Effective date: December 01, 2021

Welcome to Volee, a software platform that enables users to meet with others around them to share interests and goals.

This "Privacy Policy" (hereinafter referred to as the "Policy") describes how are personal data collected and used, including data provided, data collected automatically, and data obtained from third-party sources in accordance with the provision of the “General Personal Data Protection Regulation” (GDPR) of the European Union.

We are transparent when it comes to the processing of personal data and privacy of our customers, website visitors, and every individual ("you") and would like to inform you what are your rights in relation to your personal data that we process.

We are committed to protecting the confidentiality, integrity, and availability of your personal data.

Who we are and how to contact us

The Data Controller (i.e., the person who or entity that determines the purpose and means of processing) for the personal data collected pursuant to this Privacy Policy is Volee Technologies OÜ (hereinafter referred to as “Volee”, “we”), a limited liability company, having its registered address at A.Lauteri 3, Tallinn, 10114, Estonia.

Please note that when we process personal data pursuant to a Customer Agreement, we typically act as a Data Processor on behalf of our Customer.

We are happy to support you or answer additional questions at community@volee.co

Where this Privacy Policy applies

This Policy applies to visitors of our websites (https://www.volee.io/) and users of our networking platform, including the related products, software solutions, integrated services, provided through the customer-specific online platforms (collectively, "Services").

This Policy applies to all your personal data:

● that you voluntarily provide us (for example, when contacting us, filling out the feedback form on our website, registering on our website, engaging with us);

● that is gathered automatically during your use of our websites or our Services (e.g., through cookies);

● that are legally entrusted to us for processing by tour Customer, an organization that provides you the Service, through integrated applications (bots) in messengers or social networks (e.g. Facebook, Linkedin, Instagram, Slack, Telegram).

This Policy applies to:

● all Volee’s websites, including, but not limited to https://www.volee.io;

● all Volee's Services, provided through the respective customer-specific online platforms (https://*.volee.io;).

This Policy applies to all types of data processing performed by us in an automated and mixed way, including the following actions: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

This Privacy Policy does NOT apply to other websites or services and does NOT apply to third-party websites or services.

BY USING OUR SERVICES, VISITING OUR WEBSITES, OR/AND PROVIDING US WITH YOUR PERSONAL DATA,

YOU CONFIRM THAT YOU FULLY UNDERSTAND AND AGREE WITH ALL THE CONDITIONS OF DATA PROCESSING DESCRIBED IN THIS POLICY,

AND YOU PROVIDE US WITH YOUR VOLUNTARY CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY.

IF YOU DO NOT AGREE WITH THIS POLICY OR ANY OF ITS PROVISIONS, PLEASE DO NOT USE OUR SERVICES AND DO NOT VISIT OUR WEBSITE.

Data sources

We get some of the information, including your personal data, from the sources listed below.

From publicly available sources, such as information on your company website and/or your publicly available social media profile. We are not responsible for the personal information you share or link to on social media. Social media operates independently of us, and we are not responsible for their privacy policies regarding the processing of your personal information. We encourage you to carefully review the privacy policies and settings of the social networks with which you interact.

From authentication services, when you create a profile on our website or Service using your social profile, we obtain personal information from the social profile that you choose to use for that purpose and combine it with information that is collected through our websites or Services.

Typically, user authentication is done through the social profile provided by Google or Telegram. In this way, we access and process the following personal data transmitted by these services: your username, password, company name, first name, middle name, title, email address, city, URL, and profile picture.

Any access we receive to such information from the authentication service is done in accordance with the authentication procedures defined by that service.

The terms of processing your personal information on Google (https://www.google.com/intl/en/policies/privacy/) and Telegram (https://telegram.org/privacy) are governed by the privacy policies of those services. Please review them before using their service.

What data we process

We collect and process the minimum amount of personal data necessary to achieve our processing purposes.

We do NOT process special categories of personal data (relating to race, ethnicity, political opinions, religious or philosophical beliefs, intimate life) or biometric data, and we try to avoid the processing of such data.

Our websites and our Services are not directed to or intended for use by minors. We do NOT knowingly collect personal information about children under the age of 13. If you believe that your child has provided such information, we strongly encourage you to contact us immediately. We will do our best to promptly remove such information from our records.

