Data and Privacy Policy

Introduction
1. We are committed to safeguarding the privacy of our website visitors and users of our products and services.
2. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and users of our products and services; in other words, where we determine the purposes and means of the processing of that personal data.
3. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
4. You have the option of subscribing to our newsletter, in which case we will prompt you for your consent to use the data you provide in order to send you news and marketing communication. You can withdraw your consent at any time. You can also access, rectify or erase this data at any time.
5. In this policy, "we", "us" and "our" refer to Hindenburg Systems Aps. For more information about us, see Section 13.
Credit
1. This document was created using a template from SEQ Legal (https://seqlegal.com).
How we use your personal data
1. In this Section 3 we have set out:
  1. the general categories of personal data that we may process;
  2. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
  3. the purposes for which we may process personal data; and
  4. the legal bases of the processing.
2. We may process data about your use of our website and services ("website usage data"). The website usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent.
3. We may process information relating to software licence agreements you have entered into ("licence data"). This data includes your name, email address, address, country, IP address, product licensed, licence period, licence terms and conditions, your registration email address, your licence key (registration key), the name of your organisation, and the status of your licence. The source of this data is data you provided when entering into the agreement by submitting a form on our website or data provided by you and our payment handling partner when you bought the product. Details of the licence data may be processed, updated and changed over time to reflect the current situation and status of the licence. This data may be processed for the purpose of allowing you to use our product and for keeping records of our licence agreements. The legal basis for this processing is (1) our legitimate interests, namely managing our licence agreements and (2) the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
4. We may process information relating to your use of any licence agreement(s) that you have entered into ("licence usage data"). This data includes some of the data points mentioned in 3.3 (licence data). This data may also include information on your downloads of assets, including software packages, from our servers, including times of download, IP addresses, browser and OS information, your computer name and your computer user name related to those downloads. Furthermore, this data may include information on activations and/or failures of activation of your products, including time of activation, your registration email, your licence key (registration key), your IP address, your computer name, your computer user name, your operating system, and version of the software being updated. Furthermore, this data may include information on instances of your software checking for software updates, including times of update check, registration email address, your licence key (registration key), IP addresses, your OS information, your computer name and your computer user name, your software version, and the result of the update check, related to those update checks. The source of this licence usage data is data automatically collected by us when you or the software performs one of the operations mentioned above (namely downloads, activations and update checks). This licence usage data may be processed for the purpose of monitoring how our software is being used, collecting statistics about the use of our software, and to monitor if the use of our software violates any licence agreement(s), and deliver support and services to our customers based on the specific use of our software. The legal basis for this processing is (1) the performance of a contract between you and us, and (2) our legitimate interests, namely the ability to provide relevant support for our customers and the assertion that our licence agreement(s) are not being violated.
5. We may process your data relating to sending you news and marketing communication ("mailing list data"), but only if you sign up for our newsletter. In some cases, this sign-up is a separate operation and in other cases it is done at the same time as requesting a trial licence. In any case, during the sign-up process, we will ask you for the necessary consent. The mailing list data includes your name and email address and may additionally contain other supplemental data such as data about your purchased products, product interests, preferences, and the name of the organisation that you represent. Furthermore, the data may include your IP address, geographical location, browser type and version, operating system, referral source, page views and website navigation paths. The source of this account data is data you provided, and data collected by automatic means, when signing up for our newsletter. This mailing list data may be processed for the purposes of sending you relevant information, including marketing communication. The legal basis for this processing is consent.
6. If you have been offered special discounts or other offers, we may process data relating to your current or previous offer(s) that you are entitled to ("offers data"), including details of the offer(s), your personal promo code(s) and promo code expiry date(s). The source of this offers data is data created by us regarding offers that we have entitled you to. This offers data may be processed for the purpose of sending you relevant information, including marketing communication. However, we will not send you marketing communication unless you have signed up for our newsletter and given us consent to receive such communication. The legal basis for this processing is either (1) consent and/or (2) the performance of a contract between you and us and/or taking steps, at your request, to enter into a such a contract.
7. In case you have signed up for our newsletter as described in 3.5 (mailing list data), and you have entered into any licence agreement(s) with us, including requesting a trial licence, we may link your personal mailing list data with your licence data (described in 3.3). If you withdraw consent to processing of your mailing list data, your mailing list data and the linked licence data will be deleted to the extent that it does not impinge on our ability to provide you access to the licences you have acquired, but your original licence data will be retained in its original form.
8. In case you have signed up for our newsletter as described in 3.5 (mailing list data), and you have been offered special discounts or other offers, we may link your personal mailing list data with your offers data (described in 3.6). If you withdraw consent to the processing of your mailing list data, your mailing list data and the linked offers data will be deleted, but your original offers data will be retained in its original form.
9. We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is either (1) consent and/or (2) the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
10. We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your organisation, your job title or role, your contact details, and information contained in communications between us and you or your organisation. The source of the customer relationship data is you or your organisation. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is either (1) consent or (2) our legitimate interests, namely the proper management of our customer relationships.
11. We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your payment method and the transaction details. The transaction data will not include your payment card information because the payment is not handled by us but by our payment-handling partner. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
12. We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our business and communications with users.
13. Related to the correspondence data described in 3.12, we may process data relating to your receiving and opening our emails. This may be done by inserting a tracking image in our emails, which your email client or email system might request from our servers in which case we will register the email as having been "opened". The resulting data ("email tracking data") will be used to confirm or disconfirm, to a certain degree of certainty, that you have received and opened our email. The email tracking data is processed for the purpose of ensuring that you receive critical information from us regarding your purchases, licence agreements and other important information. The legal basis for this processing is (1) our legitimate interests, namely ensuring that critical information is received by our customers and (2) the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and (3) to protect the vital interests of you, as our customer and/or partner.
14. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
15. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
16. In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
17. Please do not supply any other person's personal data to us, unless we prompt you to do so.
Providing your personal data to others
1. We may disclose your personal data to any member of our group of companies this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3. We may disclose personal data to our suppliers or subcontractors insofar as reasonably necessary for providing our services according to our contracts.
4. Financial transactions relating to our website and services are OR may be handled by our payment services providers, Fastspring, Paddle, PayPal, Wise, Banks, etc. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at Fastspring, Paddle, PayPal, Wise, etc.
5. In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
International transfers of your personal data
1. In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
2. The hosting facilities for our website are situated in Germany, Denmark and Sweden. As all are members of the EU, data protection is regulated by The General Data Protection Regulation (GDPR) of The European Union. For information: https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en
3. The following suppliers and subcontractors are situated outside The European Union. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en:
  1. Google Analytics (USA)
    
