The Cloqqa online service (the ”Service”) is maintained and provided by Great Slogan Oy (”Cloqqa”).
Please read these terms of use (the ”Contract” or “Terms”) carefully before installing and beginning to use the Service. By clicking the “I agree” button, you accept these Terms and the Contract is entered between you and Cloqqa. By installing the Service or using the Service you are committed to following these Terms in all respects. If you do not accept these Terms, you do not have the right to install, open or use the Service.
As party to this Contract with Cloqqa you are either a legal entity (organization) subscribing to the Service (“User Organization” or “you” or “User”) or a private person who is an employee or partner designated by said User Organization to use the Service (the “End User” or “you” or “User”). By this Contract, you are granted certain rights to use the Service that are explicitly applicable to you (as User Organization or End User). Cloqqa reserves all other rights to the Service.
If you enter into this Contract on behalf of a User Organization, by finalizing the subscription to the Service you hereby warrant to have the required authority to subscribe to the Service and commit to these Terms on behalf of the User Organization.
The User Organization/End User entering into this Contract and Cloqqa shall be individually referred to as the “Party” and together as the “Parties”.
Only a User Organization registered to the Service or an End User designated by said entity to use the Service and also Party to this Contract shall have the right to use the Service. The User Organization may use the Service with End Users within and outside its own organization. The User Organization shall at all times remain liable for all obligations and liabilities as well as actions and negligence of End Users as for its own. The Service may only be used for the internal operations of the User Organization (that has acquired the user right for the End User by inviting the End User to use the Service). Any commercial use of the Service is prohibited.
The User Organization shall ensure that no person invited by it to use the Service uses the Service without having accepted this Contract. The User Organization and each End User will receive a personal user ID and password for using the Service after entering into this Contract. Your user ID and password may only be used by you personally. You shall ensure that you store your user ID and password carefully and that you do not give or disclose them to any third party. You are liable for any use of the Service that takes place by using your user ID and password (and any user ID and password of an End User, if you are a User Organization). You shall immediately inform Cloqqa of any third parties gaining knowledge of a user ID or password, or of any suspected misuse of a user ID or password. Only the User Organization’s administrator may add End Users and change the permission levels of End Users.
The granted right to use the Service is personal, limited and non-exclusive. You undertake not to sell, lease, lend, or otherwise transfer your right to use the Service to third parties. In addition, you are not permitted to do any of the following:
Cloqqa has the right to temporarily or permanently prevent the access of the User Organization and any End User to the Service or limit such access if Cloqqa suspects that the User Organization or an End User breaches the Terms, law or good practice.
In order to maintain the information security of the Service, Cloqqa may require the User Organization and the End Users to change the password required for the use of the Service and provide them with other necessary instructions and orders in relation to the use of the Software.
The User shall not use the Service as a storage service. The User is solely responsible for storage of and taking and maintaining appropriate back-up copies of any of its User Data (as defined below).
All intellectual property rights related to the Service, the data, functions and other content contained therein belong to Cloqqa. The Cloqqa and Great Slogan names and logos are owned by Cloqqa, and may not be copied, imitated or used without the permission of Cloqqa. The User does not have the right to change, modify, delete copy, publish, make available to the public or transfer anything that is subject to intellectual property rights. Nothing in this Agreement shall constitute a transfer of any intellectual property rights of Cloqqa to the User.
Cloqqa retains all rights except for the rights expressly granted in these Terms.
“User Data” shall mean all the User’s data (and all data that a third party has authorized the User to process and submit to the Service) that the User submits to the Service. The intellectual property rights and the title to the User Data shall belong to the User or a third party who has authorized the User to process the User Data.
Cloqqa and its subcontractors may (subject to applicable data protection laws) use, copy, store, and modify User Data during the term of this Contract for the purposes of providing the Service to you as well as analyze the use of the Service.
Cloqqa and its subcontractors shall have the right to collect and generate anonymous data and statistics from the User Data and your use of the Service (“Aggregate Data”) for updates and development of the Service. The intellectual property rights and title to Aggregate Data shall belong to Cloqqa. For clarity, Aggregate Data shall not in any event be used by Cloqqa or any third party in a manner that identifies you or any other natural person.
The User shall be responsible for its User Data and shall be liable for ensuring that User Data is accurate and complete and does not infringe any third party rights (including intellectual property rights) or violate applicable legislation, and that the User possesses such necessary licenses and permissions from third parties as may be required in order to use the User Data as set out herein. The Service may not be used to store any personal data identifying any natural person.
Cloqqa has the right to freely develop and modify the Service and the system requirements for the equipment needed to use the Service. Cloqqa has the right to provide the Service in the manner it sees fit. Cloqqa may make modifications and changes to the Service, including its functionalities and features, at any time at its sole discretion and without notifying the User thereof. However, if Cloqqa introduces changes that materially reduce the functionalities of the Service, Cloqqa aims to notify the User thereof in advance, e.g. through the Service.
Cloqqa has the right to suspend the production and the availability of the Service or part of it at any time for any reason, including changing, disabling and removing the Service or part of it.