We process the following information of our websites visitors and users of our Services:

Purpose	Data
To create a personal profile on the website or the Service	username, password, first name, last name, company name, title, URL, profile picture, email, links to social networks and messengers, country, city of residence, answers to questions about your field of activity, professional interests, personal characteristics, information about meetings and communities
To prepare for entering into or for the execution of a contract between us	company name, title, first name, last name, contact information: address, email, telephone number
To provide the Service (contact matching)	first name, last name, email, telephone number, Telegram or Slack username, answers to questions about you, your interests, preferences (to better select the relevant contact for you, such as language, country of residence, self-description, professional interests, the purpose of participation in the community, hobbies, etc.), your comments, messages, posts, correspondence, your publicly available information (name, last name, and general information from your public profile)
To satisfy your request, to answer a question	email, the information you provide us, your request, question, comment, message, the information necessary to identify you
To analyze the use of the Services and to improve the quality of the provided Services	your preferences data for the use of the site or the Service, your profile settings, information about your device (your computer, phone, or another device that you use while using the Service), your device features data (operating system name and version, general internet connection information), location: IP address (to determine your general location at the city or country level), information about speakers, microphone, and camera, anonymized visitor data (including cookies), audit logs
For marketing purposes, to offer you Services, including personalized offers that may be useful to you based on your preferences and interests	contact information: email, first name, last name, company name, title, links to the profiles in social networks and messengers
To provide you with relevant information, notifications, or alerts concerning our Services that you use	contact information: email, first name, last name, Telegram or Slack username
To provide technical support and address errors and/or malfunctions in our Service	contact information: first name, last name, email, phone number, your appeal, message, question, error report
To process your payments	contact information: first name, last name, e-mail, address, phone number, payment details: card number, owner's name, term

Cookies and other tracking technologies

We use cookies to make our websites and Services easier to use and to tailor content to your preferences. Websites can read and place cookies, which allow them to recognize you and remember important information (such as your preferred settings).

Most browsers allow you to manage cookies yourself, to view, delete and block them. Keep in mind that blocked cookies may cause the Service to malfunction.

The cookies that we use are:

● Cookies that are strictly necessary for the operation (for example, authentication and logging into your profile) of the Service or website you have requested and cannot be disabled;

● Analytical cookies, for the ability to perform analysis of your use of the Services (e.g., click counts, visits);

● Functionality cookies, to provide additional features (such as saving your preferences, language, and other settings);

● Advertising cookies, for displaying ads based on your interests.

Your consent to the use of analytical, functional, and advertising cookies may be given or revoked in the respective cookie banner on the Service or website you are using.

For more information and to customization options of your cookies preferences, visit the website of the browser you are using from the list below:

We also use other tracking technology, such as “trust tokens”. Unlike cookies, trust tokens are designed to authenticate a user without needing to know their identity. The trust tokens are stored securely by the user's browser, and can then be redeemed in other contexts to confirm the user's authenticity. This allows the trust of a user on one website (such as a social media site or email service) to be conveyed to another website (such as a publisher or online store) without identifying the user or linking identities across sites.

Automated decision-making (profiling)

Our Service is a networking platform for making new business connections. At the heart of this Service is artificial intelligence, which uses machine learning to make automated decisions, in particular profiling.

For the Service to be able to function, we need to carry out automated decision-making (aggregation, analysis, and profiling) of your personal data, to give a preliminary assessment of your interests, your preferences, and habits, when we lack relevant information that you provided us about yourself.

To perform profiling, we use algorithms that compare information about you with other people from the same network to find similarities and points of interest between you. This automated processing of your personal data is done for the purpose of providing you with quality Service, which intends to find the most relevant business contact for you and is not intended to evaluate your personality or compare you with others. With that, the profiling that we perform shall not have any legal consequences for you.

Profiling is performed, only lawfully, with your consent, or for the performance of a contract of which you are the beneficiary.

You may object to such processing or get more detailed information on the algorithms used by sending us an email at community@volee.co

How we process data

We process personal data in a lawful, fair, and comprehensible manner.

We perform automated decision-making of your personal data in order to find the most relevant business contact for you.

We process your personal data for the purposes based on the following lawful bases:

● To exercise our rights and legitimate interests, or to achieve a public purpose, as long as your rights and freedoms are not violated in doing so, including, but not limited to:

○ to conduct our business;

○ to promote our Services;

○ to improve the Services we provide;

○ to conduct webinars and marketing events;

○ for internal administration and auditing;

● To enter into and perform a contract, which you are a party (or beneficiary);

● Your consent to do so;

● To respond to legal requests or/and fulfill our legal obligations;

You give us your consent for the processing of your personal data when:

● You submit your personal data, on the website, in the Service, in the community chat;

● You log in using social profiles or other electronic services available for authentication on our Services or websites;

● You voluntarily participate in promotions and marketing events.

