Privacy Policy

Introduction

This Policy is intended to help you understand: 

• why we collect your personal data;
• how we collect, use and store your personal data;
• which rights relating to your personal data you have;
• how you can exercise the rights relating to your personal data;
• how we use cookies and other tracking technologies;
• how we share and disclose your personal data;

Angle2 Agency (“we”, “us”, “our”, “Company”, “Angle2 Agency“) always takes care about privacy issues, which arises when our website users’, subcontractors’ and others’ personal data is processed. This Privacy Policy (“Policy”) describes  the different ways We may collect, use, and share information obtained when you interact with the website https://angle2.agency (the “Site”) and social media, messengers or internet platforms, such as Instagram, LinkedIn (“social media”), WhatsApp, Telegram (“messenger”), Clutch, Behance (“platform”), or information is transferred to us by our Customers to render Website or App design, software and other services (the “Services”) or you provide us with information about yourself via email, video call, voice call or in any other way. Our data processing operations may include, but is not limited to, the following:

• collection; 
• recording;
• organization;
• storage;
• structuring;
• adaptation;
• alteration;
• retrieval;
• consultation;
• use;
• disclosure by transmission;
• dissemination or otherwise making available;
• alignment or combination;
• restriction; and
• erasure or destruction.

You can be our visitor or customer (collectively “users”): 

• You are a Visitor when you merely browse this Site and/or submit your personal data via the Site’s online chat, feedback forms or any other forms;
• You become a Customer when you submit your personal data through a form on the Site or communicate with us by any other way to obtain Services from us with the desire to consume our Services and provide us with information about your offer.

When you submit your personal data to us, you may be asked to consent to our processing of the personal data you provide as explained in this Policy to enable us to provide you with the information or Services requested, if no other legal ground can be used. At the same time, We may ask your consent to collect your personal data for the purpose of improving your user experience connected with usage of our website.

Definitions

To facilitate your understanding of this Policy, we explain the usage of the definitions listed here under the GDPR.

We use the following definitions in this Policy: 

“data controller” means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data is processed. 

“data processor” means the natural or legal person who processes personal data on behalf of the data controller. 

“data subject” is any living individual who is using our Site and/or Services. 

“personal data” means any information relating to you and helping identify you (directly or indirectly) such as your name, last name, email, location data, etc. 

“processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. 

“joint controllers” means two or more controllers jointly determining the purposes and means of processing. 

The definitions of terms used within this Policy are taken from the GDPR.

Data Collection

We collect and process the information about you or obtained from you in accordance with this Policy.

We collect two basic types of information about you in connection with our services: customer data, visitor data, which relate to Customers and Visitors respectively. In particular, we collect: 

1. Online Identifiers. We may collect some of your personal data when you visit our Website. Such data may include your IP address, different types of cookies and other data mentioned herein.  On our Site, we may use cookies and other tracking technologies for a variety of purposes: for statistics, marketing activities and other purposes. Such use may involve the transmission of information from us to you and from you to a third party website or us. To learn more regarding our use of cookies please see our Cookie Policy. Also We may collect online identifiers directly disclosed to us by our Customers.
2. Automatically Collected Information. When you use our Website, we collect certain information about you and your device automatically, including user behaviour, conversions and interface integrations. Our Customer may provide us with automatically collected information for redesigning of Website or App, performing UX audit, Design Management or rendering our software services.
3. Contact Information. We can collect some personal data when you submit your personal data via the Website forms, social media, messengers, email to contact us and/or provide feedback on our Services. Such data may include name, email, place of work and other information you may provide us via available contact options.
4. Payment Information. If you order services from us, you will need to provide certain personal details, including payment information, so such an order can be fulfilled. In order to obtain payment from you, we will use or direct you to a third-party payment processor who will collect this information from you and process your payment.  We also collect your payment information when we engage you as Contractor after the contract with you takes effect.
   Please note that a third-party payment processor is responsible for all collection, processing, and storage of your financial information and we do not have direct access to or possession of your payment card information or banking information.
5. Customer’s Information. As part of our services, we can process third-party personal data that has been provided to us by our Customers. In this case, we process such personal data (which may relate to customers, prospects, employees, contractors of Customer) under instructions provided by the respective Customer. Otherwise, We may collect personal data on behalf of our Customer for the purpose of defining user flow and creating appropriate design decisions. It may include Customer’s users interviewing to grip with users’ needs, goals and behaviors on Customer’s Website, as well as it includes obtaining your personal data, like your early feedback,  which can be disclosed by our Customer to improve the logic and structure of the interface.
6. Communicational Information. We may collect your personal data, you provide us with via email, social media, messengers or platforms, for purposes of carrying out or enhancing quality of our Services, Contractors involvements or for employment purposes. 
7. Candidates and Employees information. During the employment process our Company may collect personal data regarding you, when you send us information about your full name, your education, your employment history and other information you provide us with before We hire you.  After we hire you our Company may collect information about your current health condition, your financial information and other information which We need to collect for complying with local laws.