    Google Analytics is a web analytics service. You can visit their Privacy Policy page here: https://policies.google.com/privacy.
  2. Google Adwords (USA)
    
    Google Adwords is Google's advertising system in which advertisers bid on certain keywords in order for their clickable ads to appear in Google's search results. Read Google’s Policy page here: https://policies.google.com/privacy.
  3. Facebook Ads (USA)
    
    Facebook Ads is Facebook’s advertising system in which advertisers pay to have certain advertisements appear in Facebook’s News Feed on desktop, News Feed on mobile, and in the right column of Facebook on desktop. Read Facebook’s Privacy here: https://www.facebook.com/policies/ads.
  4. Active Campaign (USA)
    
    Active Campaign is an email marketing, marketing, automation, and small business CRM. Read Active Campaign’s privacy policy here: https://www.activecampaign.com/privacy-policy/.
  5. UserVoice (USA)
    
    Hindenburg uses UserVoice as support and product feedback management software. We do not transfer any personal data to UserVoice on your behalf. UserVoice is accessed through hindenburg.com/support using a widget hosted on our page. UserVoice will require that you enter personal data in order to use our support system. This data is provided directly by the user to UserVoice and thus your data is handled according to UserVoice’s Privacy Policy, as described here: https://www.uservoice.com/privacy/.
4. You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
Retaining and deleting personal data
1. This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
3. We will retain your personal data as follows:
  1. Personal data related to marketing and newsletters will be retained for a maximum period of 2 months after you cancel your newsletter subscription or contact us with a request to be removed from the newsletter and marketing database.
4. In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
  1. The period of retention of some licensing and contract-related data will be 12 months after you specifically contact us to terminate our licensing agreement. Records of such licensing agreements will be retained in perpetuity.
5. Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Amendments
1. We may update this policy from time to time by publishing a new version on our website.
2. You should check this page occasionally to ensure you are happy with any changes to this policy.
3. We may notify you of changes to this policy by email or our website.
Your rights
1. In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
2. Your principal rights under data protection law are:
  1. the right to access;
  2. the right to rectification;
  3. the right to erasure;
  4. the right to restrict processing;
  5. the right to object to processing;
  6. the right to data portability;
  7. the right to complain to a supervisory authority; and
  8. the right to withdraw consent.
3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.
4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
9. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
10. To the extent that the legal basis for our processing of your personal data is:
  1. consent; or
  2. that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
  and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
11. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
13. You may exercise any of your rights in relation to your personal data by written notice to us OR by email to sales@hindenburg.com.

Cookies

About cookies
1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
1. Hindenburg.com uses cookies for several purposes.
  