You may withdraw your consent to the processing of your personal data at any time by sending an email to community@volee.co

How we share data

We entrust our business partners and service providers with your personal data in order to fulfill our processing purposes, for the need of contract execution, with your consent, or per our legitimate interests.

In such cases, we are careful to comply with the principles of personal data processing and to apply appropriate security measures.

We may share information that is anonymized, without limitation, for our business purposes, usually to analyze and improve the Services, sometimes to resolve disputes, or to troubleshoot problems.

If you are a member of a community that uses our Services, your profile will be accessed by a community administrator authorized to manage our Services in that community.

The administrator has the following rights:

● View your profile information, such as your email, username;

● View profile and community statistics including the number of apps installed, number of participants, and number of meetings;

● Grant access rights to third-party applications to interact with the community (for example, send polls, offer new services);

● Remove you from the community, for example, if you violate community rules.

Our Services and websites contain links to third-party applications and Services or our Service may be embedded in a third-party website or application (e.g., cookies, chatbots).

When you interact with them (by clicking on links or using third-party Services), your personal data will be transferred to third parties for whose actions we are not responsible.

Information that you choose to provide or that is collected by these third parties is not covered by our Policy, so you should familiarize yourself with the policies and terms of the third parties to understand how your personal data that they process will be handled.

Such services are listed below.

Calendly - a service that you can use to automatically schedule appointments with us. When you use this service, you provide your email, first name, last name, and your calendar settings. The service is provided by Calendly LLC (271 17TH St NW Ste 1000 Atlanta, GA, 30363-6201 United States) under its own privacy policy, which can be found at https://calendly.com/privacy. By using the Calendly service, you consent to the transfer of your personal data to the United States, which does not ensure an adequate level of data protection.

We entrust the processing of your personal data to third parties sub-processors, for the purposes of performing a contract with our customer and providing you with our Services, in particular, the following third-party sub-processors:

Slack is a messenger used to integrate our Service and send alerts to community members. When you use the service within Slack, the following your personal data are processed: profile data (profile name, profile picture, email, phone number, title, company), chats, comments, messages, publications, pieces of code, downloaded files (e.g. images, documents), messages and files from applications and bots, location data, cookies. The service is provided by Slack Technologies Limited (One Park Place, Upper Hatch str., Dublin 2, Ireland) under its own privacy policy https://slack.com/intl/en-au/trust/privacy/privacy-policy. Slack stores data on Amazon Web Services (AWS US), by default with servers hosted in the USA. Unfortunately, the USA does not ensure an adequate level of data protection. Therefore, standard contractual clauses are used to transfer your data to Slack to ensure that it is properly protected.
Telegram is a messenger service from Telegram Messenger LLP (71-75 Shelton Street Covent Garden, London, United Kingdom) used to send messages and notifications to community members. When you use the Service within Telegram, the following personal information is processed: profile data (profile name, profile picture, phone, groups, videos, photos, files, and links you share), email, messages, uploaded files, contacts, location data, cookies. If you signed up for Telegram from the UK or the EEA, your data is stored in data centers in the Netherlands. Read the Telegram's privacy policy at https://telegram.org/privacy/.

Services provided by Google LLC, a company organized under the laws of the State of Delaware, USA, and operating under the laws of the USA (address: Google, Google Data Protection Office, 1600 Amphitheatre Pkwy, Mountain View, California 94043, USA):

Google Ads is a contextual advertising and remarketing service. The service processes your cookies;
Google Analytics is a web analytics service. This service processes your cookies;
Google Gmail is a service that sends out newsletters. This service processes your contact information (name, email), and your messages.

Google Privacy Policy can be found at https://policies.google.com/privacy.

Google hosts data in different countries, including the United States, Taiwan https://www.google.com/about/datacenters/locations/, countries that unfortunately do not provide an adequate level of protection of your personal data. Therefore, standard contractual clauses are used to transfer your data to Google to ensure that it is properly protected.

We integrate with Google API Services, specifically Google Sign-In - a service used for authentication and authorization whenever you authorize us to use your Google account to sign in and access our Services. Your personal data received from Google API Services are your profile information (username, email, name), authentication information (access token, refresh token, client ID, and, in some cases, a client secret).

