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PASERO on privacy

We hereby commit to defend Your Personal Data from any illegal use, data leaks, and data breaches.

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We believe that we as a provider of services need to be as open and straight forward as possible regarding our use of our Visitors' and Registered Users' Personal Data. We hereby commit to defend Your Personal Data from any illegal use, data leaks, and data breaches. We’ll do everything in our power to only forward your personal data to third parties who provide the adequate measures for safety and security that your personal data requires. Along with our Terms of Service, this policy explains how we collect and handle your Personal Data across of our website in as plain and simple manner that is possible. We can only speak for ourselves, so this policy doesn’t cover the collection or use of your information by any other service provider which we may feature on our website. That means when you go to a different service provider’s website using our website, your information will be processed by them in accordance with their own privacy policy and terms of service. If you have any form of question or suggestion, please feel free to contact us at legal@pasero.me.

About PASERO's data processing in general

  • We use your data to provision you our Services and to maintain, improve, and protect our infrastructure and services.
  • We may also use your personal data based on your consent to send you our newsletter and offers, or to track your use of the website.
  • The personal data will be either provided by you to us directly or will be sent along your Internet usage.
  • All Personal Data we have on you will be deleted or anonymized at most after 90 days of it having been collected or being relevant to your account.
  • We only use Third Parties and host data in countries which provide adequate security comparable to GDPR’s requirements.

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On purposes for using Personal Data

We use your Personal Data to provision you our Services, like authenticate you as a User, provide you bills, and to maintain and improve our infrastructure.

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We use your Personal Data:
  • to allow you to register,
  • to send you bills,
  • for sending you our newsletter or offers,
  • to enhance the quality of our service and thus elevating your user experience,
  • to protect your data and our infrastructure,
  • to communicate with you.
We use Personal Data:
  • To perform a contract to our Registered Users, including registration and billing.
  • Because it is in our legitimate interest to understand users and to improve and secure our service:
    • via creating anonymous Usage and user parameter Statistics,
    • via creating maintenance and security logs,
    • via the use of anonymous statistics.
  • Based on your consent to receive newsletters and additional offers or track website usage.
  • As a Data Processor for Content uploaded by you.
  • Out of legal obligations that require Personal Data.

On collecting Personal Data

We only collect the personal data we actually use, and no more. This happens by you directly providing us your Personal Data, us observing how you use the website, or by seeing the requests your desktop and browser send us.

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To provide the Service we need to rely on Personal Data, there is no way around it. By using our service and browsing our website, we will collect Personal Data.

We collect data:
  • you directly provide us with, like
    • your registration information,
    • your billing information,
    • any data which constitues Personal Data you upload to your profile;
  • we observe automatically during your visit and use of our website, like
    • IP address or your region,
    • informtaion about your device or browser,
    • website URL you visited us from,
    • third party sites you visit when you leave our website,
    • vendors you search for;
  • we receive from Third Parties, like
    • when you log on to our website from a social media platform,
    • when you visit our website via a promotional partner.

Our services are not intended for children under 16 years of age, and no one under the age of 16 should provide any information to, on, or via our services. We don’t knowingly collect Personal Data from children under 16 and will delete any that we learn we have collected or received that was not provided by, or with express consent on behalf of, the child’s parent or legal guardian.

On retention periods

We only keep your Personal Data as long as we absolutely need or are required to by law, that is for 90 days after collection or for 30 days after you request to have your Personal Data or account deleted. Law requirements will usually prescribe longer periods.

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The retention time depends on the purpose by which we collect and process Personal Data.

When we process data
  • to perform a contract for our Registered Users
    • to create a user profile on pasero.me and to provide our professional services, we store data till 30 days after you request your account to be deleted or when inactive for 2 years,
    • to manage billing of the Registered User’s subscription, we keep relevant Personal Data for 8 years based on requirements prescribed by invoicing regulations,
    • to secure our service via backups kept for 90 days;
  • because it is in our legitimate interest
    • for our Visitors and Registered Users alike to maintain and secure our infrastructure with logs kept for 90 days,
    • to understand users and to improve our services via analyzing Usage Statistics and user parameters that we keep after anonymizing it for extended time.

