Privacy policy

Updated 10/10/2019


  1. INTRODUCTION
    1. Cuttles respects the protection of privacy. Therefore Cuttles has made this policy about processing of personal data ("Privacy Policy").

    2. The policy describes how Cuttles collects and processes data about you when you use Cuttles’ Platform. Cuttles is data controller of your personal data. All enquiries must be made via the contact information stated under section 11.

    3. Please read this Privacy Policy carefully together with Cuttles’ Cookie Policy and Terms of Service.

  2. CONSENT
    1. By accepting this Privacy Policy, you consent to Cuttles' collection and processing of your personal data as described in this Privacy Policy.

    2. You are entitled to at any time to withdraw your consent by contacting Cuttles via the contact information stated under section 11. For further information about withdrawal, please see subsection 10.7. 

  3. PERSONAL DATA
    1. When you register to become a User to use the Service and publish Content, Cuttles will process your personal data, such as name, date of birth, sex, title, company name, job function, e-mail address and geographical placement (see subsection 3.1.2).‍

      1. E-mail addresses are used only to deliver requested information.‍

    2. The collection of personal data is necessary in order to fulfil the Terms of Service, providing you with the Service and to comply with obligations imposed on Cuttles by applicable law.‍

    3. The collection of your date of birth, sex, title and job function is necessary for the purpose of pursuing Cuttles’ interest in providing you the best Service. Cuttles uses the data for analytical purposes to continuously improve and optimize the Service to your needs.‍

    4. Cuttles urges you not to include any sensitive personal data in your use of the Service. Sensitive personal data includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or data concerning health or sex life. 

  4. PAYMENT INFORMATION
    1. When you buy a subscription to Cuttles’ Platform and Service Cuttles collects information about the transaction. This includes for instance your payment information, such as your credit card or other card information, account and verification information as well as billing information and contact details ("Payment Information").‍

    2. The collection of Payment Information is necessary in order to fulfill the Terms of Service providing you with the Service.‍

      1. When you subscribe to the Platform and Service you accept that Cuttles may disclose Payment information to Stripe Inc, 3180 18th Street, San Francisco, CA 94110, United States or Stripe Payments Europe Ldt., C/O A&L Goodbody Ifsc, North Wall Quay, Dublin(collectively referred to as "Stripe") , depending on the location of the transaction.‍

      2. If your transaction is made within Europe, Stripe Payments Europe Ldt., C/O A&L Goodbody Ifsc, North Wall Quay, Dublin, will receive the personal data for the purpose of being able to facilitate purchases and sales of licences. If your transaction is outside Europe, either fully or partly, the personal data is disclosed to Stripe Inc, 3180 18th Street, San Francisco, CA 94110, United States, for the purpose of being able to facilitate purchases and sales of licences.‍

    3. Cuttles is not responsible for Stripe's processing of your personal data.‍

    4. In order to have your payment processed, you need to read and accept Stripe's terms and conditions. By agreeing to these terms and conditions, you accept to be bound by the Stripe terms and conditions, as the same may be modified by Stripe from time to time.

  5. OTHER INFORMATION CUTTLES COLLECTS
    1. When you access the Platform, Cuttles may automatically (i.e. not by registration) collect personal data, e.g. IP address, type of Internet browser and operating system used, domain name of the website from which you came, number of visits, average time spent on the Platform, electronic address (e.g. IP- and MAC-address), terminal equipment and connection information, referral URLS, preferences, information about your use of the Service.
    2. The Service automatically tracks how the Content provided is used. This tracking allows Cuttles to pursue our interests in gaining a better understanding of potential areas for improvement and to continually improve the relevance of and accessibility of the Service.‍

    3. This usage information will only be used within Cuttles and Cuttles' relevant partners (suppliers of technical support and operation of the Service and financial institutions in regards to subscription purchase), to increase the quality of Content, Service and support to Cuttles' Users. Some of this information may be made public from time to time; however, it will only be in an aggregate, non-personally identifiable form.

    4. The Service uses cookies to collect information. You can find further information about Cuttles' use of cookies in Cuttles's Cookie Policy.

  6. COLLECTING AND PROCESSING PURPOSES
    1. Personal data is collected and processed for the purpose of being able to administrate your User account and provide the Service and facilitate purchases and sales. The data may also be used to improve Cuttles' knowledge about Cuttles' Users, to monitor and improve the attractiveness of the Service, to send you relevant marketing material and targeted marketing material. The data may also be collected and processed to provide questionnaires as well as for competitions.
  7. DISCLOSURE OF PERSONAL DATA
    1. Cuttles only discloses your personal data to the extent described in this Privacy Policy.‍

    2. When you sign up to create a User Account you accept that Cuttles have acces to all Content, including personal data you upload. The Content and personal data is used by Cuttles for the purpose of running the Platform and Service.‍

    3. Cuttles reserve the right to disclose your personal data based on a request from public authorities, including local tax authorities, police and courts and in cases where Cuttles under current legislation is obliged to do so. 