We use the personal data we collected and the personal data you provided us with or requested us to collect only for the purposes listed in this Policy. We may share your personal data with third parties solely for the purposes listed herein.

We DO NOT sell your data. We DO NOT use automated decision-making and profiling.

We DO NOT intentionally collect and process any sensitive personal data. Please, refrain from sharing your or third-party sensitive personal data with us.

Grounds for processing

Our grounds for processing your personal data are: 

• your consent; 
• our legitimate interests; 
• performance of a contract; 
• our legal obligations. 

We do NOT intentionally collect and process sensitive personal information. Please, refrain from sharing your sensitive personal data when you provide information to us through our Platform or in other ways.

We collect and process your personal data in accordance with the provisions of the GDPR. 

GDPR provides an exclusive list of lawful bases allowing us to process your personal data. During personal data processing, we rely only on four of them, namely: 

Article 6.1(a): consent 

We collect the information you choose to give us, and we process it under your consent. You may withdraw your consent to the processing of your personal data at any time. 

Please remember that the withdrawal of consent does NOT automatically mean that the processing before the withdrawal is considered unlawful. You may withdraw the consent to the processing of your personal data by sending us an email at welcome@angleto.com or by contacting us in any other way convenient for you. 

Article 6.1(f): legitimate interest 

We process your personal data to protect our legitimate interests, such as: 

• preventing fraud, 
• ensuring the security of our Website, and 
• providing you with a seamless user experience. 

We only collect and use the strictly necessary data to achieve these purposes and do not override your fundamental rights and freedoms.

Article 6.1(b): performance of a contract 

When you provide us with personal data to start negotiations or to obtain our Services on our Website or via other convenient to Customer way, this can be considered as a request to form a contract or to perform a contract between you and us. However, we may ask you for clear consent in case of doubt.

Article 6.1(c): legal obligation

We process your personal data to fulfil our legal obligations, such as complying with tax or regulatory requirements. In case  you send us a request to exercise your rights under the GDPR, we may ask you for some personal data we already have to identify you and achieve compliance with the applicable law.

Use of Your Personal Data

Depending on various legal grounds for processing or contract roles, We may act as a controller and a processor regarding the different categories of personal data. We collect the information through the Site and our social media and process it as a data controller as follows:

Purposes of collection	Types of Personal Data	Legal Grounds	Recipients
Maintenance of website	(a) Online Identifiers; (b) Automatically Collected Information;	Our legitimate interest (Article 6(1)(f));	Contractors
Negotiations on contract terms and contract concluding	(c) Contact information; (f) Communicational Information	Performance of a contract (Article 6(1)(b));	Contractors, Messaging and videocalling software providers
Processing of payments for the Services	(d) Payment Information;	Performance of a contract (Article 6(1)(b)); Our legal obligation (Article 6(1)(c));	Contractors Third-party payment processors
Analytics and developing (for optimizing and improving our Site and our Services)	(a) Online Identifiers; (b) Automatically Collected Information; (f) Communicational Data;	Your consent (Article 6(1)(a)); Our legitimate interest (Article 6(1)(f));	Contractors, Google Analytics
Hiring process or Contractor engagement	(g) Candidates and Employees Information;	Our legitimate interest (Article 6(1)(f)); Your consent (Article 6(1)(a)); Legal obligation (Article 6(1)(c));	Contractors, Our Customers

Also, as data processors acting under the instruction of the data controllers (our clients), We may process your personal data only for the purpose of fulfilling design development contracts, master service agreements and other related contracts, connected with design development, integration, maintenance, updating, audit or rendering of our software services and performance of other services, as follows:

Performance of services	Types of personal data	Common Legal Grounds	Subprocessors
Web App designing	(b) Automatically Collected Information; (e) Customer’s information; (f) Communicational Information;	Performance of a contract (Article 6(1)(b)); Your consent (Article 6(1)(a));	Our contractors
Web or App redesign	(b) Automatically Collected Information; (e) Customer’s Information; (f)Communication Information;	Performance of a contract (Article 6(1)(b)); Your consent (Article 6(1)(a));	Our contractors
Full-cycle development	(a) Online Identifiers;  (b) Automatically Collected Information; (e) Customer’s Information; (f) Communication Information;	Performance of a contract (Article 6(1)(b)); Your consent (Article 6(1)(a));	Our contractors
Design Research and UX Audit	(b) Automatically Collected Information; (e) Customer’s Information; (f) Communicational Information;	Performance of a contract (Article 6(1)(b)); Your consent (Article 6(1)(a));	Our contractors
Design Management	(b) Automatically Collected Information; (e) Customer’s Information; (f)Communicational Information;	Performance of a contract (Article 6(1)(b)); Your consent (Article 6(1)(a));	Our contractors

