Cobwebs Website Privacy Notice
Cobwebs Technologies Ltd. (referred to as “we”, “us” or “our” in this Privacy Notice) respects your privacy and is committed to protecting your personal data.
This privacy notice (“Notice” or “Privacy Notice”) is designed to inform you as to how we look after your personal data when you visit our website (https://www.cobwebs.com/) (“Website”) and notify you about your privacy rights and how the law protects such rights. For the purpose of this Privacy Notice and to the extent that the GDPR applies, Cobwebs is considered a controller of personal data that it collects in accordance with this Privacy Notice.
In this Privacy Notice, the term “GDPR” means (i) the EU General Data Protection Regulation 2016/679 (the “EU GDPR”) and/or, (ii) the UK Data Protection Act 2018, as well as the EU GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 (SI 2019/419) (the “UK GDPR”).
We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make to the terms of this Privacy Notice. This Privacy Notice supplements other notices we may provide as part of our interactions with you or notices you may have received from other controllers and is not intended to override such notices.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below.
- Identity Data includes first name, last name, company, job title, and country of residence. Career applicants may also provide a curriculum vitae or a link to their LinkedIn profile.
- Contact Data includes email address and telephone number.
- Usage Data includes information about how you use our Website (such as, date and time on which you entered the Website, system specifications and how long you stayed in the Website) as well as your IP address.
- Additional Inquiry Data includes additional information that you may provide when you contact us through the Website.
We also collect, use and share aggregated data such as statistical data for any purpose. Such information does not reveal your identity and therefore is not considered personal data. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature.
Protecting the Privacy Rights of Third Parties
If you provide any personal data relating to others to us, you must make sure that you have permission to do so.
- Direct interactions. You may provide us your Identity Data and Contact Data by entering your details on our Website, including when you apply for open positions that we post on our Website, or by providing such details to Cobwebs representatives in events and conferences.
- Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data on equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Third parties. We may receive personal data about you from third parties, such as Usage Data provided by analytics providers.
You are not legally obligated to provide any personal data to Cobwebs. Any personal data that you choose to provide to Cobwebs, is provided at your own free will.
- Where the processing is necessary in connection with the performance of any contract we have entered into with you or where it is necessary for taking steps at your request prior to entering a contract.
- Where the processing is necessary for our legitimate interests (or those of a third party), and such legitimate interests are not overridden by your interests, fundamental rights, or freedoms. Legitimate Interest means our interest in managing and conducting our business.
- Where the processing is necessary for compliance with a legal or regulatory obligation.
- Where you have provided your consent for such processing.
Purposes for Which We Use Your Personal Data
Below is a description of the ways we intend to use your personal data. To the extent that the GDPR applies, we have included specific information on the legal bases we rely on for such processing and identified what our legitimate interests are where appropriate:
- We use your Contact Data and your Additional Inquiry Data to respond to your request that we will contact you or demonstrate Cobwebs’ services to you. In case this is necessary in order to take steps at your request prior to entering into a contract, the corresponding legal basis for such processing is Art. 6 para. 1 lit. b) GDPR. Otherwise it is our legitimate interest to promote a business relationship with you, pursuant to your request, in which case our processing activities are based upon Art. 6 para. 1 lit. f) GDPR.
- We also use your Contact Data to manage our relationship with you, including by notifying you about changes to our terms or Privacy Notice. We do so for the performance of a contract with you, if it is necessary to comply with a legal obligation or if it is necessary for our legitimate interests. The corresponding legal basis is then Art. 6 para. 1 lit. b) or lit. f) GDPR.
- We use your Identity Data to enter into a contract or to perform a contract with you. Such processing is based on Art. 6 para. 1 lit. b) GDPR.
- We use your Usage Data, Identity Data and Contact Data to deliver relevant advertisements, marketing and other content to you, including via email, and to measure or understand the effectiveness of our marketing efforts. We do so on the basis of your consent pursuant to Art. 6 para. 1 lit. a) GDPR in general. To the extent permissible by law, we may rely on our legitimate interest to grow our business and to inform our marketing strategy. The legal basis for processing is Art. 6 para. 1 lit. f) GDPR then.
- We also use your Usage Data to improve our Website, products/services, marketing, customer relationships and experiences. We do so on the basis of your consent pursuant to Art. 6 para. 1 lit. a) GDPR.