  8. USE OF DATA PROCESSORS
    1. Cuttles use external companies located both within the European Economic area and in the United States of America to provide software in order to enable the Service and to undertake the technical operation of the Platform and Service and other assistance related hereto. For instance, Cuttles’ suppliers assist Cuttles in connection with carrying out statistical, marketing related or operational tasks, including with the purpose of collecting and analysing information about Cuttles' Users' demographic composition, interests, consumption patterns and other matters. These companies are data processors under Cuttles' instruction and only process data for which Cuttles are data controller. The data processors must not use the data for another purpose than instructed by Cuttles. Cuttles' transfer of data to data processors located in the United States of America is based on the E.U-U.S. Privacy Shield.
  9. LINKS TO OTHER WEBSITES
    1. The Platform contains links to other sites. Cuttles is not responsible for the privacy practices or the contents of such other sites and Cuttles therefore recommend you to become acquainted with such third party policies.
  10. SECURITY
    1. Cuttles is using technical and organizational measures to ensure appropriate protection of personal data and to avoid loss of data or likewise. Cuttles' technical and organizational measures will be revised and updated regularly to ensure safety. 
  11. YOUR RIGHTS
    1. The right of access‍
      1. about Cuttles' processing of your personal data, e.g. which information Cuttles have registered about you, the processing purpose, the categories of personal data concerned and the recipients to whom the information have been or will be disclosed.‍

      2. You are entitled to receive a copy of the personal data Cuttles process about you. For delivery of more copies, Cuttles is entitled to charge a reasonable fee based on the administrative costs. Request to exercise this right must be sent in writing to hello@cuttles.io together with documentation that you are the relevant person.‍

    2. The right to rectification‍
      1. The right of rectification. You have the right to have incorrect personal data about you rectified by Cuttles without undue delay. If you become aware that there are errors in the information Cuttles have registered about you, Cuttles urges you to contact Cuttles in writing in order for Cuttles to rectify the information. See contact details under section 12.‍
    3. The right to deletion‍‍
      1. You have a right to have your personal data deleted by Cuttles without undue delay if, for instance, Cuttles no longer have a valid processing purpose or you withdraw your consent or Cuttles has no other legal basis for processing your personal data etc. If Cuttles can prove demonstrate compelling, legitimate reasons for continued processing which precede your interests, rights and freedoms or the processing is necessary for a legal claim to be established, exercised or defended, Cuttles is not obliged to delete your personal data. Such legitimate reasons can for example be backup of Content. Backup is done for several purposes, among others to enable Users who have legitimately bought a license or another right to your Content to access said Content in accordance with the agreed terms. Other purposes for backup include storing Cuttles Users' conversations, but only in order to establish, exercise or defend a legal claim – otherwise these conversations will be effectively anonymized or deleted when no legitimate processing purpose exists.
    4. The right to restrict processing‍‍
      1. You have a right to restrict Cuttles’ processing of your personal data, e.g. if you contest the accuracy of your personal data.‍
    5. The right to data portability‍‍
      1. You have a right to receive the personal data provided to us in a structured, commonly used and machine readable format and to transfer these data to another data controller if Cuttles' processing of the data, for instance, is based on your consent and the processing is carried out by automated means.‍
    6. The right to object‍
      1. You are at any time for reasons concerning your particular situation entitled to object to Cuttles' processing of your personal data if the processing, for example, is based on legitimate interests or profiling.‍

      2. If you object to the processing, Cuttles will no longer process your personal data unless Cuttles can demonstrate compelling, legitimate reasons for continued processing which precede your interests, rights and freedoms or the processing is necessary to establish, exercise or defend a legal claim.‍

      3. You also have a right not to be the subject of a decision based exclusively on automated processing, including profiling, which has legal effect on you or similarly affects you significantly.‍

    7. The right to withdraw consent‍
      1. You are at any time entitled to withdraw your consent to Cuttles' processing of your personal data. If you withdraw your consent, you must be aware that Cuttles under certain circumstances is entitled to continue processing your data, for example where Cuttles have another legal basis for processing your data. Cuttles will inform you in such cases. Furthermore, Cuttles refer to your other rights describe above.‍

      2. If you wish to withdraw your consent, please send an e-mail to hello@cuttles.io

    8. The right to complain
      1. You are at any time entitled to file a complaint to a supervisory authority about Cuttles's processing of your personal data. The Danish supervisory authority is the Data Protection Agency (in Danish "Datatilsynet"), Carl Jacobsens Vej 35, 2500 Valby.
    9. Deletion of personal data‍
      1. Cuttles will delete your data when the collection of data is no longer necessary to fulfil this Agreement and provide you the Service. 
  12. CONTACT INFORMATION
    1. If you have any questions about this Privacy Policy, the practices of this website, or your dealings with this Service, please contact: Cuttles ApS Grønnegade 29, 1107 København K, Denmark.‍‍ hello@cuttles.io +45 53 55 50 03 Business registration number: 39 86 88 65.
  13. CHANGES TO THE PRIVACY POLICY
    1. Cuttles is at any time entitled to amend this Privacy Policy. If Cuttles makes amendments to the Privacy Policy, Cuttles will inform you about this through digital correspondance.‍

    2. If you cannot accept the amended policy, you must refrain from using the Service.

  14. VERSIONS
    1. This is Cuttles's Privacy Policy of the 1st of October 2019.

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