Welcome to Graboman.com’s Privacy Statement & Data Policy!
Date of Last Revision: December 11, 2017
This policy describes what information we collect and how it is used and shared.
Graboman.com truly respects the privacy of its users, and is fully committed to protect their personal information and use it properly. This policy describes how we may collect and use personal information, and the rights and choices available to our visitors and users regarding such information terms.
Capitalized terms which are not defined herein shall have the meaning ascribed to them in our Terms and Conditions of Use.
1. Your Consent (please read carefully!)
This policy describes our privacy practices – what information we collect on our visitors and users, how we collect it, what we do with it, how we protect it, and your rights regarding your information.
Please note: you are not obligated by law to provide us with any information. You hereby acknowledge, warrant and agree that any information you do provide us is provided of your own free will and consent, for the purposes and uses described herein.
We collect such information regarding our users and visitors, our users’ users, job applicant and anyone else who may provide it to us.
2. What Information Do We Collect?
We collect two types of information: Personal Information (which could be used to uniquely identify an individual) and Non-personal Information (which is non-identifying).
2.1. Visitor and User Information
We collect two types of information regarding our Visitors and Users:
2.1.1 Un-identified and non-identifiable information pertaining to a Visitor or un-identified User, which may be made available to us, or collected automatically via his/her use of the Services (“Non-personal Information”). Such Non-personal Information does not enable us to identify the Visitor or User from whom it was collected. The Non-personal Information collected by us mainly consists of technical and aggregated usage information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.
2.2.2 Individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual, or may be of private or sensitive nature (“Personal Information”). The Personal Information collected by us mainly consists of contact details (e.g., e-mail address or phone number), billing details (name, physical billing address, payment method and transaction details), details regarding a browsing or usage session (IP address, Geo-location and/or device unique identifier), details regarding connected third-party accounts (such as the e-mail or username for a connected PayPal, Google or Facebook account), scanned identification documents provided to us (such as an ID card, driver’s license, passport or official company registration documents), correspondences (including those made through or uploaded to our Services), and any other Personal Information provided to us by Visitors and/or Users through their access to and/or use of the Services. For the avoidance of doubt, any Non-personal Information that is connected or linked to Personal Information (for example, in order to improve the Services we offer) is deemed and treated by us as Personal Information, as long as such connection or linkage exists.
2.2. Users of Users Information
We may also collect similar information pertaining to visitors and users of our User’s Websites (“Users-of-Users”), solely for and on our Users’ behalf (as further described in Section 6 below).
2.3. Graboman Jobs Applicant Information
We also collect information that is provided to us by Graboman jobs candidates (“Applicants”), when they apply to any of the open positions published at https://www.Graboman.com/jobs/, by e-mail or otherwise (as further described in Section 7 below).
3. How Do We Collect Such Information?
There are two main methods we use:
3.1 We collect information through your use of the Services. In other words, when you are visiting or using our Services, including when you browse the Website or any User Website, register a User Account, edit your User Website and upload information and content, and/or download and use any Graboman Apps and/or Mobile Apps, we are aware of it any may gather, collect and record such uses, sessions and related information, either independently or with the help of third-party services as detailed in Section 8 below, including through the use of “cookies” and other tracking technologies, as further detailed in Section 9 below.
3.2 We collect information which you provide us voluntarily. For example, we collect the Personal Information you provide us when you register to our Services; when you sign-in to our Services via third party services such as Facebook or Google; when you place purchases and/or register domain names; when you submit or upload such Personal Information as you use any of our Services; and/or when you contact us directly.
4. Why Do We Collect Such Information?
We collect such Non-personal and Personal Information for the following purposes:
To provide and operate the Services;
To further develop, customize and improve our Services, based on Visitors’ and Users’ common or personal preferences, experiences and difficulties;
To provide our Users with ongoing customer assistance and technical support;
To be able to contact our Visitors and Users with general or personalized service-related notices and promotional messages (as further detailed in Section 10 below);
To facilitate, sponsor and offer certain contests, events and promotions, determine participants’ eligibility, monitor performance, contact winners and grant prizes and benefits;
To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our business partners may use to provide and improve our respective services;
To enhance our data security and fraud prevention capabilities;
To consider Applicants’ candidacy for working at Graboman (as further detailed in Section 7 below); and
To comply with any applicable laws and regulations.
