I Introduction
This Privacy Policy was last updated on 14.10.2019.
The purpose of this Policy is to inform you how Initiate Sarl c/o C. Colaco (also known and operating as ‘’1 Minute Feedback’’, ‘’Us’’, ‘’We’’) collects, uses and discloses your personal information. When you (‘’User”, ”Customer”, ‘’Website visitor’, ‘’End User’’’) visits our website and logs in to our Platform (collectively ”Services”) you are consequently or voluntarily sharing personal information with Us.
This Privacy Policy, together with our Terms of Use, our Data Processing Agreement (available for EEA and Switzerland upon request), and our Cookie Policy establishes the legal terms and conditions of the agreement between us governing the submission of the information and our use of it in performing the Services. Before using our Services and sharing personal information you need to read and accept this Privacy Policy.
1.0 Definitions
“Applicable Law” – means any Law governing the performance of this Privacy Policy. Users situated in the EEA (meaning European Union, Island, Norway and Liechtenstein) and Switzerland have additional privacy rights that are governed by the Regulation (EU) 2016/679 (”General Data Protection Regulation”, ”GDPR”) and by their local Applicable Laws.
“End Users” – your employees, consultants or independent contractors, affiliates and respondents who are authorized by you to use the Services in accordance with our Terms of Use and Privacy Policy.
“Controller” means the natural or legal person, public authority, agency or other bodies which, alone or jointly with others, determines the purposes and means of the Processing of Personal Information. You are considered to be a data controller in our relationship when you use our Platform.
“Processor” means a natural or legal person, public authority, agency or other body which Processes Personal Information on behalf of the Controller. 1 minute feedback is data processor when processing your request for feedback and report generation through our Platform.
“Processing” – is any operation or set of operations which are performed on Personal Information or on sets of Personal Information, whether or not by automated means (collecting, storing, aggregating, sharing etc.).
‘’Personal Data Breach’’ – is a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information transmitted, stored or otherwise processed.
“Staff” means any natural person or legal entity employed or contracted by us (including, but not limited to employees, interns, contract employees, consultants and volunteers).
“Third Party” means a natural or legal person, public authority, agency or body other than the yourself, End User, Controller or Processor.
2.0 Summary
Privacy of your information is our top priority. In this section we will explain how we collect, use, and share your personal Information and personal information belonging to End Users.
We are responsible as a data processor for the information that exists on our Platform and as a data controller for our Website and visitor data (collected through cookies or similar technologies and various contact forms and sign ups).
As a Controller, we determine the purposes and means of the Processing of Personal Information while as a Processor we processes Personal Information on your behalf.
This Privacy Policy will help you understand:
3.0 How we collect Personal Information
When you use our Website, we may collect information regarding your visit from your device (i.e. desktop, mobile etc.), store cookies and similar technologies on your device and browser or try to reach out in some way. Such information helps us to determine information about how you found our website, the date you visited our website and search engines that may have led you to our website. We collect this information to continually improve and enhance the functionality and security of 1minutefeedback.com.
When you gain access to our Platform, we may use your personal information and personal information belonging to End User to provide you with our service, offer support and make your experience more enjoyable and secure.
3.1 Personal Information You Choose to Provide
In order to make your visits to our website as enjoyable as possible, we may ask you for personal information. Personal information includes, for example, your name and e-mail address, both of which you will be asked to provide if you e-mail us through a contact form on our website. We ask you for information so we can respond to your questions and comments. If you choose to correspond with us via e-mail, we may retain the content of your e-mail messages, your e-mail address and our response to you. In certain cases, and with your permission, we may post content from your e-mails to us on the website.
We also collect the following information to provide a value-added service to all of our Users. This information includes:
User Information
We collect your name, e-mail address, password, the name of your organization and specific information related to your role in your organization including management level, region, country, function and unit.
Respondent Information
A User will enter your e-mail address and may enter your name so that we can send you a personalized request to provide feedback to the User based on the questionnaire they would like you to complete.
Billing Information
We collect your organization’s bank account information or may collect an individual’s credit card information including card number, the cardholder’s name, billing address, the expiry date and security code.
Questionnaire Data
We collect and store the feedback you submit including your comments. If you have a question about the feedback you are being asked to provide, we encourage you to contact the person who sent you the request for feedback. This information is used to generate Reports that may contain personal information about feedback provided by you and your team members, respondents and other End Users.
3.2 Personal Information Collected Automatically
Our main goal is to make you to feel safe and to provide you with ease of use while you are on our Platform. For this reason, we are constantly developing new features and adjusting your user experience while at the same time carefully monitoring for safety issues. In order for us to keep you and End Users safe and happy we may automatically collect certain personal information.
Cookies
When visiting our website, we may use cookies on or in connection with our website to maintain information about you. A cookie is a very small text document, which often includes an anonymous unique identifier and additional information. Cookies are used to assist in collecting information associated with the use of the website, such as which web pages are visited and the duration of a user session.
You will find out more about our use of cookies in our Cookie policy.
