Context Broker on Azure Marketplace – Privacy Policy
Data protection and privacy are very important to Sirus NV (hereafter: “Sirus”). With this privacy policy (hereafter: Privacy Policy) Sirus wants to inform you about the processing of your personal data. Sirus shall process the personal data with respect for your privacy and in compliance with the applicable data protection legislations.
Sirus reserves the right to, at any moment, make updates to this Privacy Policy. In order to stay informed of any changes, we ask you to regularly consult this Privacy Policy.
This privacy policy was last updated on: 2/10/2022.
1. Definitions
Processing of personal data: Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly.
A processor: A processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
A controller: A controller is a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
2. For whom does the privacy policy apply?
This Privacy Policy applies to all direct customers, visitors, suppliers, applicants and all other persons who are not employees of Sirus and of whom Sirus processes personal data as controller. For the remainder of this Privacy Policy, an individual belonging to one of these groups is referred to as a “data subject”.
3. Contact Details
| Name | Sirus NV |
| Enterprise number | 0841.451.739 |
| Address | Verlorenbroodstraat 122, 9820 Merelbeke |
| info@sirus.be | |
| Phone number | +32 (0)9 335 76 43 |
4. How we process Personal Data
We process your Personal Data as a Processor on the basis of the instructions of your employer or principal as defined in the Agreement, when you sign up or are signed up by your employer or principal to our Platform when you complete your user account, and where applicable when uploading content on the Platform, as further explained below.
In relation to the above uses, we shall Process your Personal Data on the legal basis determined by your employer or principal, including to enable us to perform our contractual obligations under the Agreement. If you wish to receive more information regarding the legal grounds for processing, we recommend to directly contact your employer or principal, who is, as Controller, solely responsible to foresee such legal grounds in its own privacy policy. Depending on the functionalities you use on our website and the Platform and as deemed relevant by your employer or principal, the following Personal Data might be Processed by Sirus:
4.1. Contact information and account data
| Purpose | Contact information is collected to create a personal account, to allow you to have access (through your account) to the Platform, to communicate, to allow you to participate in interactive features of the Platform, when you choose to do so (e.g. upload manuals, instructions, videos or other documentation, to the extent you are allowed to do so by your employer or principal)), to comply with our obligations in respect to the Platform towards our clients and to enable such clients to use the Platform, to provide support services, notify you about changes to the Platform, including informing you about new versions of the Platform and about new features and functionalities. |
| Type of personal data | First name, name, email address, language preference.
These are the data fields, generally required to create and register an account, however, not every field is mandatory and/or available in every country. |
| Retention term | Contact information will be deleted from Sirus’s databases, upon the active deletion of your user account on our Platform by Sirus’s client, and will in any case be deleted no later than ninety (90) days after termination of the Agreement. In case these Personal Data must be retained for a longer period, then they will be retained for as long as justified for the performance of the Agreement, including as long as necessary to contact the Data Subject or for the legitimate interest of Sirus or the organization pursuant to which you are using the Platform (as applicable). |
4.2. End user data
| Purpose | End user data is collected to comply with our obligations in respect of the Platform towards our clients and to enable such clients and end users to use the Platform. In particular, our clients will assign different user roles to end users. Depending on your user role you will be able to upload content, such as manuals, instructions, videos, pictures, or other documents in order to share practical information, instructions, knowledge and best-practices regarding your profession, job, function etc. |
| Type of personal data | Manuals, videos, pictures, texts, and any other content or documents created by an end user.
This information is provided voluntarily by the end user uploading the information. |
| Retention term | End user data will be deleted from Sirus’s databases, upon active deletion of this Personal Data by the user in their account on our Platform, and will in any case be deleted no later than ninety (90) days after termination of the Agreement. In case these Personal Data must be retained for a longer period, then they will be retained for as long as justified for the performance of the Agreement, including as long as necessary to contact the Data Subject or for the legitimate interest of Sirus or the organization pursuant to which you are using the Platform (as applicable). |
4.3. Analytical and statistical and configuration, system generated and technical information
| Purpose | Analytical data, including history and logs data are collected to comply with our obligations in respect of the Platform towards our clients (i.e. the organization for which you are using the Platform). This includes providing your employer or principal with reports, summarizing information provided during your use of the Platform, and to provide our clients with information on the creation and use of manuals and other content uploaded on the Platform.
Configuration, system generated and technical information is collected for the proper functioning of the Platform, to comply with our obligations in respect of the Platform towards our clients (i.e. the organization for which you are using the Platform) and to enable such clients to use the Platform. Additionally, this data allows us to recognize the end user when logging in and/or using our Platform and website and ensures the efficient use of the Platform and website’s functions, including to enable secure login for you in the Platform, to verify your identity when logging in and to enable you to move around and use the features on our Platform and to remember your preferences such as language settings, login details, etc. |
| Type of personal data | When you use the Platform, we will keep a record of the details of that usage, including the date, time, location, frequency and duration of the usage; other information about your use of the Platform, including the pages you have viewed, searches carried out, browsing behavior, technical information about your computer or mobile device for system administration, including your IP-address, unique device identifiers, User-ID, operating system, browser type, information with regards to your hardware, software and network information and local storage information, the domain name(s) of the website(s) where you implement the Sirus services, website and Platform. This information may be linked to your user profile and/or account (where relevant).
