1. Roles and Scope
When providing the Conlumina Reviews service, Conlumina acts as a data processor on behalf of its customers. In such cases, the customer is the data controller and is responsible for the processing of personal data, including the legal basis and communication with data subjects.
This Privacy Policy applies only to situations where Conlumina acts as a data controller, such as when you:
- Visit our website
- Contact us directly
- Register for or manage an account
If you receive a review invitation or interact with a review, the relevant customer is responsible for the processing of your personal data.
2. Personal Data We Collect
When acting as a data controller, we may process the following categories of personal data:
- Contact information (e.g. name, email address)
- Account information
- Communication data (e.g. messages sent to us)
- Technical data (e.g. IP address, browser type, device information)
3. Purpose and Legal Basis
We process personal data for the following purposes:
- Providing and managing the Service
- Responding to inquiries and support requests
- Improving and securing our website and Service
- Managing customer relationships
The legal basis for processing is typically:
- Performance of a contract (Article 6(1)(b) GDPR)
- Legitimate interests (Article 6(1)(f) GDPR), such as improving our services and communicating with customers
4. Use of the Service
When customers use the Service, they may upload personal data about their own customers. In such cases:
- The customer acts as data controller
- Conlumina acts as data processor
- Processing is governed by a separate Data Processing Agreement (DPA)
Conlumina does not use such data for its own purposes.
5. Sub-processors and Third Parties
We may use third-party service providers to operate our website and Service, including providers of hosting, infrastructure, communication delivery, and analytics.
These providers may process personal data on our behalf and are bound by appropriate data protection obligations.
A list of sub-processors is available upon request.
6. International Transfers
Personal data may be transferred outside the EU/EEA where necessary to provide the Service. In such cases, appropriate safeguards are implemented in accordance with applicable law.
7. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, or as required by law.
Personal data processed on behalf of customers is retained and deleted in accordance with the Data Processing Agreement.
8. Your Rights
Under applicable data protection law, you have the right to:
- Access your personal data
- Request correction or deletion
- Object to processing
- Request restriction of processing
- Request data portability
If processing is based on legitimate interests, you have the right to object at any time.
If you have received a review invitation, please contact the relevant company directly to exercise your rights.
9. Cookies
We use cookies and similar technologies to improve user experience and analyse website traffic. Further information is available in our cookie policy.
10. Contact
If you have any questions about this Privacy Policy or our processing of personal data, please contact us at:
Conlumina Digital
Box 2234
[email protected]
11. Updates
We may update this Privacy Policy from time to time. The latest version will always be available on our website.