Clear GIFs
When you visit 1 Minute Feedback, we may also use “Clear GIFs” (a.k.a. “web beacons” or “pixel tags”) or similar techniques in our website and/or in our communications with you. A clear GIF is typically a one-pixel, transparent image located on a web page or other type of message that helps us to verify an individual’s viewing or receipt of a web page or message. Clear GIFs allow us to know whether you have viewed a web page prior to visiting our website and may enable us to relate such information to other information, including your personal information. We use information provided from clear GIFs to allow more accurate reporting, improve the effectiveness of our marketing and make 1 Minute Feedback better for our users.
IP address and Clickstream data
Our servers automatically collect data about your Internet Protocol address when you visit us. When you request pages from our website, our servers may log your IP address and sometimes your domain name. Our servers may also record the referring page that linked you to us (e.g. another website or a search engine); the pages you visit on this website; the website you visit after this website; other information about the type of web browser, computer, platform, related software and settings you are using; any search terms you have entered on this website or a referral website; and other web usage activity and data logged by our web servers. We use this information for internal system administration, to help diagnose problems with our servers and to administer our website. Such information may also be used to gather broad demographic information, such as country of origin and Internet service provider. Personal information (including IP addresses) is not used to facilitate contact with users who have not provided their contact details to us. Your IP address may be used to identify the clickstream that led you to our site; however, personal information is not shared with any third-party marketing companies.
Various Analytics
Our powerful automation and analytics tools may produce identifiable personal information depending on the number of end user’s data that is included in the equation.
Geographical Information
We may collect your device’s location in order to offer you language options/personalized services.
4.0 How we use the Personal Data we collect
If we need your information for some other purpose that is not related to our provision of services, we will ask for permission first.
We will never sell your information to others.
As a growing business we may utilize your information and metadata derived from your service usage to better ourselves and offer you new features.
Please read carefully and accept our Terms of Use as they also govern how we use your information.
Other than for provisions of our services, general communication, and analytics, we may use your information in the following ways:
- To protect the safety of any person from death or severe injury.
- To prevent fraud or abuse of us or our Users
- To protect our property rights.
- To enforce the Terms of Use, including investigation of potential violations
- If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction, but we will notify you (for example, via email and/or a prominent notice on the Website) of any change in control or use of your Personal Information . We will also notify you of choices you may have regarding the information.
- We may disclose information that we collect when we have a good faith belief that disclosure is reasonably necessary.
5.0 How we share Personal Data that we collect
Service providers
We may use third-party partners to help us operate and maintain our website and deliver our products and services. We may also share your information with our service providers and other third parties (“Affiliated Parties”) that provide products or services for or through this website or for our business (such as website or database hosting companies, address list hosting companies, communications providers, e-mail service providers, third party consultants / feedback drivers, analytics companies, distribution companies, fulfilment companies, credit card processing companies and other similar service providers that use such information on our behalf).
Third-party service providers are contractually restricted from using or disclosing the information, except as necessary to perform services on our or your behalf or to comply with legal requirements. Data may be processed in the European Union, the United States, Canada, India or Serbia depending upon contractual requirements and in accordance with legal jurisdictions for the region(s) to which 1 Minute Feedback is subject.
Full list of our current service providers is available upon request.
Aggregated statistics
We may disclose non-personally identifiable aggregated statistics regarding user behaviour as a measure of interest in and use of our website and e-mails to third parties in the form of aggregated data, such as overall patterns or demographic reports that do not describe or identify any individual user. Information relating to aggregated statistics will be collected through the use of third-party cookies and other third-party tracking devices.
Legally compelled disclosures
We may disclose your personal information if required to do so by law or subpoena or if we believe that such action is necessary (a) to conform to the law, comply with a judicial or court order or comply with legal processes served on us or Affiliated Parties; (b) to protect and defend our rights and property, the website, the users of the website and/or our Affiliated Parties; or (c) to act as needed under the circumstances to protect the safety of users of our website, ourselves or third parties.
6.0 How we store and secure the Personal Data we collect
1 Minute Feedback understands the importance of your personal data. As a result, we have implemented reasonable physical, technical and organizational measures designed to preserve the integrity and security of all information we collect. We also use Secure Sockets Layer (SSL) encryption when transmitting sensitive information. Whilst we endeavour to protect the security and integrity of sensitive personal information provided to this Website, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee information, either during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.
Our systems and Service providers are monitored for vulnerabilities and audited at least once a year.
If you contact us by e-mail or similar feature on the website, you should be aware that your transmission might not be secure. An unaffiliated third party could view information you send by these methods in transit. We accept no liability for disclosure of your information due to errors or unauthorized acts by third parties during or after transmission.
In the unlikely event that we believe the security of your personal information in our possession or control may have been compromised, we may notify you of that development. If notification is appropriate, we shall endeavour to do so as promptly as possible under the circumstances, and (insofar as we have your e-mail address) we may notify you by e-mail.
We employ only highly vetted trustworthy staff to work with our personal information. We have set strict confidentiality and contractual obligations on our teams and they are receiving by annual privacy and security trainings to maintain the highest level on confidentiality and privacy.
7.0 How we transfer Personal Data we collect internationally
Information collected from you may be stored and processed in the EEA, Switzerland, the United States, Canada, Serbia or any other country in which our service providers or we maintain facilities.
