The privacy of your data is important to us. Therefore we process and use your data in a secure manner in accordance with the General Data Protection Regulation. In this policy, you will find an overview of: what data we collect and why; how your data is handled; and your rights to your data.
This policy applies to all related products built and maintained by ANGKEL GP including ShareBoost. If you have any questions about your privacy or this statement, please contact us.
What we collect and why
Our guiding principle is to collect only what we need. Here’s what that means in practice:
Identity & access
When you sign up for an ANGKEL GP product, we typically ask for identifying information such as your name, email address, and maybe a company name or url. That’s just so you can personalize your new account, and we can send you invoices, updates, or other essential information. We sometimes also give you the option or ask to add a profile picture that displays in our products. We’ll never sell your personal info to third parties.
Billing information
When you provide payment for a paid account for ShareBoost, we ask for your credit card, name, and billing address. That’s so we can charge you for service, calculate taxes due, and send you invoices. Your credit card is passed directly to our payment processor and doesn’t ever go through our servers. We store a record of the payment transaction, which may include the last 4 digits of the credit card number and as-of billing address, for account history, invoicing, and billing support. We store your billing address to calculate any sales tax due in the United States or VAT in the EU, to detect fraudulent credit card transactions, and to print on your invoices, if necessary. Only your email, your country and your name are passed to our servers and databases for your User Account.
Geolocation data
We may log all access to all accounts by full IP address so that we can always verify no unauthorized access has happened. We also may log full IP addresses used to sign up a product account. We keep this record forever for all our services, because they are used to mitigate spammy signups. Web analytics data are also tied temporarily to IP addresses to assist with troubleshooting cases.
Website interactions
When you browse our marketing pages or applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, performed actions, page load timing, and which website referred you for statistical purposes like conversion rates and to test new designs. We sometimes track specific link clicks to help inform some design decisions. These web analytics data may be tied to your IP address and user account if applicable and you are signed into our Services. Other web analytics we utilize are described further in the Cookies and Do Not Track section.
Anti-bot assessments
We may employ the use of CAPTCHA services across our services to mitigate brute force logins and in ShareBoost (shareboost.co) as means of spam protection. We have a legitimate interest in protecting our apps and the broader Internet community from credential stuffing attacks and spam. When you log into your accounts and fill specific forms in ShareBoost, the CAPTCHA service evaluates various information (e.g IP address, how long the visitor has been on the app, mouse movements) to check whether the data is possibly filled out by an automated program instead of a human. We may retain these data ourselves or via our subprocessor forever because they are used for anti-spam mitigation.
Cookies and Do Not Track
We do use persistent first-party cookies to store certain preferences, make it easier for you to use our applications, and support some in-house analytics. We may partner with Google for some marketing activities or other critical functions such as authentication. If you are coming to our services from a Google ad, and are in the United States, Google will send a cookie to your browser to determine whether you visited our websites because of a particular advertisement you viewed. This enables us to evaluate the effectiveness of these ads. A cookie is a piece of text stored by your browser. It may help remember login information and site preferences. It might also collect information such as your browser type, operating system, web pages visited, duration of visit, content viewed, and other click-stream data. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to view which cookies have been set and how to manage and delete them, please visit: www.allaboutcookies.org. Additionaly we may use a third-party services for analytics to better understand user behavior and improve our services. We have a commercial interest in using your surfing behaviour and related data to analyse and improve our service where necessary. At this time, our sites and applications do not respond to Do Not Track beacons sent by browser plugins.
Voluntary correspondence
When you write to our team with a question or to ask for help, we keep that correspondence, including the email address, so that we have a history of past correspondences to reference if you reach out in the future.
We also store any information you volunteer like surveys. Sometimes when we do customer interviews, we may ask for your permission to record the conversation for future reference or use. We only do so if you give your express consent.
We have a commercial interest in using some of your personal data for marketing purposes. We process your email for direct marketing. We process your email when you ask us a support question or when you indicate that you want to be kept informed about our latest blog articles. We will delete this information as soon as you unsubscribe or indicate that you no longer wish to be contacted by us.