We use your personal data, collected through the Site, social media, messengers or platforms and data transferred to us by Customer or data collected on behalf of Customer, only for the purposes listed in this Policy. We may share your personal data with third parties solely for purposes listed herein.

We do not sell your data.

Use of cookies

Cookies are small text files containing information that websites send to your browser. They are stored on your device, which might be a personal computer, a mobile phone, a tablet or any other device. 

We use them for various purposes, as you can read more about in this section.

We use cookies and other tracking technologies on our Website for some purposes, including enabling the functionality of the Website, enhancing user experience, understanding the online behaviour of people who interact with our Website, and delivering relevant interest-based advertising to you on third-party websites.

We do not use cookies to identify you directly. We only use cookies for the following purposes: 

Necessary: these cookies and other tracking technologies are essential for your use of the Platform and our compliance with applicable data protection laws. We use them for certain purposes, such as checking if your browser supports cookies and determining whether you have accepted the cookie consent box. 

Statistic: these cookies help us to understand how you interact with our Website (e.g., page visits and page load speed) by collecting information anonymously to avoid your identification. Their sole purpose is to improve Website functions. 

Marketing: these cookies are used to track the visitor’s interest in a particular product, to measure the number of unique visits and recognise returning users and to deliver a targeted advertisement to users. These cookies are placed by us and selected third parties and enable adverts to be presented to you on third party websites.For further information on cookies, we kindly refer you to review our Cookie Policy.

Data Security, Integrity and Retention

We will store and process your personal data for as long as needed to provide you or customers with the services. 

Also, you may request erasing of your personal data by contacting us in any way convenient for you.

We store and process your personal data until we do not need it for any of the purposes defined in this Policy unless longer storage is required or permitted by law.

We may not delete or anonymize your data if we are compelled to keep it to comply with the law or legal process.

Notwithstanding any of the aforementioned periods of data storage, you may request to delete your personal data by sending us an email at welcome@angleto.com or contacting us via special form placed on our Website or by another way convenient for you. 

We have implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and others. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

These measures include, but are not limited to the following:

• pseudonymisation;
• differentiation access levels; and
• password complexity policy.

Data Sharing and Disclosure

We only transfer your personal data to third parties according to the requirements of GDPR.

Where possible, we always enter into data processing agreements (DPAs) and Non-Disclosure Agreements (NDAs) with our third parties.

We may disclose the personal data to third parties, including those outside the EU and EEA, provided that proper safeguards are put in place, and the applicable local laws do not put your rights at risk.

We may share your personal data as a data controller to data processors or as data processor to our subprocessors in accordance with provisions specified hereafter.

Sharing data with data processors

There are many features necessary to provide you with access to our Platform that we cannot complete ourselves, thus we seek help from third parties. We may grant some service providers access to your personal data, in whole or in part, to provide the necessary services. 

Therefore, we may share and disclose your personal data to other data processors:

• Google LLC, USA. One of the reasons why We use Google Analytics services is the necessity to observe your activities, concerning your interactions with our Website and to make our Website more comfortable and user-friendly. Another reason to use that tool is the instructions of our Customer for the purpose of rendering our Services and providing our Customers with the most innovative, trend oriented, user-friendly and unique design or software decisions for Customers’ Websites. You may familiarize yourself with information about processing of your personal data, conducted  by this Company, here.
• Pipedrive OÜ, Estonia. We exploit such a software-as-a-services solution, as Pipedrive CRM, to store our Customers’ Contact Data  to organize, manage and improve the customer experience, regarding each of our Services provided to them, throughout the entire customer lifecycle. You may familiarize yourself with information about processing of your personal data, conducted by this Company, here.

During our business activities we may engage different specialists, including on an outsource basis, which may receive your personal data, including technical, sales, UI/UX design, manager and marketing specialists, to provide you with better customer service. Also, we may disclose some of your personal data to our outsource legal and accounting professionals to make our business accurate and transparent. The abovementioned specialists are collectively referred to as Contractors.

