Data Protection

CUSTOMER privacy

PRIVACY NOTICE FOR CUSTOMERS

General information

Interactio UAB ("we") are committed to protecting Your privacy and Your data. Transparency and data protection are essential for our business.

This Privacy Notice describes how we process and use the personal data that is related to You. By having a contract with You, we act as a data controller.

Who we are:

• Interactio UAB
• Company code 303303137
• Address Paupio g. 50-136, LT-11341 Vilnius
• City: Vilnius
• Country: Lithuania
• Data protection officer contact: dpo@interactio.io

To understand better about data processing

This Privacy Notice describes how we process and use the personal data that is related to You. By having a contract with You, we act as data controller and data processor. Two possible data processing situations in Your relationship with us:

• When You are our potential, existing, or former Customer, we act as a data controller. This means that we, alone or jointly with others, determine the purposes and means of processing personal data. Responsibility for personal data processing under European Union or Lithuania law lies with us.
• When we process personal data of your end users who use our Remote simultaneous interpretation (RSI) platform “Interactio”, we act as a data processor. This means that You alone or jointly with others determine the purposes and means of processing personal data. We act as data processors on behalf of You. This information you can find in our data processing agreement.

If You have additional questions regarding our processing of Your data, You can contact our data protection officer here: dpo@interactio.io

How Interactio process “Customer account data”

Why do we need your data?

“Customer account data” will be used by Interactio for these reasons:

• To understand who our customers and potential customers are and their interests in Interactio products and services.
• To maintain relationships with our existing and former customers by sharing information about our products and services.
• To inform our customers about changes related to ordered services and products.
• To carry out business operations such as accounting, filing taxes, and fulfilling regulatory obligations.
• To detect, prevent or investigate security incidents, fraud and other abuse and/or misuse of our products and services.
• To use anonymized data from Remote simultaneous interpretation (RSI) platform “Interactio” to do technical analysis and troubleshoot possible service errors in the event and in the future.
• To use anonymized data from the Remote simultaneous interpretation (RSI) platform “Interactio” for further developments of the Services.
• To improve our Customers’ support service and Remote simultaneous interpretation (RSI) platform by collecting feedback after an event.
• To track our customers’ requests and RSI platform incidents related to the provided services, to keep the agreed SLA level.
• To analyse event participants, listeners, interpreters provided requests or incidents.
• To collect Net Promoter Score (NPS) to rate the likelihood of recommending Interactio as a company, product, or service to a friend or colleague.

What data do we collect?

We collect different data related to You when we collect data under the data category “Customer account data”. We collect your data:

• When you visit Interactio website Interactio.io.
• When you subscribe to our newsletter on the website, form a request to receive information about our products
• When you contact our Sales Team or Customer Support Team through email or web chat in interactio.io website
• When you share your data in live events (for example demo calls)
• When you sign up in our Remote simultaneous interpretation (RSI) platform “Interactio” and use it for testing purposes.
• When you rate and share your feedback about Interactio services with us.

We collect the following data types of personal information, and for the following reasons:

• We collect Identifiers, Your name, email information and we create a user ID number, when you sign up or use our remote simultaneous interpretation (RSI) platform “Interactio”.
• We collect Internet and other electronic activity information, such as communications metadata, as You browse our website or use our Remote simultaneous interpretation (RSI) platform “Interactio”.
• We collect Commercial information when we keep track of the services that you purchase from us and our communication history about those services. Our sales team must know information about your purchased services and information related to it. Each customer has a dedicated sales team that takes care of the Customer’s accounts.
• We collect financial information, such as your payment information, when you pay for our services and what services. Be aware that we share this data with our governmental institutions, as this is required by law.
• We collect information that you send to us by email or by entering web chat forms.
• We collect your email address and other electronic data (IP address, browser data, device type) when you subscribe to our newsletter. You can revoke your given consent at any time. You can do this by pressing the unsubscribe button at the bottom of each newsletter.
• We collect Your data when you contact our Sales or Customer Success teams, who keep a record of this communication, including Your contact details and other information You share during the time of the communication. We store this information to help us keep track of the inquiries we receive from You and from customers. This helps to improve our services. Based on this information, we do training for team members. We think that this information also helps us to maintain ongoing relationships with our customers.
• If You attend an event, we might collect your business card for future interaction with You.
• When you visit Interactio website, we automatically collect certain information using tracking technologies like cookies, web beacons, and similar technologies. We use this information to understand how visitors of our websites are using them and which pages and features of the websites are most popular. This helps us understand how we can improve our websites and track the performance of our advertisements. Before entering our website, we will ask your permission to collect defined data. This does not affect strictly necessary cookies. Please see our Cookie Policy for more details on our use of cookies and tracking technologies. We do not sell this information to third parties.

How long do we store “Customer account data”?

We will store your “Customer Account Data” as long as needed to provide You our services and to operate our business. If you ask Us to delete personal information from your Customer Account Data, we will honor this request unless deleting that information prevents us from carrying out necessary business functions, like billing for our services, calculating taxes or conducting required audits, securing our information systems. Please, be aware that we will not be able to delete anonymized data.

