May 25, 2018
At Gartle LLC, we care about the privacy of your data and are committed to protecting it.
When we write "Gartle LLC", "Gartle", "we", or "us" we are referring to Gartle LLC, incorporated in the Russian Federation.
Table of contents
- Information collection and use
- Information access and disclosure
- Data storage, transfer, retention, and deletion
- For European Union users
- Contact us
Information collection and use
What Information does Gartle collect about me?
When you interact with our websites, software, and/or services, we collect information that alone or in combination with other data, could be used to identify you ("Personal Data").
Some of the information we collect is stored in a manner that cannot be linked back to you ("Non-Personal Data").
The information that we collect depends on your operations. There are operation categories:
- Website visit
- Product download
- Product installation/uninstallation
- Product activation online
- Product activation by email
- News subscription
- Reading subscription emails
- Support request
Information about website visitors
We use the following technologies on our websites: web server logging, Google Analytics, tracking pixel.
Web servers log files contain the following data: date and time, IP-address, request method, request URL, referrer, browser.
Google Analytics collects a lot of information. We get aggregate reports only.
The tracking pixel logs the following data: date and time, IP-address, Google Analytics cookie, request URL, referrer.
Information about product downloads
We collect the following data about downloads: date and time, IP-address, Google Analytics cookie, request URL (file), referrer (page).
Information about product installation/uninstallation
Product setup wizards open special web pages after installation and uninstallation.
Such pages contain useful actual information for users.
Opened URLs contain UTM labels that allow us to understand products, versions, and operations.
The opened URLs can contain registration codes that allow link such operations with the information obtained during the product activation.
Information collected during online product activation
Starting May 24, 2018, all active products include a new product registration wizard.
When you activate any product online, we collect the following data:
date and time, IP-address, company (optional), country (optional), product, product version, registration code, input language.
If you use the product registration wizard of the previous version, we collect the additional information that you give us: first name, last name, email, job role.
We recommend you updating installed products to the latest versions.
The registration code does not contain any personal data. However, it is unique for the pair of the product code and user's computer.
The registration codes allow us to control the number of activated licenses vs. purchased ones.
So, we can link the product activation data with the data about purchases.
Information collected during product activation by email
When you activate any product by email, we collect the following data:
date and time, sender email, company (optional), country (optional), product, product version, registration code, input language.
See notes about the registration codes above.
If you use the product registration wizard of any version released before May 24, 2018, we collect the additional information that you give us: first name, last name, job role.
We recommend you updating installed products to the latest versions.
Information about paying customers
We sell our products via 2Checkout.com, Inc. To be precise, 2Checkout.com sells our products.
So, you create a buyer account and make purchases at 2Checkout.com.
We have a copy of all transaction documents sent to a customer including orders, product/subscription information, and invoices.
These documents contain customer's first and last name, company, email, phone, fax, country, address, IP-address, language, time zone, payment method, product codes.
Also, we receive these data in an electronic form suitable to import in our systems.
We do not have access to your credit card information.
Information about news subscribers
We suggest to our actual and potential users useful materials via email subscriptions including welcome educational series, tips & tricks, release news, and special offers.
You can subscribe and unsubscribe at any time.
We run our email campaigns with email marketing providers, MailChimp (USA) and Elastic Email (Canada).
Both companies are industry leaders and are complied with the European Union's GDPR.
We collect the following data about subscribers: email, first name, last name, subscribe IP-address, subscribe date, unsubscribe date.
Information about news subscribers on reading emails
The open rate is an important metric in Email marketing that allows understanding user satisfaction.
So, we get the information about opening every email by every subscriber to calculate it.
Information collected during support requests
We have all the information that you give us in your email.
At least, we have a sender email. In most cases, we have a first name, last name, company, and a position.
How does Gartle use my information?
We use, process, and store your information as necessary to perform our contract with you and for our legitimate business interests, including:
- to help us administer our websites, software, and/or services, authenticate users for security purposes, provide personalized user features and access, process transactions, conduct research, develop new features, and improve the features, algorithms, and usability of our websites, software, and/or services;
- to communicate with you about your use of our websites, software, and/or services, product announcements, and software updates, as well as respond to your requests for assistance;
- to send you direct marketing emails and special offers, from which you can unsubscribe at any time;
- to calculate business metrics including sales funnel metrics based on visits, downloads, installations, activations, and purchases;
- to detect and prevent fraud and misuse.
Information access and disclosure
Does Gartle share my Information?
We only disclose Personal Data to third parties when:
- We use service providers for sales, email communication, customer relation management, hosting, and analytics. These service providers may only access, process, or store Personal Data under our instructions and to perform their duties to us.
- We have your explicit consent to share your Personal Data.
- We believe it is necessary to investigate potential violations of the Terms of Service. Or we believe it is necessary to investigate, prevent, or act regarding illegal activities, suspected fraud, or potential threats against persons, property, or the systems on which we operate our websites, software, and/or services.
- We determine that the access, preservation, or disclosure of your Personal Data is required by law to protect the rights, property, or personal safety of Gartle and users of our websites, software, and/or services, or to respond to lawful requests by public authorities, including national security or law enforcement requests.
We may disclose Non-Personal Data publicly and to third parties, for example, in public reports or to partners under an agreement with us.
Using cookies, we help deliver advertisements for relevant products and services to you.
Gartle does not share your Personal Data with third parties to enabling them to deliver their advertisements to you.
Does Gartle sell or rent my Personal Data?
No, Gartle does not sell or rent your Personal Data.
Cookies are small text files stored on your device and used by web browsers to deliver personalized content and remember logins and account settings.
Our products currently do not respond to Do Not Track requests.
How do third-party apps and plugins work?