Such countries may have laws which are different, and potentially not as protective, as the laws of your own country.
Whenever we share Personal Information originating in the EEA or Switzerland we use suitable safeguards (Standard Contractual Clauses developed by the European Commission, EU-U.S. and Swiss-U.S. Privacy Shield Frameworks).
If you reside in the EEA, Switzerland or other regions with Law governing data transfers, please note that you are agreeing to the transfer of your Personal Information to the United States and other jurisdictions in which we operate.
8.0 How to access and control your Personal Data
Rights to Opt In / Opt Out
You have the right to “opt in” and/or “opt out” of certain of our uses of your personal information. For example, you may have the opportunity to choose whether you would like to receive correspondence from us and/or third-party service providers. Your personal information will not be shared with third-party service providers unless you give consent. You will have the opportunity to opt out of 1 Minute Feedback’s promotional e-mails by clicking the “opt out” or “unsubscribe” link in the e-mail you receive. You can also request this by sending an e-mail through our contact form, specifying whether
- you would like to opt out of receiving promotional correspondence from 1 Minute Feedback in general, or just via e-mail, post and/or by phone, and/or whether
- (ii) you would only like to opt out of specific 1 Minute Feedback e-newsletters or correspondence.
Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.
If you are our User
You can review and update your Personal Information by logging into your account and editing your account profile. You can close your account at any time upon request.
After you close your account, you will not be able to sign in to the Platform or access any of your Personal Data. If you close your account, we may retain certain Personal Information associated with your account comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse or enforce the Terms of Use.
Information stored in routine backups may also be retained for the period those backups are retained in the ordinary course of business.
You can choose not to provide us with certain information, but that may result in you being unable to use certain features of the Platform and Services because that information may be required in order for you to register as a customer, purchase Services, obtain customer support, or initiate other transactions.
If we have already provided your information to a Third Party or a service provider before you have changed your preferences or updated your information, we will notify said Third Party or service provider.
If you Reside in the European Economic Area or Switzerland
You have additional rights available to you under the GDPR and your Applicable Law, including:
Right to access
You have the right to know if we possess and process your personal information. Depending on our relationship we will enable you to access this information ether through our Platform of offer some other suitable way.
Right of erasure
You can request that we erase your Personal Data in certain circumstances. We reserve the right to refuse if we must keep your information for record-keeping purposes, to complete transactions or to comply with our legal obligations, among other things.
Rights to object and restrict Processing
If you receive promotional and non-service-related emails from us you can opt out from further emails by clicking unsubscribe button in the emails footer or by selecting appropriate checkbox in our settings menu.
If you believe that the Personal Information, we hold about you is inaccurate or unlawfully held you can request that we restrict Processing of your Personal Information until you take appropriate legal actions or provide us with correct data.
Right to data portability
Upon your request you will be provided with the Personal Data we hold about you in a structured, machine-readable and commonly used format.
To protect your privacy and security, we may take steps to verify your identity before complying with the request.
Right to file a complaint with your Data Protection Authority
You also have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.
If you want to exercise your rights or receive additional information contact through our contact form.
Breach Notification
In the event of data breach that might result in harm to a natural person or may result in the unauthorized access, use or disclosure of Personal Information belonging to you or your End Users, we will promptly investigate the matter and notify you of such breach.
We are responsible for notifying you and, as applicable, any other parties of any security breach in accordance with Applicable Law.
9.0 Other important privacy information
Third Parties
When you are on this website, you may have the opportunity to visit or link to other websites, including other websites operated by us or by unaffiliated third parties. These websites may collect personal information about you, and (because this privacy policy does not address the information practices of those other websites) you should review the privacy policies of such other websites to see how they treat your personal information.
Social Media Features
Our Website may include, from time to time, social media features, such as Twitter , Facebook, Instagram and LinkedIn buttons and widgets, such as “share” buttons or interactive mini-programs that run on our Website and Platform. These features may collect your IP address, which page you are visiting on our Website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a Third Party or hosted directly on the Platform. Current Cookie policy holds information related to these features and options how to opt-out from them.
Our Policy Toward Children
This website is not directed at children under the age of thirteen. We do not knowingly collect personal information from children under the age of thirteen on our website. If we become aware that we have inadvertently received personal information from a visitor under the age of thirteen on our website, we will delete the information from our records.
Changes to our Privacy Policy
1 Minute Feedback may periodically update this policy. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your 1 Minute Feedback primary account holder account or by placing a prominent notice on our site.
Notice to End Users
Our Services are intended for use by businesses that are our users. Where the Services are made available to an End User through our customer (e.g. an employer, someone asking for feedback, sharing link for questionnaire), our User is the administrator of the Services and is responsible for the accounts and/or Services over which it has control. End Users should direct data privacy questions to their administrators, as their use of the Services is subject to that business’s policies. If we receive privacy related requests from End Users, we will promptly notify administrators and enable them to act accordingly.
Contacting Us
If you have any questions or comments about this privacy policy, or if you would like to review, delete or update information we have about you or your preferences, please contact us through our contact form.