Privacy Policy

Last update: June 30, 2014

We, Edhub, Ltd. (“Edhub” , “we”, “us” or “our”)) are committed to protecting your personal data and being transparent about what data we process about you, and therefore have created this Privacy Policy Declaration  (“Declaration“).

Edhub is a technology company behind the website located at www.perpetto.com including its successor domain names or sites (the “Site“), the Perpetto platform, as well as a number of related services under the brand name Perpetto (“Perpetto”) for enabling and optimizing social connectivity and user intelligence on third party websites and apps across the Internet and mobile (collectively called “Services“).

This Privacy Policy Declaration applies to the Site and the Services.

Edhub uses data collected through the Product about the end users (“End User Data”) in order to make the Product accessible and available to our Clients and End Users and have other rights except for the described ones.

Clients of Edhub can be any legal entities (“Clients”), which own, control, operate or support internet websites or mobile applications that perfrom advertising or other activity aimed towards the visitors and registered users (“End Users”) of these internet websites or mobile applications.

The terms of this Privacy Policy Declaration are incorporated by reference in the Terms of Service that you accept upon registration for the Services (the “Terms of Service“). By accepting the Terms of Service, you accept the terms of this Declaration. Capitalized terms not defined in this Declaration shall have the meaning set forth in our Terms of Service.

 

What does this Privacy Policy Declaration Cover?

The purpose of this Privacy Policy Decration is to give you a clear explanation about how Edhub uses profile, activity and social data that we gather when you are using Services. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

Personal Data” as used in this Privacy Policy Declaration, is information that allows a person to directly identify an individual, such as a name or email address, as well as other information that is capable of indirectly identifying an individual.

It is important for you to read this policy in full to understand what information we process about you, how we may use it and how you can access, update and delete your personal data. However, if you don’t have time to read the whole policy now, here are the main reasons we collect different types of information about our users:

  • To help us monitor and improve our Services;
  • To help Clients provide you with a more personalised experience, such as making recommendations or telling you what specific content you might like or sending you personalised news about their content or products, where you have signed up to receive such news.
  • To help Clients sell their online advertising space better and be able to put this advertising revenue back into better services they provide to you.

Compliance with laws and your rights

The legal requirements regarding data protection are contained in the Data Protection Act (in force from January 2002, as amended from time to time) and in Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data .

Broadly, the laws require that:

  • You agree your data to be processed which in general terms means to be collected, used, oraganized and stored;
  • You agree to processing of information which is capable of identifying you indirectly (such as IP addresses)
  • No more information than is required is asked of you;
  • Your personal information must be securely kept to prevent unauthorised access;
  • You have a right to know what information an organisation holds about you;
  • Your personal information must be deleted when it is no longer required; and

 

How Edhub operates?

Edhub acts as an agent or back-end vendor of the Client’s website or mobile application, to which the End User of our Client granted the permissions (if applicable), and Edhub is storing the End User Data on the Client’s behalf. We do this only at the request and direction of the Client.

Our mission is to allow businesses around the world to understand who their users really are and what they are interested in without compromising each person’s right to privacy.

Our Services enable our Clients to

  • easily connect their websites to major social networking platforms (Facebook, Twitter, LinkedIn, Google+, etc.), email providers and other third party identity providers (“Identity Providers”);
  • offer End Users on-site (or in-app) authentication through Social Login buttons (“Social Login”);
  • analyze the website’s users profile, activity and social data to build a notion of a company’s End User profiles and general interests (“User Intelligence”); and
  • outsource user data storage obtained through Social Login (“Identity Storage”).

 

Information we collect

Types of Collected Data

We collect information on this Site and on websites of Clients using the Services.

While using the Product, Edhub, on behalf of its Client in accordance with its Data Protection Policy, will collect, save and analyse data for users from Identity Providers, from the websites of the Client and its subsidieries as well from other public sources. We perform these activities on Client’s request and in accordance with his directions thereof.