You can contact us any time about deleting your Personal Data, and if there’s no contractual or legal reason to keep your Personal Data, we comply with your request as soon as possible.

On loction of data storage

We store your personal data only where we are certain that the appropriate safety, security, and legal measures have been made. To make our lives easier and our services more affordable, we mainly use Amazon Web Services located in Ireland to host our infrastructure.

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We are using Amazon Web Services with servers in Ireland to store most of the data provided by Registered Users. These servers are provided and/or supported by our contracted third parties acting under our instructions.

We only process European users’ Personal Data outside the European Economic Area where a European Commission-approved method of validating the transfer has been put in place.

On Personal Data security

We respect your privacy and safeguarding your personal data is embedded into our culture. We use a combination of industry-standard and good practice methods to protect it. Your Personal Data is encrypted both in transit and at rest.

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Unfortunately, no website or app can guarantee complete security, but we put great effort into our application and data security, and do our best to keep your Personal Data as safe as possible. We use a range of technical, organizational, and administrative security measures and good practices proportionate to the risks of data processing. For example, the computer systems we use to store your data have access limitations and are hosted with reputable vendors. We use encryption to protect your personal data when we transfer it across the Internet and store it at our servers. We carry out security assessments and do due diligence on Third Party vendors who handle your data.

To make sure we maintain a culture of ‘Privacy by Design’, we provide thorough data protection and privacy training to all PASERO employees. We develop our services with the goal of using the minimum amount of personal data possible, including through use of data minimization techniques like anonymization and pseudonymization. Also, whenever we develop or update our services in ways that involve the collection or use of new forms of Personal Data, we conduct a balancing test to understand and reduce the likelihood of any unintended impact on you.

We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the data. The data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to PASERO, in some cases, the data may be accessible to certain types of persons in charge, involved with the operation of pasero.me (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by PASERO-MI Ltd. The updated list of these parties may be requested from PASERO at any time.

To ensure availability, we keep backups of all data within the Service and store them separately for at most 90 days. Our backups are encrypted and have additional access restrictions in place. Also our infrastructure is designed to withhold Denial of Service attacks or to mitigate its effects.

Miscellaneous information

We may use your Personal Data as part of legal obligations, legal claims, handling illegal activities, etc. If you have any question about our data processing which is not properly described in this policy, please contact us.

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Use of Personal Data for compliance with a legal obligation

Users' Personal Data may be used for legal purposes by PASERO in Court or in the stages leading to possible legal actions arising from improper use of pasero.me or other related services. User declares to be aware that PASERO may be required to reveal personal data upon request of public authorities. PASERO only provides personal data if the requesting Third Party provides the proper and exact legal basis of its request.

Use of Personal Data for our legal claims

We may disclose your information where necessary to enforce our Terms of Service or other agreements, or to a prospective or ultimate buyer if PASERO itself (or part of our business) is sold. We may also disclose your Personal Data if necessary to prevent, detect or prosecute illegal or suspected illegal activities, including fraud, or to prevent other damage or where necessary in response to legally binding requests, legal action against us, or to enforce our rights and claims.

About "Do Not Track" requests

PASERO does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to our Privacy Policy

PASERO reserves the right to make changes to our privacy policy at any time by giving notice to its Users on this page and possibly within pasero.me and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to PASERO. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

On Personal Data in Content and of Registered Users

Content is the data you upload in the course of using the Service (see definition and conditions in the Terms of Service). PASERO acts as a Data Processor for your Content and any Personal Data contained within. For other Personal Data related to Registered Users, we either use your Personal Data to provision and improve our Services to you, and to maintain, improve, and protect our infrastructure. We may also use your Personal Data based on your consent to send you our newsletter and send you offers that might interest you. We will keep your Personal Data related to your registration until you have an account with us.

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We only use Personal Data of Registered Users
  • to perform a contract to our Registered Users, including registration and billing;
  • because it is in our legitimate interest to understand Registered Users and to improve and secure our service:
    • via creating anonymous Usage and user parameter Statistics,
    • via creating maintenance and security logs,
    • via the use of anonymous statistics;
  • based on your consent to receive newsletters and additional offers or use Analytical Cookies;
  • as a Data Processor for Content uploaded by you;
  • out of legal obligations that require Personal Data.

