PRIVACY POLICY

AELBOX Ltd. is a limited liability company incorporated and existing under the laws of the Republic of Bulgaria, registered in the Commercial Register and Register of Non-Profit Legal Persons with UIC 203733878, with a seat and a registered address in Bulgaria, Sofia 1379, zh.k. Serdika, building 13, floor 11, apt. 42, engaged in the provision of Planning Poker, also called Scrum Poker, through https://scrumpy.poker/ (the Website).

In carrying out our activities, the protection of your data is a top priority for us, and therefore we strive to process it to the necessary minimum and only for a limited period of time, by applying appropriate technical and organisational security measures. We value the privacy of your life and the confidentiality of your data.

1. Personal Data Controller
2. Types of Processed Data
3. Way of Processing
4. Your Rights
5. Storage of Personal Data
6. Current Version
7. Personal Data Controller

“Personal Data Controller” is a person who alone or jointly with another person determines the purposes for which personal data will be processed (collected, used, and retained) on paper or in electronic form.

We will act as a personal data controller in connection with the provision of our services; processing of your requests, applications and complaints; dispute resolution; implementation of our legal/ legitimate interests.

In certain cases, we may process your personal data as a joint controller with other controllers or assign the data processing to subprocessors.

Contact address: Bulgaria, Sofia 1379, zh.k. Serdika, building 13, floor 11, apt. 42

You can contact us by email at info@scrumpy.poker

On any issues related to the collection and processing of your personal data you can refer to the personal data authority in your country of residence.

2.      Types of processed data

In the course of the provision of our services we process the following data:

name, email address and your data in your social network account if you choose to sign-in using the latter.

For the purposes of communication, the following data will be processed: your name, your email address, your phone number, your IP address, signature (in case of written communication).

We process personal data about you when considering your complaints/requests and resolving disputes with you – because it is important for us to approach individually your requests and complaints and respond to your expectations and needs in the best possible way.

While using our Service with third-party systems integration like Jira and Confluence, we may temporarily (only during the refinement/planning session for performance reasons) collect particular data (“External Data”), but not limited to:

• Jira ticket number
• Jira ticket title
• Jira ticket summary
• Jira ticket assignee name
• Jira ticket status
• Confluence space name
• Confluence page title

We do not collect and process sensitive data. Please, do not submit any sensitive data using our contact details.

We apply the principle of minimising the processing of personal data.

However, it is important to inform you that when you visit the Website, we collect information about you which can be qualified as personal data only when processed in combination with other information about you, collected through the Website. This data is processed in connection to your activity as a user of the Website and/or in connection to the functioning of the Website and the proper provision of services you have requested generally provided through the Website (temporary data (cookies) and other technical data stored on your device and used by the browser opening the Website). Such other data include the following specific information:

• information about your browser;
• information obtained through cookies files, used pixel tags and other technologies; and
• demographic and other information, provided by you; and
• aggregated information from the use of the Website.
• Please refer to our Cookies Policy.

3.      Way of Processing

The purposes for which we process your personal data are:

• to provide and maintain the Service;
• to notify you about changes to our Service;
• to allow you to participate in interactive features of our Service when you choose to do so;
• to provide customer care and support;
• to provide analysis or valuable information so that we can improve the Service;
• to monitor the usage of the Service;
• to detect, prevent and address technical and other issues;
• to fulfill our legal obligations;
• to protect lawfull/legitimate interests.

In order to achieve these objectives, we collect information about you in a variety of ways, whereas most commonly personal data is submitted by you.

We process your personal data by the application of a number of technical and organisational security measures through various processing operations (including, but not limited by: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, alignment or combination, restriction, deletion or destruction) carried out manually and automatically. The type and the way of performing the specific processing operations depend on the purposes of processing and of the business processes related to these purposes.

We guarantee that your personal data will be processed only in accordance with the purposes set out above. In connection with these purposes, your data can be provided/disclosed/transmitted to third parties, acting as controllers, processors or as joint controllers of personal data, such as:

• Government and other public authorities;
• Courts, prosecutors’ offices;
• technical consultants, lawyers, accountants, auditors, and companies which provide specific services (e.g. IT-support, courier or postal services, insurance companies, etc.);
• subcontractors;
• agents and other partners who offer our services.

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. We may use third-party Service Providers to monitor and analyze the use of our Service.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

We will not disclose/pass/ provide your information to third parties, who are not entitled to know data about you.

4. Your rights

As a personal data subject under Regulation (EC) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (“The General Data Protection Regulation”), you have the following rights:

• the right of access to your data – upon your request, we will provide you with information about your data that is processed;
• the right of rectification of your data – in case you find that your data is no longer up-to-date or is incorrect you are entitled to request rectification of such data;
• the right to delete your data (right to be forgotten) – we will  satisfy your request if for us, there is no longer a legal basis to process your data.
• right to restrict processing – in case you have contested the accuracy of the processing of your data, the restriction of the processing applies only for the period in which we check the accuracy of your data; when the processing is unlawful, but you oppose to the deletion of the data; when you objected to the processing and a check if our legitimate interests have a priority over your interests as a personal data subject is expected, if we no longer need your personal data, but you need it to exercise or defend legal claims;
• the right of portability of data – you can ask us to transfer all or part of the data provided by you, to you or to another controller in a form suitable for machine reading when the processing of this data is based on your consent or on the performance of the contract and where the processing is carried out by automated means;
• the right to be informed of security breaches – we will inform you without delay about any security breach of your personal data;
• the right to object against the automated processing of your data, against the profiling and against the processing for purposes of direct marketing – you have the right, at any time and for free, to change your marketing preferences and to withdraw your consent for the processing of your personal data for the purposes of direct marketing, automated processing and profiling;
• the right to withdraw your consent for the processing of personal data – you have the right, at any time and free of charge, to withdraw a consent already given by you for the processing of personal data. We would like you to know that it is possible to continue to process your personal data and following the withdrawal of your consent if other ground for processing exists.
• You can exercise your rights as described by filling out a Form for the exercise of rights under the General Data Processing Regulation, which you can find at the Website and send it to info@scrumpy.poker or send it by post to Bulgaria, Sofia 1379, zh.k. Serdika, building 13, floor 11, apt. 42.

We may request and process certain personal data for the purpose of establishing and verifying your identity in the course of processing your application for the exercise of rights.

Your application for the exercise of rights will be processed in due course, in the most general case for not more than thirty (30) calendar days.

5. Retention of Personal Data

We will retain your personal data to the extent necessary to comply with our legal obligations (for example, for the purpose of compliance with accounting and tax laws), resolve disputes, and enforce our legal agreements and policies but in any case no longer than the maximum period provided by law.

6.  Current version

The current version of this Privacy Policy can be found on our Website as we will notify you of any significant changes that could affect you, by publishing information about the changes. The latest update of this Privacy Policy was 20th of June 2021.