Our Platform and website use cookies and similar technologies for these purposes. For more information, we refer to our cookie policy. |
| Retention term | Technical and analytical information will be deleted upon the active deletion of your user account on our Platform by Sirus’s client, and will in any case be deleted no later than ninety (90) days after termination of the Agreement. In case these Personal Data must be retained for a longer period, then they will be retained for as long as justified for the performance of the Agreement, including as long as necessary to contact the Data Subject or for the legitimate interest of Binders Media or the organization pursuant to which you are using the Platform (as applicable). For information regarding the retention period of Personal Data Processed via cookies, we refer to our cookie policy. |
Additionally, each time you visit our website and/or Platform we may process your personal data as Controller. For instance we may automatically collect information in order to improve our services and for other analytical purposes. The relevant legal basis for Processing this Personal Data is, depending on the relevant situation: (i) Sirus’s legitimate interests or (ii) your consent.
Depending on the functionalities you use on our website and the Platform, the following Personal Data might be Processed by Sirus:
4.4. Analytical, configuration, system generated and technical information
| Purpose | Analytical configuration, system generated and technical data, including history and logs data are collected to ensure the proper functioning and improvement of our Platform and website, (including (without limitation), to tailor our Platform and website to your use, for other statistical and diagnostical purposes, for availability and accessibility of the Platform and website and to monitor the effectiveness of the Platform and website and to ensure the efficient use of the Platform and website’s functions, including to enable you to move around and use the features on our Platform and website and to remember your preferences such as language settings, or consent preferences so that we can automatically read and respect your consent preferences on all subsequent pages and future end user sessions . Personal Data collected from you for these purposes will only be used by us in an aggregated and de-identified format. |
| Type of personal data | When you use the Platform or website, we will keep a record of the details of that usage, including the date, time, location, frequency and duration of the usage; other information about your use of the Platform or website, including the pages you have viewed, searches carried out, browsing behavior, data we obtain from other websites, for example if you ask us to connect with your Facebook account, technical information about your computer or mobile device for system administration, including your IP-address, unique device identifiers, User-ID, operating system, browser type, information with regards to your hardware, software and network information and local storage information, the domain name(s) of the website(s) where you implement the Sirus services, website and Platform. This information may be linked to your user profile and/or account (where relevant).
Our Platform and website use cookies and similar technologies for these purposes. For more information, we refer to our cookie policy. Some of our webpages may contain electronic images known as Web beacons (sometimes known as clear gifs) that allow us to count users who have visited these pages. Web beacons collect only limited information which includes a cookie number, time and date of a page view, and a description of the page on which the Web beacon resides. We may also carry web beacons placed by third party advertisers. |
| Retention term | The retention period of the above described data is dependent on the purpose for which it is collected and will range from as long as the duration of a session/website or platform visit, to as long as consent is not revoked and as long as necessary to contact you or for the legitimate interest of Sirus (as applicable).
For more details regarding the retention term you may always send an email to support@sirus.be |
4.5. Contact information
| Purpose | Contact information is collected to provide support services answer questions and data subject requests and to investigate possible complaints about our products or services, to establish a primary channel of communication with you and to manage our client relations, including to notify you about changes to the Platform and website and new versions of the Platform and website and about new features and functionalities, for direct marketing purposes, including to send promotional emails about our products and services, special offers and other information which we think might interest you (to the extent you subscribed to our newsletter) and to contact you for market research purposes from time to time. Additionally this data is processed serving as proof for your consent or the withdrawal thereof. |
| Type of personal data | Basic contact details are collected such as first name, name, date of birth, birthplace, nationality, phone number, e-mail address, address however, not every field is mandatory and/or available in every country.
Additionally the date and time of consent, URL from which the consent was submitted, user agent, including your IP-address, unique device identifiers, User-ID may be collected, serving as proof for your consent or the withdrawal thereof. |
| Retention term | Contact information will be retained as long as consent is not revoked and as long as necessary to contact you or for the legitimate interest of Sirus (as applicable).
For more details regarding the retention term you may always send an email to support@sirus.be |
4.6. Business administration and legal compliance
| Purpose | We use your Personal Data for the following business administration and legal compliance purposes:
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| Type of personal data | Name, role and contact details of end users.
Other types of Personal Data, depending on the legal obligation concerned. |
| Retention term | Business administration and legal compliance data will be retained up to five (5) years after the expiry or termination of the client relationship or as long as legally required. |
Where Personal Data of third parties are disclosed via the Platform, the person communicating the Personal Data guarantees that he or she has informed those third parties and that he or she has received all necessary consents to communicate the third parties’ Personal Data to Sirus.