Processing specific to Registered Users

  • To provision the Service, we will at least need your e-mail address and billing information.
  • We only share your Personal Data where we use services of Third Parties to facilitate our services and then only with Third Parties and into countries which provide adequate security comparable to GDPR’s requirements.

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During registration, we may ask you to provide us with following Personal Data:
  • first name,
  • last name,
  • email address,
  • billing information.
We use this data for general contact while you have an active account on pasero.me.
  • We send your Personal Data to our online payment service provider and our accountant.
  • We use your e-mail address to:
    • communicate with you during your active subscription,
    • send you newsletters in case you consent.

We store your Personal Data at: Amazon Web Services, ProtonMail.

Third Parties, who may receive your Personal Data: online payment&accounting service provider, accountant.

We keep your Personal Data related to your registration for the period you have an active user account on pasero.me. You can request to have your account deleted, after which we need to keep most of the Personal Data related to Registered Users for 8 years because of invoicing regulations. After that, we will anonymize all your Personal Data and only keep this anonymized data for statistical reasons.

If your account is inactive, we will consider it deleted after 2 years of inactivity. For any Personal Data not related to your registration, we will delete it latest 90 days after collection.

Your Personal Data shall be accessed only by
  • our authorized employees,
  • our payment and accounting service providers.

Processing specific to Content

  • Content is the data you upload in the course of using the Service (see definition and conditions in the Terms of Service). PASERO acts as Data Processor for any Personal Data contained within your Content.
  • We only share your Content where we use services of Third Parties to facilitate our services, and then only with Third Parties and into countries which provide adequate security comparable to GDPR’s requirements. You can find our up to date list of Subprocessors here (link)
  • We will not act upon Data Subject Requests related to your Content, but forward the requests to you the Data Controller.

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As part of using the Service you may enter following Personal Data as part of your Content:
  • first name,
  • last name,
  • email address,
  • billing information,
  • contract signatories and contacts,
  • email address of your customers,
  • free text within comments and descriptions.

We are not going to process any Personal Data other then as instructed by you based on our Data Processing Agreement. We will forward any Data Subject Requests we receive in relation to your Content to you, and only act upon your instructions.

We store your Content at Amazon Web Services in servers in Ireland.

We keep Personal Data in your Content for the period you have an active user account on pasero.me. You can request to have your account deleted, after which within 30 days we will
  • keep relevant Personal Data related to Registered Users required by invoicing regulations for 8 years,
  • remove any Personal Data contained within your Content.

If your account is inactive, we will consider it deleted it after 2 years of inactivity.

Your Content shall be accessed only by our authorized employees.

Rights and questions of Registered Users

You own your Personal Data, and we respect that by providing you all the rights as prescribed by GDPR. Contact us at legal@pasero.me with any inquiries. In case your Personal Data is part of the Content of one of our Registered Users, you need to contact them to exercise your rights.

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You may exercise certain rights regarding your data processed by PASERO. You have the right to do the following:
  • Withdraw your consent at any time: you have the right to withdraw consent where you have previously given your consent to the processing of Personal Data, like our newsletter or Analytical Cookies.
  • Object to processing of your data: you have the right to object to the processing of your Personal Data if the processing is carried out on a legal basis other than consent.
    • Where Personal Data is processed for a public interest, in the exercise of an official authority vested in PASERO or for the purposes of the legitimate interests pursued by PASERO, you may object to such processing by providing a ground related to your situation to justify the objection.
    • But: should your Personal Data be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn, whether PASERO-Mi is processing Personal Data for direct marketing purposes, you can reach out to us.
  • Access your data: you have the right to learn if data is being processed by PASERO, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.
  • Verify and seek rectification: you have the right to verify the accuracy of your data and ask for it to be updated or corrected.
  • Restrict the processing of your data: you have the right, under certain circumstances, to restrict the processing of your data. In this case, PASERO will not process your data for any purpose other than storing it.
  • Have your Personal Data deleted or otherwise removed: you have the right, under certain circumstances, to request the erasure of your Personal Data from PASERO.
  • Receive your data and have it transferred to another controller:
    • You have the right to receive your Personal Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
    • This provision is applicable provided that the Personal Data is processed by automated means and that the processing is based on your consent, on a contract which you’re part of or on pre-contractual obligations thereof.
  • Lodge a complaint: you have the right to bring a claim before your competent data protection authority.

