Add Privacy Policy

[jiri-janousek]

• It is not such an issue as we collect only absolutely necessary personal info and don't sell and don't share it with anyone. But we need to be GDPR compliant.
• Info:
  • https://gdprchecklist.io/
  • https://www.gdpr.cz/blog/pristup-k-udajum
  • https://help.shoptet.cz/topic/gdpr-checklist-potrebnych-opatreni/
  • http://gdpr.spir.cz/
• Inspiration:
  • Travis CI
  • Authy
  • Zoho summary, Zoho legal
  • Patreon
  • ZenHub
  • Private Internet Access
  • Mailtrap.io, blog post
  • Stack Overflow
  • Mixcloud
  • Toggl
• Links to the policy:
  • Tiliado account creation - "By submitting this form, you agree with Privacy Policy."
  • Each Nuvola product on Gumroad. "By purchasing this product, you agree with Tiliado Privacy Policy."
  • One time email to existing users.

[jiri-janousek]

Draft of Privacy Policy

Definitions

• We, Our, Us refers to Tiliado project operated as a sole proprietorship by Jiří Janoušek (registered in the Trades Licensing Office of the Czech Republic, ID 03556131).
• Our Services include Tiliado.eu website, Nuvola Apps website, Flatpak repositories, our software, and other services served from tiliado.eu domain and its subdomains.
• Our Software includes Nuvola Apps Runtime, individual Nuvola Apps, and other software managed under Tiliado organization on GitHub unless noted otherwise.
• Our Products include Nuvola Basic, Nuvola Premium, and Nuvola Patron licenses, subscriptions and temporary offers such as free trials and discounts.

General

By using the Website or our Services you consent to the use of your Personal Information as described in this Privacy Policy. Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent. We will not actively collect Personal Information for the purpose of sale or marketing in a way that specifically identifies the individual. In other words, we don't sell customer lists. You may withdraw your consent to our processing of your Personal Information at any time. However, withdrawing consent may result in your inability to continue using the Website and/or the Services.

What information do we collect

We collect personal information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.

• When you connect to Tiliado.eu server: Your IP address, session cookie/token.
• When you submit Tiliado.eu account registration form: Your username, real name/nickname, and email address.
• When you submit Tiliado.eu account preferences form: Your username, real name/nickname, email address, and link to a personal page/profile.
• When you send us an e-mail: Your name and email address.
• When you purchase our product on Gumroad: Your name and email address.
• When you pledge to our product on Patreon: Your name, Patreon profile id and link.
• When you send us a payment via PayPal: Your name and email.
• When you sign up for our mailing list on MailChimp: Your name and email.
• When you communicate with us on GitHub: Your name and username.
• When you choose to link our software to your Tiliado account: It connects to Tiliado server (see above).

We may also collect information that is not classified as personal:

• When you launch Nuvola Runtime without a valid license or subscription: Anonymous app-specific hash of a device identifier, which cannot be used to identify the user of the device nor to track the usage of different applications.
• When our software is built with a telemetry feature, its settings are available in preferences and the feature is not disabled by the user: Anonymous usage statistics and device capabilities as shown in telemetry preferences. If there are no telemetry preferences, no telemetry information is collected and sent.

What do we use your personal information for

How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.

We use your personal information to:

• provide Tiliado services to you and operate our business.
• reply to your questions and provide you with support.
• allow you to sign in to your account and modify account preferences.
• allow you to connect Tiliado software with your Tiliado account.
• link your purchases to your Tiliado account.
• send important information regarding your account (e.g. expiring subscription, changes of terms of service, password reset procedure, etc.).
• conduct research and development to improve our services and develop future products that our users may be interested in by analyzing how you use it.
• log access to the Tiliado website and prevent abuse/malicious requests.
• send newsletters you have subscribed to.
• to advertise you as our customer upon your explicit consent.

Legal bases for processing: If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:

• We need it to provide you the Services, including to operate the Services, provide customer support and personalized features, to protect the safety and security of the Services and to prevent abuse of the Services (GDPR Article 6.1bf);
• It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests (GDPR Article 6.1f);
• You give us consent to do so for a specific purpose (GDPR Article 6.1a); or
• We need to process your data to comply with a legal obligation (GDPR Article 6.1c).

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.

Who we may share your personal information with

We will only share your personal data with the public under the following circumstances:

• Upon your explicit approval in Tiliado account preferences, we may show your name and link to a personal profile in the list of Nuvola Patrons on website, in blog posts, in Tiliado software, in newsletters, and in advertising and marketing materials. You can revoke your approval in Tiliado account preferences anytime.