Note: Most of the Profile Data or Social Data we collect is already existent about you on the Identity Providers’ websites that you use the Services with. It is often protected by privacy settings for your profile on the Identity Provider and you will be explicitly asked to authorise our Client’s website to access it.

Profile Data

When you sign with Social Login on our Site or on a website of our Client you will be asked to choose an Identity Provider (a Social Network such as Facebook for example) to log in with. When you do this you are authorising the Client’s website or mobile application to access certain Profile Information about you stored on the chosen Identity Provider. Depending on the Identity Provider this will include basic Personal Information such as name, email address, date of birth, some of which may be personally identifiable information, as well as other details you choose to share according to your Third Party IdP account settings. Check below the “My choices” section to see how you can restrict the amounts and types of accessible data from a Third Party IdP.

Any Profile Data collected by the Services, including those mentioned above, is subject to that particular Client’s or website’s privacy policy, and we are  merely facilitating the collection, storage and analysis of that information in accordance with the Client’s privacy policy. You should read and be aware of the terms of service, privacy policy, and privacy practices of the website of any Client utilizing our Services. Edhub creates and maintains the level of protection of personal data required by the law.

Usage: This data is used to build a demographic representation of the Client’s End Users, help the Client make informed marketing and to replace the outdated registration method using username and passwords with the more secure authentication through a Third Party IdP.

Activity Data

Usage data

We provide automatic data collection to Clients, similar to those found on most web sites, so that when you visit the Client’s website we receive non-personally identifiable information that allows to track your use of the Site and to collect certain basic information about your surfing habits. This information is associated with a given device and browser, not a particular person, and includes information about your operating system, your IP addresses, browser type and language, referring pages and URLs, keywords, date and time, what sections of a website you visit, and similar information concerning your use of the Site and the Services (the “Usage Data”).

We collect this information automatically by using cookies. Cookies are very useful and do lots of different jobs that help to make your experience on websites as smooth as possible. For more information on cookies, visit www.allaboutcookies.org. Remember, disabling cookies may disable many of the features available on the Service, so we recommend you leave cookies enabled.

Usage: For example, cookies let you move between web pages efficiently, remembering your browsing preferences. By using cookies and understanding your browsing preferences we attempt to figure out potential topics of interest and generally improve your user experience.

Event Data

Certain Activity Data collected by Edhub is also made available directly to us by the Client (“Event Data”). The Client has the ability to manually pass the Events Data to our back-end, or to third party analytics tools (like Google Analytics for example) for additional reporting.

Usage: The Event Data is used to understand what specific pieces of content you spend most time with and create recommendations to the Client so that he improves the products and services offered to you.

Social Data

The Product  may from time to time, on different Clients’ websites, apps and services, request you to authorise Edhub to access more Social Data about you. The additional information we request, will be displayed in the login window and you will be asked to explicitly authorise the Client to access it. This information is generally already existent and provided by the Identity Provider. It might include data such as posts, tweets, shares; Interests preferences such as likes, groups, followers and followed profiles; Previous work, educational background; All this data is referred to as (“Social Data”).

Any Social Data collected by the Services, including those mentioned above, is subject to that particular Client’s or website’s privacy policy, and we are merely facilitating the collection, storage and analysis of that information in accordance with the Client’s privacy policy. You should read and be aware of the terms of service, privacy policy, and privacy practices of the website of any Client utilizing our Services. The specific data fields requested, are also determined by the Client, not Edhub.

Usage: The Social Data is used to understand your general topics of interests and provide our Clients with insights on what topics you consider relevant and interesting.

 

How we use information?

The Product may combine the information about you including, for example, your Profile, Activity and Social Data to build up an unique representation of the types of content and general topics which might be of interest to you.

The Product will use the data we collect about End Users of our Clients in the following ways:

  • To help us monitor, analyse and improve our Services.
  • To build a notion of your interests and preferences.
  • To help us provide insights to our Clients about which content, products and services are most interesting, enjoyable and useful to you, and if they are shared via social networks. The data also helps Clients to identify when errors occur within their products and services, and test different versions of a page or feature to see which one works best.

