
If you choose to register on our website, four categories of data to and on behalf of you will be processed:
When you register for an account on our site, place an order, subscribe to our newsletter or respond to a survey, basic contact details are collected such as the e-mail address and name of your contact person, company name, address, phone number, VAT number, preferred language and currency, any purchase order number, any e-mail address of invoice receivers and masked credit card or bank account details.
We collect your direct input to our cloud service Cookiebot Consent Management Platform (the “Service”) after login, like the domain name(s) of the website(s) where you implement the Service and configuration of the content, looks and behavior towards website visitors (“End Users”).
“End User Data”
Data generated by End Users browsing your website(s) using the Service. When an End User submits a consent from your website(s), the following data are automatically logged at Cybot:
- The End User’s IP number in anonymized form (last three digits are set to ‘0’).
- The date and time of the consent.
- User agent of the End User’s browser.
- The URL from which the consent was submitted.
- An anonymous, random and encrypted key value.
- The End User’s consent state, serving as proof of consent.
The key and consent state are also saved in the End User’s browser in the first party cookie “CookieConsent” so that the website can automatically read and respect the End User’s consent on all subsequent page requests and future End User sessions for up to 12 months. The key is used for proof of consent and an option to verify that the consent state stored in the End User’s browser is unaltered compared to the original consent submitted to Cybot.
If you activate the Service feature “bulk consent” to enable consent for multiple websites by a single End User submission, the Service will also store a separate random, unique ID with the End User’s consent. If all of the following criteria are met, this key will be stored in an encrypted form in the third party cookie “CookieConsentBulkTicket” on the End User’s browser:
- You enable the bulk consent feature in the Service configuration.
- The End User allows third party cookies through browser settings.
- The End User has disabled “Do Not Track” through browser settings.
- The End User accepts all or at least “preferences” types of cookies when consenting.
“System Generated Data”
The Service automatically creates and stores meta data on basis of the other types of data, e.g.:
- Subscription data, like start date, latest invoice date and the result of a mandatory VAT number validation. Issued invoices are stored so that you may access any issued invoices from within the Service Manager.
- Definitions of the cookies found when the Service has scanned your website(s), including reports on the result of each scan.
- Aggregated statistical data on End User consents.
You can issue instructions to Cybot through configuration and/or execution of relevant functions offered by the Service from the Service Manager. If a specific instruction regarding personal data cannot be carried out through the Service Manager, you may send instructions to us through the help desk provided at www.cookiebot.com/en/helpdesk.
You will be informed by Cybot about relevant changes concerning the Service, such as the implementation of additional functions, by e-mail, if you subscribe to Cybot’s newsletter from the account settings page in the Service Manager.
3. What do we use your information for?
Any of the information we collect from you may be used for one or more of the following purposes:
3.1.To personalize your experience (the information will help Cybot better respond to your individual needs);
3.2.To enable you to control the user experience towards End Users and enable the Service to automatically apply the End User’s consent to other websites of yours;
3.3.To improve our website (Cybot continually strives to improve our website offerings based on the information and feedback we receive from our customers);
3.4.To identify you as a contracting party;
3.5.To enable secure login for you in the Service Manager at cookiebot.com;
3.6.To establish a primary channel of communication with you;
3.7.To enable Cybot to issue valid VAT invoices and to process transactions (your information will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the service requested);
3.8.To enable automated handling of the subscriptions;
3.9.To produce and display cookie declarations to End Users and store and display scan report(s) to you;
3.10.To provide you with aggregated information on the choices of the End Users regarding accepted cookie types and generate a graphical representation in the Service Manager; and/or
3.11.To send periodic e-mails (The e-mail address you provide for order processing, may be used to send you information and updates pertaining to your order, in addition to receiving occasional company news (if accepted), updates, related product or service information, etc.)
If at any time you would like to unsubscribe from receiving future e-mails, you can cancel your account after login by clicking on “Cancel my account”.
4. Legal basis
4.1. EU General Data Protection Regulation (GDPR)
The processing of your data is either based on your consent or in case the processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract, cf. GDPR art. 6(1)(a)-(b).
If the processing is based on your consent, you may at any time withdraw your consent by contacting us using the contact information in clause 1.
In order to enter into a contract regarding the purchase of Cybot’s Service, you must provide us with the required personal data. If you do not to provide us with all the required information, it will not be possible to deliver the Service.
4.2. California Online Privacy Protection Act Compliance
Because Cybot values your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute any personal information to outside parties without your consent except as stated in clause 7.
As part of the California Online Privacy Protection Act, all users of our website may make any changes to their information at any time by logging into their account and navigating to the “profile page”.