  In this section 10, we will describe the categories of cookies used and the purpose of each category. You can choose to accept or reject most of the categories of cookie, and you can change your consent at any time by going to https://hindenburg.com/cookies.
2. We use cookies for the following purposes:
  1. Strictly necessary cookies - These are required for the website to function, and cannot be switched off in our system. You can set your browser to block these cookies, but some parts of the site may not work then. These cookies do not contain personal information. (For a list of cookies used for this purpose, please see https://hindenburg.com/cookies#necessary);
  2. Preferences cookies - These cookies store information about your settings and choices on the site. These cookies can be disabled. If you disable this, you might lose some settings on the site, for example your choice of language or currency. These cookies do not contain personally identifiable information. (For a list of cookies used for this purpose, please see https://hindenburg.com/cookies#preferences);
  3. Statistics cookies - These cookies help us analyze how our site is being used. (For a list of cookies used for this purpose, please see https://hindenburg.com/cookies#statistics);
  4. Targeting cookies - These cookies are used for personalizing our website by showing you the most relevant content. We will also use this data for the purpose of measuring the performance of marketing activities such as email campaigns. This data will not be transferred to any 3rd party except our designated Data Processor who will only process the data according to our instructions in accordance with our Data Processing Agreement with them. This data contains some personal information such as your IP address, and if you have signed up for our newsletter, it can be used to associate your page visits with our contact records containing your name, email address and other personal data. You can view, correct or delete this data at any time by going to my mailing list preferences. (For a list of cookies used for this purpose, please see https://hindenburg.com/cookies#targeting);
  5. Advertising and tracking cookies These cookies are used for the purpose of measuring our advertising and marketing results, personalising content and tracking user navigation. We will also use this data for the purpose of measuring the performance of ads we run on other sites. Furthermore, this information is shared with 3rd parties such as social media, advertising and analytics partners, and it may be combined with other data that you have provided to them or that they have collected from your use of their services, and as such it can be used in order to show you relevant advertising content on other web sites, or for other purposes. (For a list of cookies used for this purpose, please see https://hindenburg.com/cookies#tracking);
  6. Cookie consent cookies - These cookies are used to store your preferences in relation to the use of cookies more generally. (For a list of cookies used for this purpose, please see https://hindenburg.com/cookies#consent);
Cookies used by third-party content embedded in our pages.
1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
2. When visiting hindenburg.com, you may encounter some cookies that are not described in the list of cookies and that are not directly related to Hindenburg. To support our content, we sometimes embed content from social media and other third-party websites. These include YouTube, UserVoice, Twitter and Facebook as well as our merchandise partner Spreadshirt. As a result, when you visit a page containing such content, you may be presented with cookies from these websites and these third-party cookies may track your use of the our website. Since the content is not authored by us nor served from our web server, but simply embedded in the form of iframes, which are in effect completely separate self-contained web pages served by our partners from our partners' web servers, we cannot control their use of cookies. This means that you cannot use our cookie settings to extend or withdraw consent to the use of those cookies, and the cookie settings on hindenburg.com will not affect the way in which, or the extent to which those cookies are being used. If you do not want to have those third-party cookies set, you have the following options:
  1. You can review the cookie policies of those partners and if possible opt out of their use of cookies, or
  2. You can choose not to visit specific pages on our website, namely https://hindenburg.com/news (Facebook, Twitter), https://hindenburg.com/shop/merchandise-shops/ (Spreadshirt), https://hindenburg.com/support/ (UserVoice widget) and any page with embedded YouTube videos (especially pages under https://hindenburg.com/support/tutorials) (YouTube), or
  3. You can set up your browser to not accept cookies from the domains of our partners (see section 12).
Managing cookies
1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
  1. https://support.google.com/chrome/answer/95647?hl=en (Chrome);
  2. https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
  3. http://www.opera.com/help/tutorials/security/cookies/ (Opera);
  4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
  5. https://support.apple.com/kb/PH21411 (Safari); and
  6. https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
2. Blocking all cookies will have a negative impact upon the usability of many websites.
3. If you block cookies, you will not be able to use all the features on our website.
Our details
1. This website is owned and operated by Hindenburg Systems Aps.
2. We are registered in Denmark under registration number DK-32359337, and our registered office is at:
  
  Knabrostræde 20, 1st floor
  DK-1210 Copenhagen K
  Denmark
3. Our principal place of business is at:
  
  Knabrostræde 20, 1st floor
  DK-1210 Copenhagen K
  Denmark
4. You can contact us:
  1. by post, to the postal address given above;
  2. using our website contact form;
  3. by telephone, on the contact number published on our website from time to time; or
  4. by email, using sales@hindenburg.com.
Data protection officer
1. Our data protection officer's contact details are: sales@hindenburg.com.

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