Some third-party applications and services that work with us can ask for permission to access your information. Those applications will provide you with notice and request your consent to obtain such access or information. Please consider your selection of such applications and services, and your permissions, carefully.
Some third parties embedded content or plugins on our websites and/or software, such as Facebook "Like" buttons, may allow their operators to learn that you have visited the websites, and they may combine this knowledge with other data they have collected about your visits to other websites or online services that can identify you.
Data collected by third parties through these apps and plugins are subject to each party's policies.
We encourage you to read those policies and understand how other companies use your data.
Will Gartle send me emails?
From time to time, we may want to contact you with information about product announcements, software updates, and special offers. We also may want to contact you with information about products and services from our business partners.
You can opt-out of such communications at any time by clicking the "unsubscribe" link found within emails and changing your contact preferences. You will continue to receive transactional messages related to our products and services, even if you unsubscribe from promotional emails.
We only send marketing communications with your prior consent.
We got and may get your consent with the product registration wizard released before May 24, 2018.
Starting May 24, 2018, we removed this feature, and you can subscribe explicitly only using the subscribe pages (see also the link in the finish wizard step).
Does Gartle collect information from children?
Gartle does not knowingly collect personal information from children under the age of 13. If we determine we have collected personal information from a child younger than 13 years of age, we will take reasonable measures to remove that information from our systems. If you are under the age of 13, please do not submit any personal information through the websites, software, and/or services. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the websites, software, and/or services without their permission.
Data storage, transfer, retention, and deletion
Where is my information stored?
Any information submitted to Gartle can be transferred to, processed, and stored in the Russian Federation where Gartle LLC incorporated and located.
Information about paying customers is transferred to, processed and stored in the European Union (2Checkout.com, former Avangate) and the Russian Federation.
Information about subscribers is transferred to, processed and stored in the United States (MailChimp), Canada (Elastic Email), and in the Russian Federation.
Information about website visitors is transferred to, processed and stored in the United States (Dreamhost) and the Russian Federation.
Information about the key and potential customers can be transferred to, processed, and stored in the United States (Zoho CRM).
All our partners, except the web hosting provider, Dreamhost, announced their compliance with European Union's GDPR.
How secure is my Information?
Gartle is committed to protecting the security of your Information and takes reasonable precautions to protect it. However, Internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100% secure, and as a result, we cannot ensure the security of Information you transmit to us, including Personal Data. Accordingly, you acknowledge that you do so at your own risk.
We use industry-standard encryption, TLS and SSL, to protect your data in transit.
Once we receive your data, we protect it on our servers using a combination of technical, physical, and logical security safeguards.
We anonymize and eliminate the personal data where it is possible.
If Gartle learns of a security system breach, we may attempt to notify you and provide information on protective steps, if available, through the email address that you have provided to us or by posting a notice on the websites. Depending on where you live, you may have a legal right to receive such notices in writing.
How can I delete my Personal Data from Gartle?
We will ask for your confirmation sending an email to your sender address.
After receiving the confirmation, we will remove, if possible, or completely anonymize related records.
If you purchased our products, you might want to delete your personal data at 2Checkout.com (former Avangate).
How long is Personal Data retained?
You can remove your Personal Data from Gartle at any time as described above.
However, we may keep some of your Personal Data for as long as reasonably necessary for our legitimate business interests, including fraud detection and prevention and to comply with our legal obligations including tax, legal reporting, and auditing obligations.
For European Union users
Gartle uses, processes, and stores Personal Data, including those listed in the "What Information does Gartle collect about me?" section, as necessary to perform our contract with you, and based on our legitimate interests.
We rely on your consent to process Personal Data to send promotional emails and to place cookies on your devices. In some cases, Gartle may process Personal Data under a legal obligation or to protect your vital interests or those of another person.
What rights do I have, and how can I exercise them?
Individuals located in the European Union have certain rights in respect to their personal information, including the right to access, correct, or delete Personal Data we process through your use of the websites, software, and/or services. If you are a user based in the European Union, you can:
- Request a Personal Data report.
To request the report, submit your request at . This report will include the Personal Data we have about you, provided to you in a structured, commonly used, and portable format. We will use your sender address to identify you, so the address must be personal. Please note that we may request additional information from you to verify your identity before we disclose any information.
- Have your Personal Data corrected or deleted.
To correct or remove your Personal Data from Gartle, submit a request at .
Also, some Personal Data can be updated by you: you can update your name and email address in your subscriber account at MailChimp using the "update your preferences" link in an email.
- Object to us processing your Personal Data.
You can ask us to stop using your Personal Data, including when we use your Personal Data to send you marketing emails. We only send marketing communications to users located in the European Union with your prior consent, and you may withdraw your consent at any time by clicking the "unsubscribe" link found within emails and changing your contact preferences. Please note you will continue to receive transactional messages related to our software and services, even if you unsubscribe from marketing emails.
- Complain to a regulator.
If you are based in the European Union and think that we haven't complied with data protection laws, you have the right to file a complaint with your local supervisory authority.
Who is our European Union Representative?
We do not fall under Article 27 of the General Data Protection Regulation of the European Union.
As Gartle evolves, we may need to update this Policy to keep pace with changes in our websites, software, and services, our business, and laws applicable to us and you.
We will, however, always maintain our commitment to respect your privacy.
We will notify you of any material changes that impact your rights under this Policy by email (to your most recently provided email address) or post any other revisions to this Policy, along with their effective date, in an easy-to-find area of the websites. So, we recommend that you periodically check back here to stay informed of any changes. Please note that your continued use of our websites, software, and/or services after any change means that you agree with, and consent to be bound by, the new Policy.
If you disagree with any changes in this Policy and do not wish your information to be subject to it, you will need to leave our websites, and use the existing previous versions of software and/or services.
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