Dealing with customers and visitors is a matter of trust. We value the confidence you have placed in us and consider it an important obligation to handle your information carefully and protect it from any misuse. In this privacy statement we would like to inform you about the way in which we store certain types of data and how we use this data – of course, this is done in compliance with current data protection legislation. This privacy statement clarifies the nature, scope and purpose of the collection and use of personal data on the website of Small Improvements Software GmbH, Rosenthaler Str 23, 10119 Berlin.
Collecting and processing of personal data
In principle, you can visit our website without telling us who you are. Every time a user accesses a page on the internet and every time a file is opened, information about this process is stored in a log file. This is not personal information as we cannot determine which user has accessed what data.
- Name of the website
- Date and time of opening the file
- Amount of data transfer
- Description of the type of web browser used
- Operating system of the user
- Device ID
- IP address and the requesting provider
Personal user profiles cannot be created from this data. The saved data is only gathered for statistical purposes. However, we reserve the right to check the log data subsequently if there is a legitimate suspicion of unlawful use.
When you register with Small Improvements, information is needed to set your account. This includes:
- Company name
- Email address
Small Improvements uses the collected information for processing your order, billing and service improvements. We collect and process contact details when inquiries are made through our web form, if such details are necessary for processing. These include:
- Email address
Purposes of collection and processing
Small Improvements is a processor of Customer Data and the Customer is the controller. The Customer may, for example, use our Services to grant and remove access to a feature, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services. Small Improvements uses the personal data you have provided to
- respond to investigations, court orders or legal process
- to investigate, prevent or take action regarding illegal activities, suspected fraud, or potential threats to the physical safety of any person,
- to prevent violations of Small Improvements’s terms of service, or
- as otherwise required by law.
Any transfer of personal data to state institutions and authorities will take place only as required by national legislation.
Small Improvements will send a welcome email, as well as emails regarding the status of a person’s performance review, 360 degree reviews, objectives etc. All emails may be disabled by either the recipient in their settings page, or company-wide by the system’s administrators. Administrators will at times receive Small Improvements product related announcements in order to inform about upcoming changes. These emails can be unsubscribed from at any time as well.
If you are making use of our Services, during typical use we will only collect the data that we need to provide those services. If we ask for further information, it will be provided voluntarily. We only process personal data in order to carry out the requested service and to protect legitimate business interests. All of your data remain private and confidential.
Legal basis for the processing
The legal basis for the processing of your personal data is the contract or contract initiation ratio pursuant to Art. 6 para. 1 lit. b DSGVO. This data is collected and processed only to the extent required by law. As far as further data may not be required directly for the execution of the contractual relationship, the processing is based on a legitimate interest of the company according to Art. 6 para. 1 lit. f DSGVO, such as direct marketing or improving customer loyalty or customer support.
In individual cases, we may also obtain your consent (Art. 6 (1) a; Art. 7 GDPR) in the processing or transmission of your data. Your consent in these cases is voluntary and unless otherwise agreed, may be rescinded for the future at any time.
Place of data processing
Small Improvements is an international company. Therefore, personal data could be transferred to the corporate office to perform data processing tasks. In addition, the use of various service providers may also result in the processing of your data in European and non-European countries. If this is the case, sufficient contractual agreements and guarantees have been made to allow for data processing within the legal framework.
Sharing of information
Customer Access. Administrators, Authorized Users and other Customer representatives and personnel may be able to access, modify or restrict access to the account. This may include, for example, your employer using service features to export logs of activity, or accessing or modifying your profile details. For information about your profile settings, please see your setting page.
Third Party Service Providers and Partners. Small Improvements may engage third party companies or individuals as service providers or business partners to process the service and support our business. These third parties may, for example, provide virtual computing and storage services. Additional information about the subprocessors we use to support delivery of our services is set forth at our list of subprocessors.
Third Party Services. Customer may enable or permit Authorized Users to enable Third Party Services. When enabled, Small Improvements may share information with Third Party Services. Third Party Services are not owned or controlled by Small Improvements and third parties that have been granted access to information may have their own policies and practices for its collection and use. Please check the privacy settings and notices in these Third Party Services or contact the provider for any questions.
This website and Small Improvements platform use Google Analytics, a web analytics service provided by Google, Inc. (“Google”).
Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website is usually transmitted to and stored by Google on servers in the United States.
Please note that we use a setting called “anonymizeIP” in order to mask your IP address before sending it to Google Analytics. You can opt out from collecting data about the usage behaviour in the platform in your individual settings page.
Small Improvements only stores your data for as long as it is necessary to fulfill the above-mentioned purposes or until you object to the data processing. Thereafter, the data will be deleted or blocked if the deletion conflicts with statutory provisions or legitimate interests. A legitimate interest exists e.g. regarding the assertion, exercise or defense of legal claims.
Small Improvements takes the security of your data very seriously. To protect the data you have given us from accidental or intentional manipulation, loss, destruction or access by unauthorized persons we have implemented different technical and organizational measures according to Art. 32 GDPR. Our security measures are continuously improved in line with technological developments. Access is limited to a few authorized personnel who are specifically committed to dealing with data privacy and are involved in the technical, administrative or editorial management of this data. Find out more about how we handle your data on our security information here.
To the extent prohibited by applicable law, Small Improvements does not allow use of our services by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.
According to Art. 15 to 23 GDPR, you have the unlimited right to access information about your stored data as well as a right of correction, deletion or blocking of data as well as obligation and the right of data portability if possible.
Upon request, we are happy to provide you with written information about whether or not we have stored personal information about you, as well as which information in particular. Where possible, we will take appropriate steps to update or rectify your data stored with us, at short notice. In such cases, please contact us at firstname.lastname@example.org.
As an affected person, you have the right the right to lodge a complaint with a supervisory authority. The supervisory authority that files the complaint will notify you of the status and outcome of your complaint, including the possibility of a judicial remedy.
User declaration of consent
By using our website and the offers contained therein, you hereby agree that you have voluntarily provided us with personal data that we have stored and will process and use in accordance with this privacy statement.
Any other questions?
You may also contact our data protection officer directly, who will be happy to provide you with further assistance:
DataSolution LUD GmbH
T.: +49 (0) 3378.205729
Last updated: May 2018
Please also see our terms of service.