All of these measures help our Clients:

  • Provide you with a more personalised experience. By looking at the information we have about you, Clients can create a more tailored experience.
  • To inform the way the they commission future content. They will use aggregated and anonymous user data to help marketing and publishing teams understand what type of content users like, so that they can make more of it in the future.
  • To sell advertising on their products and services.
  • Improve their products and services.

By understanding more about you, Clients are able to serve you more tailored, relevant content, recommend you useful products or news and improve your overall user experience. For example, if a Client you have registered with receives information that you are interested in health and beauty topics, you may find that they serve you with health and beauty product advertising or content from time to time.

How long we keep End User Data?

Edhub will retain the data we collect on our Site, the data we collect through our Service, and the data we process on behalf of our Clients for as long as needed to provide our Services. Edhub will retain and use this information as necessary for backup, archival, analytics and to comply with our legal obligations, resolve disputes, and enforce our agreements.

Following termination or deactivation of a Client account, the Client will no longer be able to access any End User Data. If you have any questions about data retention or deletion, please contact support@perpetto.com.

 

How is data shared?

We disclose information collected via the Services to other companies or individuals as follows:

  • We disclose information to Partners who use the Service for their own analytics purposes.For example, we provide our Clients with statistics on specific topics their users are interested in, so that a publisher can understand demand for a specific type of content or so that advertisers can understand the number of people who may be interested in their campaigns.
  • We may disclose information to our subsidiaries, joint ventures, or other companies under common control with us, in which case we will require them to honor this policy
  • In the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, we expect that any and all information that we have will be among the assets transferred;
  • We disclose information to third-party service providers (e.g., data storage and processing facilities) in order for those service providers to perform business functions for us or on our behalf;

Whether you are an End User or a Client, with this Declaration you acknowledge that End User Data can be extended with End User Data from any web site or mobile application of the Client.

 

Consent and Data Protection

Information Transfer

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside Bulgaria and choose to provide information to us or use the Services, please note that we transfer the information, including Personal Information, to the European Union and especially Bulgaria and process it there.

When you use the Services, you are consenting to that transfer.

Keeping your data safe

Perpetto maintains strict administrative, technical and physical procedures to protect data stored in our servers, which are located in the European Union. Access to data is limited (through user/password credentials) to those employees who require it to perform their job functions. We use industry-standard Secure Socket Layer (SSL) encryption technology to safeguard the account registration process and sign-up information. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to building and files.

 

What control do I have?

You can always revoke Edhub’s future access to your data and respectively the Client’s future access to your data with the Product by accessing the social network or Third Party IdP you used to log in to a Client’s website, head to the account settings page and disable that Client’s application that you have authorised.

Edhub will then delete any non-public Third Party IdP data you have shared with the Client’s website. You may still receive recommendations, offers or other marketing communication from the Client’s products and services, but it won’t be tailored to you.

With this Declaration you give your consent to receive recommendations, offers or other marketing communication from the Client’s products and services once your data was deleted by Edhub.

Please contact the Client whose services you have registered for if you have questions about the Client’s use of your data or technology service providers like Edhub, or just have specific requests concerning your data, such as disabling your account or deleting your data.

 

Questions or Concerns

Deleting or disabling cookies: You may be able to disallow cookies to be set on your browser. Please look for instructions on how to delete or disable cookies and other tracking/recording tools on your browser’s technical settings. You may not be able to delete or disable cookies on certain mobile devices and/or certain browsers. For more information on cookies, visit www.allaboutcookies.org. Remember, disabling cookies may disable many of the features available on the Service, so we recommend you leave cookies enabled.

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to support@edhub.io, or send mail to:

Edhub, Ltd.
56-58 Krum Popov Str.
betahaus Sofia
Sofia, 1421
Bulgaria

We will make every effort to resolve your concerns.

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