4.3. Children’s Online Privacy Protection Act Compliance
Cybot is in compliance with the requirements of the Children’s Online Privacy Protection Act. We will not intentionally collect any information from anyone under 13 years of age. Our website, products and services are all directed at people who are at least 13 years old or older.
5. How do we protect your information?
Cybot implements the following technical, physical and organizational measures to maintain the safety of your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized use, unauthorized modification, disclosure or access and against all other unlawful forms of processing.
The Service utilizes the extensive features of the cloud environment to ensure high availability, like full redundancy, load balancing, automatic capacity scaling, continuous data backup and geo-replication along with a traffic manager for automatic geographical failover on datacenter level disasters. All failover mechanisms are fully automated.
No personal data is stored permanently outside Cybot’s cloud platforms. The physical security is thereby maintained by Cybot’s subcontractors, see clause 7. Microsoft’s datacenters comply with industry standards such as ISO 27001 for physical security and availability, e.g. by using security staff around the clock, two-factor access control using biometric and card readers, barriers, fencing, security cameras and other measures.
To ensure integrity, all data transits are encrypted to align with best practices for protecting confidentiality and data integrity. E.g. all supplied credit card information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway provider’s database only to be accessible by those who are authorized to access such systems and who are required to keep the information confidential.
For data in transit, the Service uses industry-standard transport protocols between devices and Microsoft datacenters and within datacenters themselves.
All personnel are subject to full confidentiality and any subcontractors and subprocessors are required to sign a confidentiality agreement if not full confidentiality is part of the main agreement between the parties.
Whenever personal data is accessed by authorized personnel the access is only possible over an encrypted connection. When accessing the data in a database, the IP number of the person accessing the data must also be pre-authorized to obtain access.
Any device being used to access personal data is login protected by Cybot’s Azure Active Directory (AAD), Microsoft’s cloud based identity and access management service, and has Cybot’s corporate antivirus solution installed. If any personal data are temporarily stored on a device, the storage unit on the device must also be strongly encrypted.
On premise devices storing personal data temporarily is at all times, except when not being actively used or relocated under uninterrupted supervision, locked in a safe. Personal data are never stored on mobile media like USB sticks and DVD’s.
Cybot will at all times keep you informed about changes to the processes to protect data privacy and security, including practices and policies. You may at any time request information on where and how data is stored, secured and used. Cybot will also provide the summaries of any independent audits of the Service.
All access to personal data is blocked by default, using a zero privileges policy. Access to personal data is restricted to individually authorized personnel. Cybot’s Security and Privacy Officer issues authorizations and maintains a log of granted authorizations. Authorized personnel are granted a minimum access on a need-to-have basis through our AAD.
5.6. The ability to intervene
Cybot enables your rights of access, rectification, erasure, blocking and objection mainly by providing built-in functions for data handling in the Service Manager, by offering the option to send instructions through Cybot’s helpdesk and also by informing about and offering the customer the possibility of objection when Cybot is planning to implement changes to relevant practices and policies.
Cybot uses security reports to monitor access patterns and to proactively identify and mitigate potential threats. Administrative operations, including system access, are logged to provide an audit trail if unauthorized or accidental changes are made.
System performance and availability is monitored from both internal and external monitoring services.
5.8. Personal Data breach notification
In the event that your data is compromised, Cybot will notify you and competent Supervisory Authority(ies) within 72 hours by e-mail with information about the extent of the breach, affected data, any impact on the Service and Cybot’s action plan for measures to secure the data and limit any possible detrimental effect on the data subjects.
“Personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed in connection with the provision of the Service.
See Cybot’s Cookie Declaration at www.cookiebot.com/en/cookie-declaration for information on the cookies we use.
7. Do we disclose any information to outside parties?
Cybot does not sell, trade or otherwise transfer to outside parties any personally identifiable information.
This does not include trusted third parties or subcontractors who assist us in operating our website, conducting our business, or servicing you. Such trusted parties may have access to personally identifiable information on a need-to-know basis and will be contractually obliged to keep your information confidential.
We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect our or others’ rights, property, or safety. Furthermore, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
7.1. Subcontractors/trusted third parties
The subcontractors Microsoft Ireland Operations Ltd, Dublin, Ireland and Fujitsu A/S, Ballerup, Denmark are following and being audited against the standards of ISO/IEC 27001. The main subcontractor Microsoft has also adopted the international code of practice for cloud privacy, ISO/IEC 27018. The subprocessor E-conomic International A/S is certified in “International Standards on Assurance Engagements 3000” (ISAE 3000).
Cybot will monitor subcontractors’ and subprocessors’ maintenance of these standards and audits to ensure that data protection requirements are fulfilled.
Any intended changes concerning the addition or replacement of subcontractors or subprocessors handling personal data will be announced to you with at least 3 months’ notice. You retain at all times the possibility to object to such changes or to terminate the contract with Cybot.