Exercising your rights: Any requests to exercise your rights can be directed to PASERO via legal@pasero.me. These requests can be exercised free of charge and will be addressed by PASERO as early as possible and always within one month.

On Personal Data of Visitors

  • As a Visitor of our website, we will collect Personal Data on you as it is sent to us from your device or browser, or as we can observe as you browse our website.
  • Any Personal Data we have on you will be deleted latest 90 days after collection.

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We use Personal Data of Visitors out of our legitimate interest to provide quality and secure services to you. Based on your consent, we will also collect Usage Statistics from our Analytical Cookies, to understand how you use our site (see Cookies).

Our legitimate interests >>>

Pasero within its legitimate interest collects user data and Usage Statistics of our Visitors.

During your visit on our website, we collect following Personal Data:
  • IP Address and your region,
  • information about your device and browser,
  • website URL you visited us from,
  • third party sites you visit when you leave our website.

For more information about your rights as a data subject please see below.

Retention periods >>>

Any Personal Data we have on you will be deleted latest 90 days after your visit. This can be by the means of deletion, like in case of our security logs, or by anonymization, like for site statistics.

Rights and questions >>>

You may exercise certain rights regarding your data processed by PASERO. You have the right to do the following:
  • Withdraw your consent at any time: you have the right to withdraw consent where you have previously given your consent to the processing of Personal Data, like our newsletter or Analytical Cookies.
  • Object to processing of your data: you have the right to object to the processing of your Personal Data if the processing is carried out on a legal basis other than consent.
    • Where Personal Data is processed for a public interest, in the exercise of an official authority vested in PASERO or for the purposes of the legitimate interests pursued by PASERO, you may object to such processing by providing a ground related to your situation to justify the objection.
    • But: should your Personal Data be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn, whether PASERO-Mi is processing Personal Data for direct marketing purposes, you can reach out to us.
  • Access your data: you have the right to learn if data is being processed by PASERO, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.
  • Verify and seek rectification: you have the right to verify the accuracy of your data and ask for it to be updated or corrected.
  • Restrict the processing of your data: you have the right, under certain circumstances, to restrict the processing of your data. In this case, PASERO will not process your data for any purpose other than storing it.
  • Have your Personal Data deleted or otherwise removed: you have the right, under certain circumstances, to request the erasure of your Personal Data from PASERO.
  • Lodge a complaint: you have the right to bring a claim before your competent data protection authority.

Exercising your rights: Any requests to exercise your rights can be directed to PASERO via legal@pasero.me. These requests can be exercised free of charge and will be addressed by PASERO as early as possible and always within one month.

Cookie policy

PASERO uses cookies for greater user experience, to understand usage, and for statistics.

Analytical Cookie provider: Google

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Third Parties

  • We use cloud based Third Party vendors to make our Service more affordable and secure.
  • We only use Third Parties and host data in countries which provide adequate security comparable to GDPR’s requirements.
  • Find our up to date list of Third Parties here.

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We share Personal Data only if
  • you explicitly authorize us to do so,
  • it is necessary for our service, that is mostly for hosting and data storage,
  • legal reasons (claims or requests by authorities).
Your Personal Data is collected
  • by social logins if you use them,
  • by Data Processors that contribute in providing our services to you on our behalf, like online payment service providers, hosting providers, etc.

About our use of Third Party Data Processors

These Third Parties only process your Personal Data under our instructions and in compatible terms to our Data Processing Agreement(see here).

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We require all of our contracted Third Party Data Processors to:
  • process Personal Data only as instructed or as you gave them explicit consent,
  • have the necessary and obligatory security measures,
  • demonstrate compliance with the applicable data protection laws,
  • ensure authorized processes and confidentiality,
  • only engage another processor with our acknowledgement,
  • assist us in the fulfilment of the controller's obligation to respond to requests for exercising data subjects' rights.

We will put in place appropriate measures to ensure that Personal Data is adequately protected if the Third Party Data Processor is outside of the European Economic Area.