5. Where Do We Store Your Information?
5.1 Graboman Visitors’, Graboman Users’ and Users-of-Users’ Personal Information may be maintained, processed and stored by Graboman and our authorized affiliates and service providers in the United States of America, in Europe (including in Germany and the Netherlands), in Bulgaria, and in other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law (as further explained below).
Graboman Jobs Applicants Information will be maintained, processed and stored in Bulgaria, in the
applied position’s location(s), and as necessary, in secured cloud storage provided by our Third Party Services.
Online Creations Ltd. is based in Bulgaria, which is considered by the European Commission to be offering an adequate level of protection for the personal information of EU Member State residents.
Graboman affiliates and service providers that store or process your Personal Information on Graboman’s behalf are each committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.
5.2 U.S. – Swiss Safe Harbor Framework: Graboman.com complies with the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from Switzerland. Graboman.com has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Graboman.com certification, please visit https://safeharbor.export.gov/swisslist.aspx.
5.3 EU-U.S. Privacy Shield : Graboman.com participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Graboman.com is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov]
Graboman.com is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Graboman.com complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Graboman.com is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (FTC). In certain situations, Graboman.com may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Upon request Graboman will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by contacting us here. We will respond to your request within a reasonable timeframe.
5.4 Data Localization Obligations: If you reside in a jurisdiction that imposes “data localization” or “data residency” obligations (i.e., requiring that Personal Information of its residents be kept within the territorial boundaries of such jurisdiction), and we become aware of that, we may maintain your Personal Information within such territorial boundaries, if we are legally obligated to do so. For example, if we learn that you reside in the Russian Federation, we may be required to maintain your Personal Information there, whether independently or with a local data storage and processing provider.
You acknowledge and agree that while doing so, we may continue to collect, store and use your Personal Information elsewhere, including in the United States of America as explained above.
6. Users-of-Users’ Information
Graboman may collect, store and process certain Non-personal and Personal Information of Users-of-Users (“Users-of-Users Information”), solely on our Users’ behalf and at their direction. For example, each of our Users is able to import their e-mail contacts from third party services like Gmail, or otherwise collect and manage contacts via their User Website. Such contacts are then stored with Graboman, on the User’s behalf.
For such purposes, Graboman serves and shall be considered as a “Data Processor” and not as the “Controller” (as both such capitalized terms are defined in the European Data Protection Directive) of such Users-of-Users Information. The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Users-of-Users Information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions.
You are responsible for the security, integrity and authorized usage of your Users-of-Users’ Personal Information, and for obtaining any consents and permissions required for the collection and usage of such information.
Graboman cannot provide legal advice to Users or their Users-of-Users, however we do recommend that all Users publish and maintain clear and comprehensive privacy policies on their User Websites, in accordance with the applicable laws and regulations, and that all Users-of-Users carefully read those policies and make sure that they consent to them.
For more information on how Users-of-Users Information may be handled by Graboman (which may be relevant for the specific notice you provide to and/or consent you obtain from your Users-of-Users), please see Sections 8, 12 and 13 below.
If you are a visitor, user or customer of any of our Users, please read the following: Graboman has no direct relationship with the individual Users-of-Users whose Personal Information it processes. If you are a visitor, user or customer of any of our Users, and would like to make any requests or queries regarding your Personal Information, please contact such User(s) directly. For example, if you wish to access, correct, amend, or delete inaccurate information processed by Graboman on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data). If requested to remove any Users-of-Users’ Personal Information, we will respond to such request within thirty (30) days. Unless otherwise instructed by our User, we will retain their Users-of-Users’ Personal Information for the period set forth in Section 12 below.
7. Graboman Jobs Applications
Graboman welcomes all qualified Applicants to apply to any of the open positions published at https://www.Graboman.com/jobs/, by sending us their contact details and CV (“Applicants Information”) via the relevant Position Application Form on our Website, or through any other means provided by us.
We understand that privacy and discreetness are crucial to our Applicants, and are committed to keep Applicants Information private and use it solely for Graboman’s internal recruitment purposes (including for identifying Applicants, evaluating their applications, making hiring and employment decisions, and contacting Applicants by phone or in writing).
Please note that Graboman may retain Applicants Information submitted to it even after the applied position has been filled or closed. This is done so we could re-consider Applicants for other positions and opportunities at Graboman; so we could use their Applicants Information as reference for future applications submitted by them; and in case the Applicant is hired, for additional employment and business purposes related to his/her work at Graboman.
If you previously submitted your Applicants Information to Graboman, and now wish to access it, update it or have it deleted from Graboman’s systems, please contact us here.