- In case that you are a career applicant, we use your Identity Data, Contact Data and Additional Inquiry Data to consider your application for career opportunities at Cobwebs. We do so where it is necessary for our legitimate interests (recruitment of personnel and handling career applications) in which case 6 para. 1 lit. f) GDPR will be the legal basis for such processing, or where it is necessary in order to take steps prior to entering a contract with you. The legal basis is Art. 6 para. 1 lit. b) GDPR then.
- In the event of a legal dispute between you (and / or a party on your behalf) to us (and / or a party on our behalf), we may use your Identity Data, Contact Data, Usage Data and Additional Inquiry Data to the extent necessary in connection with handling such dispute. We do so where it is necessary for our legitimate interests (to defend and enforce our legal rights). Accordingly, the legal basis is Art. 6 para. 1 lit. f) GDPR.
- Where it is necessary for compliance with applicable law we are subject to. The legal basis is Art. 6 para. 1 lit. c) GDPR then.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
We may use your Identity, Contact and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
When you visit our Website, we may place cookies onto your device, or read cookies already on your device, subject to your consent where required by applicable law. For further details, please see our Cookies Policy.
This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or interacting with such content may allow your data to be shared with the relevant third-party. We do not control these third-party websites and are not responsible for their privacy statements; we therefore recommend that you read the privacy notice of every website you visit.
- legal and regulatory authorities to the extent required by applicable law;
- our professional advisors (e.g. lawyers, accountants) to the extent necessary for the provision of their services; and
- third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets, or parties whose business we wish to acquire.
We require such third parties to respect the security of your personal data and to treat it as required by applicable law and/or in accordance with binding contractual obligations of confidentiality. We permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal data from accidental or unlawful loss, use, alteration or disclosure. We also maintain reasonable technical and physical safeguards to protect your personal data. Unfortunately, we cannot guarantee against the loss or misuse of your personal data or secure data transmission over the Internet because of its nature.
We retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for accounting, legal or reporting requirements. If it is not necessary for achieving that purpose, we will delete it automatically. If personal data has been processed for several purposes and is only necessary for one of these purposes anymore, it will only be processed for such valid purpose. This can e.g. be the case with regard to our legal bookkeeping obligations.
In order to determine the appropriate retention period for personal data, we consider the following criteria: the volume, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data, the purposes for which we collect and process personal data, the timeframe during which we may require such personal data in connection with potential litigation, and applicable legal requirements.
- Request access (GDPR Article 15). This means that you may receive a copy of the personal data we hold about you.
- Request correction (GDPR Article 16). This means that you may ask us to correct or complete inaccurate or incomplete data that we hold about you.
- Request erasure (GDPR Article 17). This means that you may ask us to delete or remove personal data that we hold about you. If we are unable to comply with such request, we will notify you of the specific legal reasons for our decision.
- Object to processing (GDPR Article 18). This means that you may object to the processing of your personal data where it is used for direct marketing purposes, or where we are relying on a legitimate interest and you feel that such interest is overridden by your rights and freedoms.
- Request restriction of processing (GDPR Article 18). This means that you may ask us to suspend the processing of your personal data if you believe that such data is inaccurate, if our processing is unlawful or if we no longer need to process such data for a particular purpose, but you need us to continue to hold the data.
- Data Portability (GDPR Article 20). This means that you may request that we transfer your personal data to you or to a third party. This right applies where we have obtained and processed the data from you based on your consent or where we used the information to perform a contract with you.
- Withdraw consent at any time (GDPR Article 7). This means that you may withdraw your consent where we are processing your personal data based on your consent. Upon receipt of your withdrawal of consent, we are no longer allowed to process your personal data based on your withdrawn consent. However the lawfulness of processing in the past prior to receipt of such withdrawal remains unaffected.
If you wish to exercise any of the rights set out above, please contact us.
- Email: [email protected], Postal address: Cobwebs Technologies Ltd., 1441 Broadway, New York, NY 10018, USA
- Users in the EU may also contact our European office: Cobwebs GmbH, email: [email protected], Postal address: Leopoldstrasse 23, 80802, Munich, Germany
You have the right to make a complaint at any time to data protection authorities. We would, however, appreciate the chance to address your concerns before you approach a data protection authority, so please contact us in the first instance.
We reserve the right to change this Privacy Notice at any time. If we do so, we will post an updated version of this Privacy Notice so that our users and customers are always aware of what information we collect, use, and disclose. Your continued use of our Website and services after any change to this Privacy Notice will constitute your acceptance of such change.
This version was last updated in January 2023.