The processing of personal data received from Google API Services will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Cross-border data transfers

Volee stores and processes company data and personal data within Europe, in particular in the Data Center of Hetzner Online GmbH in Finland (Helsinki).

We have implemented measures to protect your personal data, including the Standard Contractual Clauses approved by the European Commission for transfers of personal data between our affiliates and between us and our third-party providers (see “How we share data” to review all third-parties involved) outside Europe, UK or Switzerland. These clauses require all recipients to protect their personal data and rights according to the European data protection laws and regulations.

Transfers outside EEA or Switzerland will only take place if one of the following applies:

● The transfer is consented by you;

● The transfer is necessary for the performance of a contract or to take steps requested prior to entering into that contract or the transfer is governed by approved contractual clauses;

● The country receiving the data is considered by the EU to provide an adequate level of data protection;

● The organization receiving the data is covered by an arrangement recognized by the EU as providing an adequate standard of data protection.

Data retention

We will retain your data only for as long as we need it to meet our purposes set out in this Policy, including any relating to legal, accounting, or reporting requirements.

Your personal data will be deleted or depersonalized as soon as the purpose of the processing is achieved, or if it is no longer necessary to achieve that purpose, or if you withdraw your consent to its further processing.

Upon expiration of the applicable retention period, we will securely destroy your personal information in accordance with applicable laws and regulations.

However, in some cases, we must retain your personal data for as long as required by applicable regulations and to comply with our legal and reporting obligations, resolve disputes, enforce agreements, complete any pending transactions, and detect and prevent fraud.

Data protection

When processing personal data, we take legal, organizational, and technical measures necessary and sufficient to protect data from unlawful acts, complying with the requirements of the legislation of the GDPR and our internal regulations on personal data processing.

In particular, we take the following steps to protect your data:

● We have appointed a person responsible for organizing the processing of personal data;

● We regularly assess the risks of processing personal data;

● We regularly assess the damage that may be caused to you in the event of a data breach or non-compliance with internal policies;

● We have adopted appropriate, risk-based organizational and technical measures to ensure your personal data security;

● We regularly conduct internal audits;

● We train our employees on information security and data protection regularly;

● We have designed a procedure for the execution of your requests and complaints.

Your rights

We guarantee to grant you your user rights, exclusively with regard to the personal data belonging to you.

You have the following user rights:

● The Right to Information. We inform you about the collection and use of your personal data using this Policy before we engage with such processing. Additionally, you have the right to receive information about leaks (loss, disclosure) of your personal data;

● The Right of Access. You have the right to access and receive a copy of your personal data, and other supplementary information;

● The Right to Rectification. This enables you to ask us to correct any incomplete or inaccurate data we hold about you;

● The Right to Erasure (also known as the Right to be Forgotten). This enables you to ask us to delete or remove your data in certain circumstances, for example, if you consider that there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your data where you have exercised your right to object to processing;

● The Right to Restriction of Processing. This enables you to ask us to suspend the processing of your data, for example, if you want us to establish its accuracy or the reason for processing it;

● The Right to Data Portability. You may request the personal data you have provided to us in a structured format or the transmitting of your data to other entities that you have specified;

● The Right to Object. You may object to the processing of your personal data where we are relying on our legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object to where we are processing your data for direct marketing purposes. You can unsubscribe from any emails or promotions not related to the Services provided (related to the Services emails are, for example, profile checks, purchase and billing confirmations and reminders, changes/updates of Service features, technical and security notices);

● The Right to Avoid Automated Decision-Making. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly affects you. You may withdraw the previously given consent for automated decision-making about you, including profiling.

The Right to Withdraw Consent. You have the right to withdraw previously given consent for the processing of your personal data for that specific purpose at any time;

Right to Lodge a Complaint. If you believe that your personal data have been processed unlawfully or your rights are infringed, you have the right to lodge a complaint with the appropriate data protection authority. Please see https://edpb.europa.eu/about-edpb/board/members_en

You may file a complaint or request information about your personal data processing anytime by contacting us at community@volee.co

If you believe that your rights and interests have been violated, you have the right to file a complaint with the relevant supervisory authority or court.

Changes to this Privacy Policy

This Policy is effective from 01 December 2021. We routinely evaluate the privacy processes described above and update our Privacy Policy as necessary. We encourage you to periodically review this page for the latest information about our privacy practices.

Your continued use of Volee websites or Services after any modification to this Privacy Policy will constitute your acceptance of such modification.