We may transfer your personal data to countries outside the EU and EEA (for example, the USA) that are not determined to offer an adequate level of data protection on the basis of article 45 of GDPR (adequacy decision) with appropriate safeguards as determined under the GDPR.We only transfer your personal data to third parties within requirements under the GDPR. Where possible and necessary, we always enter into Data Processing Agreements (DPAs) and Non-Disclosure Agreements (NDAs) with them and treat personal data transfer seriously. Where the Contractor has an appropriate data processing agreement in place, Company may adjoin such data processing agreement. If so, Company and the Contractor may regulate the transfer of the personal data to such Contractor by means of this data processing agreement.

Transferring your personal data outside of the European Economic Area

We may transfer your personal data to third countries outside the European Union (EU) and the European Economic Area (EEA) under Article 46 of the GDPR with  appropriate safeguards, including the Standard Contractual Clauses (SCC).

We may need to transfer your personal data to countries outside the EU and EEA that do not meet the requirements of Article 45 of GDPR on the adequacy of data protection. In such cases, we will transfer your personal data to third countries under Article 46 of GDPR with the appropriate safeguards, including Standard Contractual Clauses (SCC).

We follow internal procedures when disclosing your personal data to countries outside the EU and EEA to ensure adequate safeguards for protecting your privacy and fundamental rights and freedoms. 

We take additional technical and organizational measures when transferring data outside the EU and the EEA, such as assessing the reliability and personal data protection practices of the service provider, encrypting the transferred personal data, promptly responding to any threats to confidentiality, integrity, and availability of personal data, and conducting Transfer Impact Assessments (TIA) when necessary, etc.

Your Rights under the GDPR

You may exercise the following rights under the GDPR:

• right of access;
• right to rectification;
• right to erasure;
• right to restriction of processing;
• right to object to processing;
• right to data portability;
• right to lodge a complaint;
• right to consent withdrawal.
• right not to be subject to automated decision-making

You may exercise the following rights by submitting your request at welcome@angleto.com.

 Rights under the GDPR

• right of access means that you may ask us to send you a copy of your personal data collected together with information regarding the nature, processing and disclosure of that personal data;
• right to rectification means that you may ask us to update and correct the false data, missing or incomplete personal data.  
• right to erasure (to be “forgotten”) means that you may ask us to delete your personal data collected, except insofar it is prohibited by appropriate laws.
• right to restriction of processing means that you may ask us to restrict processing where:
  
  1. your personal data is not correct or outdated;
  2. the processing is unlawful.

• right to object to the processing means that you may raise objections on grounds relating to your particular situation;
• right to data portability means that you may ask us to transfer a copy of your personal data to another organisation or you;
• right to withdraw the consent when your personal data processed on a basis of your consent; 
• right to lodge a complaint with the supervisory data protection authority pertaining to the processing of your personal data. 
  You may submit the complaint to the supervisory authority of your place of residence within the EU or to the data protection authority stated in this Policy.

Please, note that we may need to confirm your identity to process your requests to exercise your rights under the GDPR. Thus, we may not be able to satisfy your request if you do not provide us with sufficient detail to allow us to verify your identity and respond to your request.

Data Protection Authority under the GDPR

We kindly ask you to contact us directly so that we can quickly answer your question.

We kindly invite you to share your concerns with us in the first place regarding any issue related to your personal data processing. You may contact us to address your inquiries via email welcome@angleto.com or via special form placed on our Website.

Supervisory Authority under GDPR: 

In case of any questions regarding data protection, you can apply to the supervisory authority. We will cooperate with the appropriate governmental authorities to resolve any privacy-related complaints that cannot be amicably resolved between you and us. You can find the full list of EU supervisory authorities through the link.

As our Company is established in Estonia, Estonian Supervisory Authorities has following contacts:

Tatari 39
10134 Tallinn
Tel. +372 6828 712
Email: info@aki.ee
Website: http://www.aki.ee/

Changes to the Privacy Policy

We may change this policy occasionally due to the different purposes.

We will notify you of such material changes through means available to us.

This Policy may be changed from time to time due to the implementation of new updates, technologies, laws’ requirements or for other purposes. We will send notice to you if these changes are dramatic, and where required by applicable laws, we will obtain your consent for the subsequent processing. In any case, we encourage you to review this Policy to check for any changes regularly. 

Such notification may be provided via your email address, announcement published on the Website and/or by other means consistent with applicable law.

How to Contact Us

Please contact us if you have any questions about our processing activities, this Privacy Policy, or your rights.

If you have a question related to this Privacy Policy, our processing activities, or your data subject rights under GDPR and other applicable laws, you can contact us directly using the following details: 

• Our email: welcome@angleto.com.
• Our address: Harju maakond, Tallinn, Kesklinna linnaosa, Tuukri tn 19-315, 10120