7.2 Legally required disclosure
Cybot will not disclose the customer’s data to law enforcement except when instructed by you or where it is required by law. When governments make a lawful demand for customer data from Cybot, Cybot strives to limit the disclosure. Cybot will only release specific data mandated by the relevant legal demand.
If compelled to disclose your data, Cybot will promptly notify you and provide a copy of the demand unless legally prohibited from doing so.
8. Third party links
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked websites. Nonetheless, we seek to protect the integrity of our website and welcome any feedback about these websites.
9. Where do we store the information?
No stored data will be transferred, backed up and/or recovered by Cybot outside of the European Union.
9.1. Personal data location
All data are stored in databases and file repositories hosted in an Azure data center at Cybot’s cloud vendor, Microsoft Ireland Operations Ltd in Dublin. All data are automatically replicated in real time to secondary hot failover databases and file repositories in Microsoft’s data center in Amsterdam, Netherlands.
Databases are continuously backed up to enable restore to any point in time within a retention period of 35 days. Backups are stored on file storage at the same geographical location as the database.
A copy of the Account Data is also stored in Cybot’s cloud accounting system, Economic International A/S, Copenhagen, Denmark, hosted in a datacenter operated by Fujitsu A/S.
9.2. Installation of software on cloud customer’s system
No installation of software is required to use the Service. The login-protected Service Manager is accessible through a standard web browser, automatically using an encrypted https-connection for all communications between your browser and Cybot’s server to protect any data from being intercepted during network transfers.
10. Access, data portability, migration, and transfer back assistance
You may at any time obtain confirmation from Cybot as to whether or not personal data concerning you are being processed.
You may at any time order a complete data copy, which you may transmit to another controller of the data. Your data will be delivered within 10 working days by Cybot as spreadsheet files in Microsoft Excel-format. Logical relations between datasets will be preserved in form of unique identifiers. You are required to pay €1,000 + any applicable taxes on delivery for each data copy order.
11. Request for rectification, restriction or erasure of the personal data
You may at any time obtain without undue delay rectification of inaccurate personal data concerning you, cf. clause 5.6.
11.2. Restriction of processing personal data
You may at any time request Cybot to restrict the processing of personal data when one of the following applies:
a.if you contest the accuracy of the personal data, for a period enabling Cybot to verify the accuracy of the personal data;
b.if the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; or
c.if Cybot no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims.
You may without undue delay request the erasure of personal data concerning you, and Cybot shall erase the personal data without undue delay when one of the following applies:
a.if the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
b.if you withdraw your consent on which the processing is based, and where there is no other legal ground for the processing;
c.if you object to the processing in case the processing is for direct marketing purposes;
d.if the personal data have been unlawfully processed; or
e.if the personal data have to be erased for compliance with a legal obligation in EU or national law.
12. Data retention
12.1. Data retention policy
Account Data will due to tax regulations be retained for up to five full fiscal years from your cancellation of your Service account.
Configuration Data and System Generated Data will be erased immediately when you cancel the Service account.
End User Data will be erased on an ongoing basis after 12 months from registration, and immediately when you cancel the Service account.
12.2. Data retention for compliance with legal requirements
You cannot require Cybot to change any of the default retention periods, except for the reasons for erasure pursuant to clause 11.3, but may suggest changes for compliance with specific sector laws and regulations.
12.3. Data restitution and/or deletion
No data except Account Data will be retained after the termination of the contract. You may request a data copy before termination. You must not cancel the Service account until the data copy has been delivered, as Cybot otherwise will not be able to deliver the data copy.
Cybot uses the extensive range of built-in logging features and audits trails provided by Microsoft on its Azure cloud platform. Cybot also logs all system updates, configuration changes and access to provide an audit-trail if unauthorized or accidental changes are made.
You may request a data protection audit performed by an independent third party who is also accepted by Cybot. You will pay €5,000 plus applicable taxes for an audit request along with €200 per hour Cybot is spending in connection with the audit as well as any other costs related to the audit, including the auditor.
Cybot will cooperate with you in order to ensure compliance with applicable data protection provisions, e.g. to enable you to effectively guarantee the exercise of data subjects’ rights (right of access, rectification, erasure, blocking, opposition), to manage incidents including forensic analysis in case of security breach.
15. Terms of Service
Please also visit our Terms of Service section establishing the use, disclaimers, and limitations of liability governing the use of our website at www.cookiebot/en/terms-of-service.
16. Your consent
You may at any time lodge a complaint with a supervisory authority regarding Cybot’s collection and processing of your personal data. In Denmark, you can lodge a complaint with the Danish Data Protection Agency.