Categories of Third Party Data Processors

We use Third Parties for:
  • payment processing,
  • newsletter management
  • data aggregation and analytics
  • online cloud hosting and storage

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  • Payment processors: To securely store or handle payments information (credit or debit card details) if you provide us with your credit or debit card details we store these in a PCI-compliant data vault provided by a third party payment processor.
  • Provider of email management and distribution tools: When you sign up to receive SOMA newsletters or other marketing messages, we will manage the delivery of these to you using a third party email distribution tool.
  • Providers of data aggregation and analytics software services: These enable us to effectively monitor and optimize the delivery of our services.
  • Providers of online cloud hosting and storage services: These providers run our infrastructure and our code in scalable public cloud environments. Additionally, all our databases are hosted in public cloud environments.

The competent Supervisory Authority of PASERO

For complaints and exercising your data subject rights, please first reach out to us at legal@pasero.me. If we cannot adequately address your concern, you can contact the Hungarian National Authority for Data Protection and Freedom of Information.

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  • Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH)
  • Hungarian National Authority for Data Protection and Freedom of Information
  • Address: H-1125 Budapest, Hungary, Szilágyi Erzsébet fasor 22. c.
  • Phone nr.: +36 1 391 1400
  • Fax nr.: +36 1 391 1410
  • email: privacy@naih.hu or ugyfelszolgalat@naih.hu
  • web: https://www.naih.hu
  • coordinates:É 47°30'56''; K 18°

Terms, definitions, and their meanings for our Privacy Policy

Find here the legal and technical terms used throughout this privacy policy.

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Content

Content is the data you upload in the course of using the Service. Pasero-Mi Ltd. acsts as Data Processor in relation to your Content. Content may contain Personal Data, for which you will be considered the Data Controller, irrelevant whether you have a free or paid account.

Cookies

A cookie is a small data file that is stored on your computer or device. Cookies record things like your preferences and settings, helping to give us the information we need to provide you with the most consistent and relevant experience. Cookies consist of portions of code installed in the browser that assist Pasero in providing our service. Some services for which Cookies are installed may also require the User's consent. Where the installation of Cookies is based on consent, such consent can be freely withdrawn at any time.

Data Controller

The 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, including the security measures concerning the operation and use of www.pasero.com. The Data Controller, unless otherwise specified, is the Owner of pasero.me – Pasero-Mi Ltd.

Data Processor

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Subject

The natural person to whom the Personal Data refers.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Personal Data

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person. For example, this includes information that may of itself identify you such as your name, contact details, trek itinerary, internet protocol (“IP”) address, cookie strings or device IDs, as well as information that may not on its own identify you, but which we store alongside such identifiers, such as how you are using our services or the country you are in when you do so.

Registered User

A natural or legal person who registers on pasero.me.

Service

The free and paid vendor management related service provided after logging in at pasero.me.

Third Party

Any natural or legal person who does not have a direct connection with a legal transaction but who might be affected by it. In the case of the services of Pasero, a Third Party individual is a natural or legal person, who is not in direct connection with the legal relations between Pasero and the Data Subject.

Analytical Cookies

Analytical Cookies are snippets of code placed in the page to measure things like clicks and other interactions. We use Analytical Cookies to find out more about how you interact with our services, how you found our page and more generally, how you use us.

pasero.me

Pasero’s online webpage by which the Personal Data of the User is collected and processed.

Usage Statistics

Information collected automatically through pasero.me (or third-party services employed in pasero.me), which can include: the IP addresses or domain names of the computers utilized by the Users who use pasero.me, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Service) and the details about the path followed within the Service with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment. Usage Statistics can be anonymous, or more detailed if you consent to the use of Analytical Cookies.

User

The individual using pasero.me who, unless otherwise specified, coincides with the Data Subject – User may be a Visitor or a Registered User.

Visitor

A natural or legal person who visits pasero.me or contacts Pasero.

Web beacons and pixels

Web beacons or pixels are small, transparent image files inside a web page or email. We use them to understand how you interact with our services, or if you’ve redirected to a different website or app. We also use pixels to gather information such as whether you’ve opened an email, so that we can improve our communications to you.