We will only share your personal data with third parties under the following circumstances:

• To protect the security or integrity of Tiliado, and to protect the rights, property, or safety of Tiliado, its users, or others, if we believe that disclosure is reasonably necessary to comply with a law, regulation, valid legal process (e.g., subpoenas or warrants served on us). If we are going to release your data, we will do our best to provide you with notice in advance by email, unless we are prohibited by law from doing so.
• In connection with the sale, merger, bankruptcy, or sale of assets. We will notify you if a different company receives your personal information. The promises in this privacy policy apply to any data transferred to a new entity.

Your personal data may be stored at following GDPR-compliant service providers inside or outside the European Union according to their privacy policies:

• Wedos (Czech Republic): Wedos Privacy Policy.
• Contabo (Germany): Contabo Privacy Policy
• Google (USA): E-mail communication and a contacts list. Google Privacy Policy.
• Zoho (USA): E-mail communication and a contacts list. Zoho Privacy Policy. Certification: ISO 27001, EU-U.S. Privacy Shield, SOC 2 Type II.
• Gumroad (USA): Purchase details. Gumroad Privacy Policy.
• PayPal (USA): Purchase details. PayPal Privacy Policy.
• Patreon (USA): Pledge details. Patreon Privacy Policy.
• MailChimp (USA): Newsletter subscription. MailChimp Privacy Policy.

How we store and secure information we collect

We use data hosting service providers in the Czech Republic, Germany and the United States to host the information we collect, and we use technical measures to secure your data. While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others. We will respond to requests about this within a reasonable timeframe.

How long we keep information

How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

• Account information: We retain your account information until you delete your account. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve our Services.

• Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences until you unsubscribe from the mailing list.

• E-mail communication: We may keep email communication and any embedded personal data for 15 years (the limitation period under the Czech law) to protect ourselves in disputes/lawsuits.

• Purchases, subscriptions, contracts: We may keep records of purchases, subscriptions and contracts including any embedded personal data for 15 years (the limitation period under the Czech law) to protect ourselves in the case of chargebacks, disputes or lawsuits.

• Free Trials: Free trial offers are bound to anonymous app-specific hash of a device identifier, which we may keep for one year to prevent the abuse of the offers.

Your Preferences and Rights over Data

You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making some of these requests. For all other requests, or where no contact is specified, you may contact us at support@tiliado.eu to request assistance or ask privacy-related questions.

Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.

• Access and update your information: Our Services give you the ability to access and update certain information about you from within the Service. For example, you can access your profile information from your account and update your profile information within your profile settings.
• Delete your account: You can contact us to disable/delete your account and remove associated information. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
• Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don't have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time.
• Disable telemetry in our software: You can disable sending anonymous usage statistics and device capabilities in preferences of the software. If there is no such option, the telemetry feature is not available and no data are sent.
• Remove Marketing Emails: You may unsubscribe from newsletters at any time following the unsubscribe link in a newsletter or directly on MailChimp website. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services.

Our policy towards children

The Services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact our support services.

Changes to our Privacy Policy

We may change this privacy policy from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by adding a notice on the Services homepages, login screens, or by sending you an email notification. We will also keep prior versions of this Privacy Policy in an archive for your review. We encourage you to review our privacy policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this privacy policy, you will need to stop using the Services and deactivate your account(s), as outlined above.

What's New

• We explicitly say what kind of personal information we collect and that we don't sell them.
• We have a new internal policy to remove inactive Tiliado accounts to reduce personal information we store.
• Nuvola Apps may collect anonymous usage statistics and device capabilities in the future. When this feature will be implemented, you will be allowed to opt-out in preferences. We need this to better understand our typical users - what features do they use, which graphic driver is in use, which streaming services are most popular, etc.

Email draft

• By continuing the usage of Tiliado services after June 14, 2018, you agree with Privacy Policy. No other action is required from your side.
• If you don't agree with the Privacy Policy, reply to this email and request account removal. If your Tiliado account does not have any linked purchase, it will be removed completely. If there are any active subscriptions, they will be cancelled and you can then request a refund. If there are any linked purchases, your account will be deactivated so that you wont be able to use Tiliado services. However, we may still keep necessary personal data for 15 years (the limitation period under the Czech law) because of possible chargeback procedures and other disputes/lawsuits.

[jiri-janousek]

https://tiliado.eu/privacy/

[jiri-janousek]

• Added links to https://nuvola.tiliado.eu
• Need to add links to https://tiliado.eu as well

[jiri-janousek]

Done: Need to add links to https://tiliado.eu as well