8. Sharing Personal Information with Third Parties
Graboman may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and instances:
8.1. Third Party Services:
Graboman has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement and data optimization services, content providers, and our legal and financial advisors (collectively, “Third Party Service(s)”).
Such Third Party Services may receive or otherwise have access to our Visitors’ and Users’ Personal Information and/or Users-of-Users’ Personal Information, in its entirety or in part – depending on each of their particular roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.
Graboman is accountable for personal data that it receives under the Privacy Shield and subsequently transfers to a third party as described in the Privacy Shield Principles. In particular, Graboman remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Graboman proves that it is not responsible for the event giving rise to the damage.
8.2. Law Enforcement, Legal Requests and Duties:
Graboman may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.
8.3. Protecting Rights and Safety:
Graboman may share your Personal Information with others if we believe in good faith that this will help protect the rights, property or personal safety of Graboman, any of our Users, any Users-of-Users, or any member of the general public, with or without notice to you.
8.4. Social Media Features and Framed Pages:
Our Services include certain Social Media features and widgets, such as the “Facebook Connect” or “Google Sign-in” features, “Facebook Like” button, the “Share this” button or other interactive mini-programs (“Social Media Features”). These Social Media Features may collect information such as your IP address or which page you are visiting on our Website, and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties are governed by their policies and not ours.
In addition, our Services may enable you to share your Personal Information with third parties directly, such as via page framing techniques to serve content to or from Third Party Services or other parties, while preserving the look and feel of our Website and Services (“Frames”). Please be aware that if you choose to interact or share any Personal Information via such Frames, you are in fact providing it to these third parties and not to us, and such interactions and sharing too are governed by such third parties’ policies and not ours.
8.5. App Market Developers:
As part of our App Market program, we allow third party developers (“Third Party Developer(s)”) to develop and offer their own applications via the Graboman App Market (“Third Party App(s)”), in conjunction with Graboman.
8.6. GrabomanHive API:
By installing certain Graboman Apps and/or Third Party Apps, you also allow their respective provider to share and/or access certain Non-personal and Personal Information regarding you and/or your Users-of-Users, via the “GrabomanHive” API. Such information includes, among others, contact details, messages, business applications and certain activities on the Services and/or User Website, which are stored and thereafter accessible via your User Account. For further details regarding the Personal Information that may be collected and shared via the GrabomanHive API, please see the Graboman App Market Terms and Conditions of Use.
In order to further protect your and your Users-of-Users’ privacy, we contractually prohibit all Third Party Developers from combining Personal Information collected across different User Websites, and from sharing Users-of-Users’ Personal Information other than with other Apps installed on the same User Website, for the purposes of such specific User Website. Graboman however may still access and use information collected and stored via the GrabomanHive API across different User Websites and Apps, as necessary for providing and improving its Services.
You are solely responsible for notifying your Users-of-Users and for obtaining their consent to the collection, processing and use of their Personal Information via the GrabomanHive API.
To prevent the collection or sharing of Personal Information via the GrabomanHive API, you may either avoid installing Apps to your User Website, revoke the permissions granted to Apps you do install, or simply uninstall them. You should note however that previously-installed Apps may still retain certain information that was collected prior to the revocation, so if you wish such information to be deleted, we suggest that you contact them directly and request them to do so.
8.7. Graboman Subsidiaries and Affiliated Companies:
Sharing of Personal Information from Graboman subsidiaries and affiliated companies in the European Union and Switzerland to Graboman’ United States subsidiary, adheres to the EU-US Privacy Shield and US-Swiss Safe Harbor frameworks.
For the avoidance of doubt, Graboman may share your Personal Information in manners other than as described above, pursuant to your explicit approval, or if we are legally obligated to do so. Moreover, Graboman may transfer, share, disclose or otherwise use Non-personal Information in its sole discretion and without the need for further approval.
Graboman, together with its marketing, analytics and technology partners, uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide our Visitors, our Users and their Users-of-Users with a better experience. For example, thanks to these technologies, we are able to maintain and keep track of our Visitor’s and Users’ preferences and authenticated sessions, to better secure our Services, to identify technical issues, user trends and effectiveness of campaigns, and to monitor and improve the overall performance of our Services.
Cookies: In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g., for uploading media, using e-Commerce features, etc.), monitoring performance of our services and marketing campaigns, and generally providing and improving our Services.
If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is also available at www.aboutcookie.org (note that this website is not provided by Graboman, and we therefore cannot ensure its accuracy, completeness or availability). Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.