Below we explain how long we store Customer Account Data in a form that can be used to identify you. Please understand that we might keep data longer in cases of specific needs or obligations like in the case of an open investigation, audit, or other legal matter:

• Commercial information stored in our customer relationship management system(s) is stored up to 5 years following the closure of your account.
• Invoice records, including their digital equivalent, may be retained in identifying form by us for 10 years.
• Subscriber records, such as an email address or identifying information, will be retained for 3 years.
• We retain your communications with Customer success teams for up to 3 years after your account is closed.
• For the data not mentioned above, we will either delete other Customer Account Data at the remote simultaneous interpretation (RSI) platform “Interactio” or transform it such that it can no longer be used to identify You within 30 days following the closure of your account.
• We keep personal information related to incidents as long as the incident or request is
• We keep Net Promoter Score (NPS) data for 12 months.

Who has access to personal data?

The data will be stored in the system of Interactio and other internal systems used by Interactio. The data will be indirectly available to third companies engaged by Interactio or with whom Interactio cooperates in the provision of platform administration, maintenance services, application services which help Interactio manage the information received in the system more effectively. We maintain an up-to-date list of the names and locations of all processors. This list is below:

Processor

Types of data accessed Purpose for the data access Data location

PURPOSE FOR THE DATA ACCESS

DATA LOCATION

Digital Ocean Personal data contained in communications customers send or receive in remote simultaneous interpretation (RSI) platform “Interactio” Provides media streaming functionality in remote simultaneous interpretation (RSI) platform “Interactio” EU OVH Hosting Personal data contained in communications customers send or receive remote simultaneous interpretation (RSI) platform “Interactio” Provides media streaming functionality in remote simultaneous interpretation (RSI) platform “Interactio” EU Salesforce Personal data related to Commercial information, purchased services Provides customer relationship management functionality EU Salesloft Personal data related to Commercial information Provides sales engagement functionality EU Hubspot Name, email address, company name, country, title, phone number browser data, IP address Provides platform for marketing activities EU GOOGLE Personal data contained in communications customers send or receive through email services Provides email and data storage functionality EU Amazon web services Personal data contained in communications customers send or receive remote simultaneous interpretation (RSI) platform “Interactio” Provides service functionality in remote simultaneous interpretation (RSI) platform “Interactio” EU Directo Financial information, such as your payment information, when you pay for our services and what services Provides accounting system functionality EU SurveyMonkey Company name, email address, your written responses to our questions about services Provides survey tools for data collection EU Hotjar User email address, name, User feedback rating and written comments Collects Panel end-user feedback to gather feedback to improve product experience EU/EEA DocuSign Company name, company email, name, contact telephone, contact email Provides electronic signature functionality EU Atlassian Corporation Plc Company name, contact name, phone number Provides a service desk system to track fulfillment requests EU Zoho Corporation B.V Company name, contact name, phone number, Ticket number, information provided in the ticket. Provides a service desk system to track received requests/emails, track SLA responses to it. Keep email history and help analyze it EU Planhat Company representative contact data and opinions about Interactio services. Interactio service and customer data management and automation EU

Data transfer of your data

Interactio may transfer your Personal Data to countries other than in European Union. We deploy the following safeguards when we transfer personal data from European Union jurisdiction:

• European Union Model Clauses. Interactio uses European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the European Union;
• Adequacy decisions, whether a country outside the EU offers an adequate level of data protection.

How do we secure your data?

We use appropriate security measures to protect the security of your personal information both online and offline. We take measures to ensure service providers that process personal data on our behalf also have appropriate security controls in place. Our product remote simultaneous interpretation (RSI) platform “Interactio” is designed, implemented and operated based on most commons industry standards and practices. We value partnership with, so we want to make our commitment to You:

• Interactio makes services available 95% of the time, except for maintenance or as otherwise provided in the service level agreement (SLA) described in the service contract.
• Interactio splits platform infrastructure within multiple geographically diverse availability zones/regions.
• Interactio encrypts data in transmission using transport layer security (TLS) or other technologies over public networks.
• Interactio maintains commercially reasonable administrative, technical, organizational, and physical measures to protect the security of customer data against anticipated threats.
•  Interactio encrypts Confidential data stored within the production services with advanced encryption standard (AES) encryption.
• Confidential data stored within the production services are retained per customer defined retention policies.
• Disaster recovery plans are in place and tested regularly.

What rights do you have?

Data subjects have data protection regulation issued rights in relation to their personal data. Subject may have the right to request access to Information, as well as to seek to update, delete or correct this Information unless there are any exemptions provided by law. Processing of your Personal Data Interactio relies on its legitimate interests, some data processing is required by law, other data is processed to maintain contractual relationships as it is described above. If you have questions how data is processed by Interactio please contact by email dpo@interactio.io.

Data protection authority

You also have the right to lodge a complaint with your local data protection authority or the Lithuanian Data Protection Inspectorate, which is Interactio lead supervisory authority in the European Union.

Lithuanian Data Protection Inspectorate

L. Sapiegos str. 17, Vilnius, Lithuania

Email: ada@ada.lt

Web site: www.ada.lt

Contact us

Please also feel free to contact Interactio if you have any questions about this Privacy Notice or if you are seeking to exercise any of your statutory rights. Our data protection officer will respond within a reasonable timeframe. You may contact us at dpo@interactio.io.