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://cobwebs.com/) (“Website”) and notify you about your privacy rights and how the law protects such rights. For the purpose of this Privacy Notice, Cobwebs is considered a controller of personal data that it collects in accordance with this Privacy Notice. Please note, that where the EU General Data Protection Regulation applies to our processing of personal data, we have included specific information on the legal basis for such processing and your rights with respect thereto.
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.
Personal data means any information about an individual from which that person can be identified.
When you use this Website, we may collect the following types of personal data on you:
- 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, when you entered the Website and how long you stayed in the Website).
- 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 or demographic data for any purpose. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature.
We use different methods to collect data from and about you including through:
- 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.
We will only use your personal data when permitted by law. We will commonly use your personal data in the following circumstances:
- 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, and which of the legal bases we rely on to do so. We have also 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 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 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.
This is how we decide which products, services and offers may be relevant for you.
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
We share personal data with third party service providers that provide us services in connection with the purposes listed above (such as sales, business management and marketing services) as sub-contractors in terms of Art. 28 GDPR.
We may also share your personal data with:
- 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 may transfer your personal data to countries outside of the European Economic Area, which do not provide the same level of data protection as the country in which you reside and are not recognized by the European Commission as providing an adequate level of data protection. We do so for the performance of a contract or implementation of pre-contractual relations with you or subject to safeguards that ensure the protection of your personal data, such as standard contractual clauses approved by the European Commission.
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.
Under certain circumstances, you have rights under applicable data protection laws in relation to your personal data, as described below:
- 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 a 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.
If you wish to exercise any of the rights set out above, please contact us.
What We May Need From You
When you approach us with a request to exercise one of your rights, we may request that you provide us with the information needed to confirm your identity as a security measure to ensure that your personal data is not disclosed to any person who has no right to receive it.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Where it takes us more than one month to respond (for example, where your request is particularly complicated or where you have made a number of requests) we will notify you and keep you updated.
If you have any questions or concerns, please contact our data protection officer at:
- 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
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.
This version was last updated in January 2023.