Clear Gifs: We and certain Third Party Services may employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), which enables them and us to improve our Services by measuring their effectiveness and performance. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, however unlike cookies these are not stored on your device, but are instead embedded within our Services.
Flash and HTML5: We and certain Third Party Services may also employ certain tracking technologies known as “Flash cookies” and “HTML5”, mainly for advertising purposes. Various browsers may offer their own management tools for removing or blocking such technologies. Additional information about managing Flash cookies is available here.
(note that this website is not provided by Graboman, and we therefore cannot ensure its accuracy, completeness or availability).
Behavioral Targeting/Re-Targeting: Certain Third Party Services and ad networks may display advertising on our Website or manage our advertising on other websites. Such parties may use certain tracking technologies to collect certain information about your activities on the Services and different third party websites to provide you with targeted advertising based on your interests and preferences. You may opt-out of receiving targeted ads from certain advertisers and ad networks by clicking here (or if you are located in the European Union click here (provided by YourChoicesOnline.eu). Please note this does not opt you out of receiving any advertising.
User Data Supplementation: We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
“Do Not Track” Signals: Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application.
10. Communications from Graboman
10.1. Promotional Messages:
By subscribing to any Services (including to any of our newsletters, blogs, social media accounts or public events) and providing Graboman with your e-mail address or any other contact information (such as your phone number or social media handle), you expressly agree to receive promotional content, messages or calls from Graboman or our partners (acting on Graboman’s behalf) through such means.
Accordingly, Graboman and its partners shall be entitled to call you or send you promotional content or messages by e-mail, SMS, direct text messages, marketing calls and similar forms of communication. If you wish not to receive such promotional messages or calls, you may notify Graboman at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
10.2. Service and Billing Messages:
Graboman may also contact you with important information regarding our Services, or your use thereof.
For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your User Website; or notify you of material changes in our Services.
You will not be able to opt-out of receiving such Service and Billing Messages.
11. Accessing Your Personal Information
If you wish to access and/or request us to make corrections to the Personal Information that you have stored with us (either yours or your Users-of-Users’), or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, feel free to send us an e-mail from here or mail your request to Graboman.com, Krasna Poliana 1, bl. 103, entr. 3, suite 7, Sofia 1330, Bulgaria, and we will respond within a reasonable timeframe and in accordance with any applicable law.
Note that you may also correct, update or remove certain parts of such Personal Information by yourself, or completely deactivate your User Account, through your User Account or User Website settings.
12. Data Retention
We may retain your Personal Information (as well as your Users-of-Users Information) for as long as your User Account is active or as otherwise needed to provide you with our Services.
We may continue to retain such Personal Information even after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users or their Users-of-Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
Graboman has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and we regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.
However – regardless of the measures and efforts taken by Graboman, we cannot and do not guarantee the absolute protection and security of your Personal Information, your Users-of-Users’ Information or any other User Content you upload, publish or otherwise share with Graboman or anyone else.
We therefore encourage you to set strong passwords for your User Account and User Website, and avoid providing us with any sensitive information which you believe its disclosure could cause you substantial or irreparable harm. Furthermore, because certain areas on our Services are less secure than others (for example, if you set your Support forum ticket to be “Public” instead of “Private”, or if you browse to a non-SSL page), and since e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.
If you have any questions regarding the security of our Services, you are more than welcome to contact us here.
14. Public Forums and User Content
Our Services offer publicly accessible blogs, communities and support forums. Be aware that any information you provide in any such areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blogs, communities or forums, feel free to contact us here. In some cases, we may not be able to remove your Personal Information from such areas. For example, if you use a third party application to post a comment (e.g., the Facebook social plugin application) while logged in to your related profile with such third party, you will need to login into such application or contact its provider if you want to have the Personal Information you posted through it removed.
In any event, we recommend that you do not post any information (or use any posting means to post information) you would not want to be made public on these areas.
If you upload any User Content to your User Account or post it on your User Website, you do so at your own risk.
We cannot control the actions of other Users or members of the public who may access your User Content, and are not responsible for the circumvention of any privacy settings or security measures you or we may have placed on your User Website (including, for instance, password-protected areas on your User Website). You understand and acknowledge that, even after its removal by you or us, copies of User Content may remain viewable in cached and archived pages or if any third parties (including any of your Users-of-Users) have copied or stored such User Content. Again, we recommend that you do not upload or post any information you would not want to be publicly available.
15. Terms and Conditions of Use, Updates and Interpretation
16. Contacting Us