Information we do not collect
We don’t collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity, gender expression, or physical and mental abilities or disabilities. You may provide these data voluntarily. We also do not collect any biometric data. You are given the option to add a picture to your user profile, which could be a real picture of you or a picture of something else that represents you best. We do not extract any information from profile pictures: they are for your use alone.
When we access or share your information
Our default practice is to not access your information. The only times we’ll ever access or share your info are:
To provide and improve products or services you’ve requested. We do use some third-party services to run our applications and only to the extent necessary process some or all of your personal information via these third parties.
To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We have an obligation to protect the privacy and safety of both our customers and the people reporting issues to us. We do our best to balance those responsibilities throughout the process. If we do discover you are using our products for a restricted purpose, we will report the incident to the appropriate authorities.
To run our business efficiently and securely. We sometimes will have to share your personal data with other (trusted) parties such as: our accountant, professional advisors from other industries, such as law, finance and IT support, when necessary.
When required under applicable law. ANGKEL GP is a European Union based company. If EU or US law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring we share data, we have to comply. Otherwise, we reject requests from local and federal law enforcement when they seek data. And unless we’re legally prevented from it, we’ll always inform you when such requests are made.
We do not share preserved data unless absolutely required under the Stored Communications Act or compelled by a court order that we choose not to appeal. Furthermore, unless we receive a proper warrant, court order, or subpoena before the required preservation period expires, we destroy any preserved copies we made of customer data once the preservation period lapses.
If we get an informal request from any person, organization, or entity, we do not assist. If you are an account owner who wants to export data from their accounts, you can do so directly by contacting our team through the account email.
If we are audited by a tax authority, we may be required to share billing-related information. If that happens, we only share the minimum needed such as billing and email addresses and tax exemption information.
Finally, if ShareBoost or ANGKEL GP is acquired by or merged with another company — we don’t plan on that, but if it happens — we’ll notify you well before any info about you is transferred and becomes subject to a different privacy policy.
Your rights with respect to your data
At ANGKEL GP, we apply the same data rights to all customers, regardless of their location. Currently some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”) in the US. ANGKEL G.P. recognizes all of the rights granted in these regulations, except as limited by applicable law. These rights include:
- Right to Know. You have the right to know what personal information is collected, used, shared or sold. We outline both the categories and specific bits of data we collect, as well as how they are used, in this privacy policy.
- Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
- Right to Correction. You have the right to request correction of your personal information.
- Right to Erasure / “To be Forgotten”.This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, all of our service providers. Fulfillment of some data deletion requests may prevent you from using our services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
- Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority. To identify your specific authority or find out more about this right, EU individuals should go to https://edpb.europa.eu/about-edpb/board/members_en.
- Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information. (Again: we never have and never will sell your personal data.)
- Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
- Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party.
- Right to not be subject to Automated Decision-Making. You have the right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
- Right to Non-Discrimination. This right stems from the CCPA. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights (such as the right “to be forgotten”) may, by virtue of your exercising those rights, prevent you from using our Services.
Many of these rights can be exercised by signing in and directly updating your account information.
If you have questions about exercising these rights or need assistance, please contact us via email or at ANGKEL GP, Agias Sofias 17, Thessaloniki 54623, Greece. For requests to delete personal information or know what personal information has been collected, we will first verify your identity using a combination of at least two pieces of information already collected including your user email address. If an authorized agent is corresponding on your behalf, we will first need written consent with a signature from the account holder before proceeding.
What happens when you delete data in your product accounts
In many of our applications, we give you the option to delete data. Anything you delete on your product accounts may remain in our database while your account is active. We also have some backups of our application database. Retrieving data for a single account from a backup is cost-prohibitive and unduly burdensome so if you change your mind you’ll need to do so before your data are deleted.
Changes & questions
We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will also announce them on our product blog. This policy, as well as our terms and restrictions are based on the one open-sourced by Basecamp which can found on GitHub. There have been numerous changes by our legal counsel to adapt it to the needs and differences of ShareBoost and our company. Have any questions, comments, or concerns about this privacy policy, your data, or your rights with respect to your information? Please get in touch and we’ll be happy to answer them.