The Service is provided for use “as is” without any obligations to modify or update the Software. The Service may occasionally be unavailable, and defects or maintenance may interfere with the operation of the Service. Cloqqa does not provide any warranty of any kind, either express or implied, including but not limited to any warranties related to the quality, accuracy, reliability, functionality, merchantability, fitness for a particular purpose, availability, security, performance or results of the Service.
The User shall acquire hardware and internet connections needed to use the Service at its own expense. Cloqqa does not guarantee that the Service is available for use on all devices. The User is solely responsible for costs of data transfer and other costs related to the use of the Service.
Cloqqa is not liable to any User Organization, any End User or a third party for any direct or indirect damages arising from this Contract or the use of the Service, unless otherwise provided by mandatory law.
We reserve the right to rely on subcontractors for the provision of the Service.
Cloqqa collects and processes data, including personal data, in relation to the User’s registration to and use of the Service in accordance with its Privacy Policy in force from time to time. Cloqqa’s Privacy Policy can be found at https://www.cloqqa.com
The Parties may terminate this Contract at any time by giving a written notice to the other Party (e.g. by using the functionalities of the Service or by email), in which case the User’s right to use the Service, including the User’s user ID, expires immediately. This Contract and the User Organization’s and all End Users’ rights to use the Service expire automatically upon the expiry or termination of the User Organization’s contract with Cloqqa.
The User will lose access to any and all information entered into the Service by the User immediately upon the expiry or termination of the Contract.
You do not have the right to assign this Contract to a third party. Cloqqa has the right to assign this Contract to its affiliates or successors as part of a restructuring, merger, acquisition, asset sale or other corporate reorganization.
Cloqqa may make changes to these Terms from time to time and the most current version of these Terms, available at Cloqqa’s website at each time, will govern the relationship between you and Cloqqa. Cloqqa aims to notify you of material changes to the Terms in advance, e.g. by posting the new Terms in the Service or by sending them by email to the address you have submitted to Cloqqa. By continuing to access or use the Service after the new terms have become effective, you accept to be bound by the new terms of this Contract.
These Terms shall be governed by Finnish law, except for its provisions on the choice of law. Any disputes shall be settled in the District Court of Helsinki.
Great Slogan Oy
Kympinkatu 7
40320 Jyväskylä
app@cloqqa.fi
(c) Cloqqa 2019
These terms of use were updated in 11.10.2019
This Privacy Policy is applicable to the personal data processed by Great Slogan Oy (“Cloqqa” or “we”) relating to the users (“Users” or “you”) of the Cloqqa website and the Cloqqa service (hereinafter jointly refered to as “Service”).
The purpose of this Privacy Policy is to provide Users with information about the processing of their personal data in accordance with the information obligations set out in Articles 13 and 14 of the General Data Protection Regulation 2016/679 (GDPR).
Please note that this Privacy Policy only applies to processing carried out by Cloqqa as a data controller. This Privacy Policy does not address, and we are not responsible for, the privacy and data processing practices of any third parties.
This Privacy Policy may be updated if required in order to reflect the changes in data processing practices or otherwise. The current version can be found on our website https://www.cloqqa.com/privacy-policy/. We will not make substantial changes to this Privacy Policy or reduce the rights of Users under this Privacy Policy without providing a notice thereof.
Contact details
Name: Great Slogan Oy
Business ID: 2812252-8
Correspondence address: Kympinkatu 7, 40320 Jyväskylä, Finland
Contact: app@cloqqa.com
Website: cloqqa.com
We collect two types of information concerning the Users: (i) User Data; and (ii) Analytics Data.
Most of the User Data is received directly from Users in connection with the use of the Service. User Data may also be provided to us by the company or organization on behalf of which you are using the Services.
Analytics Data is collected automatically as you use the Service. Although we do not normally use Analytics Data to identify individuals, sometimes individuals can be recognized from it, either alone or when combined or linked with User Data. In such situations, Analytics Data shall also be considered to be personal data under applicable laws and we will treat the combined data as personal data.
Cloqqa may process the following User Data and Analytics Data:
User Data
Analytics Data
We use various technologies to collect and store Analytics Data and other information when Users visit our Service, including cookies.
Cookies are small text files sent and saved on your device that allows us to identify visitors of our websites and facilitate the use of our Service and to create aggregate information of our visitors. This helps us to improve our Service and better serve our Users. The cookies will not harm your device or files. We use cookies to tailor our Service and the information we provide in accordance with the individual interests of our Users. Cookies are also used to integrate our social media accounts onto our website.
Users may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. For example, the following links provide information on how to adjust the cookie settings on some popular browsers:
Please note that some parts of our Service may not function properly if the use of cookies is refused.
We also use Google Analytics to compile Analytics Data and reports on visitor usage. For an overview of Google Analytics, please visit Google Analytics. It is possible to opt-out of Google Analytics with the following browser add-on tool:
We also use the following social media cookies and pixels on our Service:
To provide our Service and carry out our contractual obligations (legal ground: performance of a contract and legitimate interest)
We process personal data to be able to offer the Service to our Users and to run and maintain our business. Personal data may be processed in order to carry out our contractual obligations towards the User or towards the organization the User represents. We may use the data for example to offer essential functionalities of the Service and to provide access to the Service.
For our legal obligations (legal ground: compliance with a legal obligation)
We process personal data to enable us to administer and fulfil our obligations under law. This includes data processed for complying with our accounting obligations and providing information to relevant authorities.
For security, claims handling and legal processes (legal ground: legitimate interest)
We may process personal data in relation to claims handling, debt collection and legal processes. We may also process data for the detection or prevention of fraud, misuse of our Services and for activities aimed at ensuring the security of our data, systems and networks.
For communication and marketing (legal ground: legitimate interest)
We may process personal data for the purpose of contacting our Users regarding our Service and for informing Users of changes in our Service. We may also process personal data to market our Service, for example in the form of sending newsletters.
For quality improvement and trend analysis (legal ground: legitimate interest)
We may process information regarding the use of the Service to improve the quality of our service, for example by analysing any trends in the use of our Service. Where possible, we will do this using only aggregated, non-personally identifiable data.
We primarily process personal data of Users on a contractual basis. For Users acting as representatives of our customer organizations, personal data is primarily processed based on our legitimate interest whilst fulfilling our contractual obligations towards the organisations they represent.
We may also process personal data based on our legitimate interests, for example in connection with analytics and marketing. When choosing to use your data on the basis of our legitimate interests, we carefully weigh our own interests against your right to privacy.
In certain cases Users may be requested to grant their consent for the processing of personal data. In this event, the legal ground for such processing is your consent. You may withdraw your consent at any time.
Cloqqa stores Users’ personal data primarily within the European Economic Area. However, we have service providers in several geographical locations. As such, we or our service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area or outside of the User’s domicile.
We will take steps to ensure that the Users’ personal data receives an adequate level of protection in the jurisdictions in which it is processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers based on the Standard Contractual Clauses or other similar arrangements.
We do not share personal data with third parties outside of Cloqqa’s organization unless one of the following circumstances applies:
It is necessary for the purposes set out in this Privacy Policy
To the extent that third parties need access to personal data to perform the Service, Cloqqa has taken appropriate contractual and organisational measures to ensure that personal data are processed exclusively for the purposes specified in this Privacy Policy and in accordance with all applicable laws and regulations.
For legal reasons
We may share personal data with third parties outside Cloqqa’s organization if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, property or safety of Cloqqa, our Users or the public in accordance with the law. When possible, we will inform Users about such transfer and processing.
To authorized service providers
We may share personal data to authorized service providers who perform services for us (including data storage, sales, marketing and support services). Our agreements with our service providers include commitments that the service providers agree to limit their use of personal data and to comply with privacy and security standards at least as stringent as the terms of this Privacy Policy.
For other legitimate reasons
If Cloqqa is involved in a merger, acquisition or asset sale, we may transfer personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all Users concerned when the personal data are transferred or become subject to a different privacy policy as soon as reasonably possible.
With explicit consent
We may share personal data with third parties outside Cloqqa’s organization for other reasons than the ones mentioned before, when we have the User’s explicit consent to do so. You have the right to withdraw this consent at all times.
Cloqqa does not store personal data longer than is legally permitted and necessary for the purposes of providing the Service or the relevant parts thereof. The storage period depends on the nature of the information and the purposes of processing. The maximum period may therefore vary per use.
We will store Analytics Data relating to the Service no longer than reasonably necessary.
Right to access
You have the right to access your personal data processed by us. You may contact us and we will inform what personal data we have collected and processed regarding you. Where possible, Users should primarily use the Service functionalities to access their own account information.
Right to withdraw consent
In case the processing is based on a consent you have granted to us, you may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use our services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to rectify
You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us. Where possible, Users should primarily use the Service functionalities to correct their own account information.
Right to erasure
You may also ask us to erase your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.
Right to object
You have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of the Services or for compliance with a legal obligation. If you object to the further processing of your personal data, this may lead to fewer possibilities to use the our Service.
Right to restriction of processing
You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use our Service.
Right to data portability
You have the right to receive your personal data from us in a structured and commonly used format and to independently transmit those data to a third party.
How to use the rights
The above mentioned rights may be used by sending a letter or an e-mail to us on the addresses set out above. We may request the provision of additional information necessary to confirm your identity.
We reserve the right to reject requests that are unreasonably repetitive, excessive or manifestly unfounded.
Notwithstanding any consent granted beforehand for the purposes of direct marketing, you have the right to prohibit us from using your personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the unsubscribe possibility offered in connection with any direct marketing messages.
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability restore the data. We regularly test our systems, and other assets for security vulnerabilities.
Should despite of the security measures, a security breach occur that is likely to have negative effects on your privacy, we will inform you and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.
In case you consider our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection.
In Finland, the local supervisory authority is the Data Protection Ombudsman (https://www.tietosuoja.fi).
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