This Privacy Policy ("Privacy Policy") applies to Zelos Internet GmbH (HillFusion), Alter Wall 32, 20457 Hamburg,Germany and its relevant subsidiaries ("Zelos," "we," or "us") and forms a part of the Zelos Terms of Service (ToS; “Principal Agreement”) between Zelos and the Customer. Zelos engages in providing access to Cloud Services, including on-premise Software, to business clients. Unless otherwise stated by the corresponding Terms of Service (ToS), Zelos is the controller of the personal information collected pursuant to this statement.

Our Services are intended for use by corporate Customers only. If our Services are provided to you through a Customer of us, that Customer is the controller of your personal data and you should contact that Customer with any questions or requests about your personal data. Zelos is not responsible for the privacy or security practices of our Customers, which may deviate from this Privacy Policy.

Definitions of the used terms can be found in Art. 4 of the European General Data Protection Regulation (GDPR).

1. Scope of Application

This Privacy Policy applies to personal data for which Zelos is responsible, which (among other things) may include:

• data collected through the SaaS, websites, mobile applications, marketplaces, developer portals,social media sites (collectively, our "Digital Properties") operated by us;
• data collected in a manner where we post a direct link to this Privacy Policy, such as. e.g., in connection with digital communications, paper forms, in-person interactions (which may include marketing and outreach activities such as surveys, contests, promotions, sweep stakes, conferences, webinars and events);
• data collected about individuals who engage in business transactions with us.
  

This Privacy Policy does not apply to data that Zelos processes on behalf of its Customers. For this constellation, please refer to our separate data processing agreement.

2. Amendments and updates

We reserve the right to update this Policy to reflect changes in legal, regulatory, and operational requirements, our practices, or other factors. Please check this Privacy Policy for updates periodically. If any of these changes are not acceptable to you, discontinue your interaction with us.

If required by applicable law, we will notify you of any changes to this Privacy Policy by posting an update on our website or by other appropriate means.

3. Data sources

We collect data about you and your interaction with us in a variety of forms.

3.1 Data that you provide to us directly. We collect the data that you provide directly to us, when you register and communicate directly with us through our digital properties, or when you participate in our marketing and outreach activities (surveys, promotions, etc).

3.2 Automatically collected information or information derived from your interactions with us. We may collect technical data about your interactions with our digital property (e.g. IP address, browsing preferences, shopping cart and purchase history) via automatic processes. For more information, see Section 8 ("Cookies and Tracking Technologies").

3.3 Data from Public Sources. We may collect information from government agencies from which public records are obtained, as well as information you submit in public forums, including information made publicly available on social media.

3.4 We may receive information about you from other third parties, such as third-party services, telephone companies, authentication service providers, data brokers, and social media (including widgets related to such networks, such as the Facebook Like button). Your interactions with these social media features are governed by the privacy policies of the companies that provide them.

3.5 We may combine and use or disclose information obtained from the various sources described in this Privacy Policy for the purposes set forth below.

4. Personal data types

The types of personal information we collect may include:

• identifiers, such as names, mailing addresses, online identifiers, instant messaging IDs, IP-addresses, email addresses, account or user names, phone numbers and social mediaidentifiers (Twitter handle, Instagram name, etc.);
• Customer data, such as credit card and payment information or creditworthiness;
• Internet or other electronic network activity and device information, such as browsing history, search history, device data, location, and other information regarding your interactions with our digital properties, using cookies or other tracking tools as applicable;
• Professional or employment-related information, such as company name, company website, or business address;
• Conclusions drawn from the information collected by us.

5. Data storage

5.1 To protect your personal data, Zelos has taken measures that comply with the GDPR and the state of the art in the software industry. These measures are continuously reviewed and adjusted if necessary. The aim is to protect your data against accidental or intentional manipulation, partial or complete loss, destruction, unauthorized disclosure or unauthorized access by third parties.

5.2 We only store your personal data to the extent necessary to fulfil the purpose for which it was collected. The storage period depends on the legal requirements and the duration of the contractual relationship. If we no longer need your personal data to fulfil the respective purpose, we will anonymize and/or delete it within the framework of the legal regulations.

6. Data processing

Zelos collects your personal data, in order to be able to:

6.1 Enable interactions and provide you with our Services. We may especially use your personal data to create, maintain, customize, administer and secure your account; provide you with access to the SaaS, Sites and the Services; enter into, administer and perform our contract with you; provide, operate, maintain, improve and promote the SaaS, Sites and Services; process your requests; send you information, including purchase confirmations and invoices and diagnose, repair and track service and quality issues;

6.2 For our own business purposes, we may use your personal data to evaluate the use and performance of programs and technologies related to interactions with us; conduct customer satisfaction surveys; conduct internal research for technology development and demonstration and devise new services; perform credit and payment collection, accounting and other similar business activities; and maintain proper business and other relevant records.

6.3 For legal, security, or other reasons, we may use your personal data to comply with legal requirements; establish, assert, or defend legal claims we have against you or jointly enforce with you; protect the security and integrity of our digital property; monitor compliance with applicable terms of use; and detect, prevent, and respond to security incidents or other malicious, fraudulent, or illegal activity to the extent permitted by law.

6.4 Consent: We may use your personal data for any other purpose for which you have given your consent.

6.5 Marketing: Zelos would like to send you information about products and services of ours that we think you might like. If you have agreed to receive marketing, you may always opt out at a later date. If you are no longer willing to be contacted for marketing purposes, click the link at the end of any newsletter you may have received.

7. Data Sharing

We may share your personal data with:

• Affiliated companies and subsidiaries within our group of companies;
• Service providers that work on our behalf (e.g., IT vendors, data analytics companies, and marketing vendors) or assist us in fulfilling your orders ( e.g., credit card and other payment processors), providing them only with the information they need to perform their services. These companies are contractually prohibited from using or disclosing this information for their own purposes, except at our direction in the course of providing the service or with your consent;
• Other third parties, if you instruct them to do so or if they are necessary to complete transactions;
• Distributors so that they may provide you with information about our Services. We require ourchannel partners to provide an opt-out option in their communications with you. If you opt out,you will not receive any future communications from our channel partner;
• For legal and security purposes, to respond to lawful requests from law enforcement or other government agencies in accordance with our Government Data Request Policy and as otherwise required by law;
• with your consent or with legitimate interest according to Art. 6 (1) f GDPR with any other thirdparty;
• Anonymized or aggregated to third parties as permitted by law.

8. Cookies and tracking technologies

8.1. Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites or use our software or services, we may collect information from you automatically through cookies or similar technology.

8.2 We may use cookies in a range of ways to improve your experience on our website or in using our services, including:

• Keeping you signed in;
• Understanding how you use our website;

8.3 The types of cookies used by Universal Software are:

• Functionality – Zelos uses cookies so that we recognize you on our website and or services and remember your previously selected preferences. These could include what language you prefer and what location you are in. A mix of first-party and third-party cookies may be used.
• Advertising – Zelos uses cookies to collect information about your visit to our website or access of our services, the content you viewed, the links you followed and information about your browser, device, and your IP address. Zelos may sometimes share some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you maybe shown advertising based on your browsing patterns on our website.

8.4 You can set your browser not to accept cookies. However, in a few cases, some of our website or service features may not function as a result. You also have the ability to choose whether you consent to the use and further processing of data collected through non-essential cookies when you first visit the Zelos website. You can update your decision at any time by clicking on the "Cookie Settings" link in the bottom of each of our web pages.

9. Data protection rights

Zelos would like to ensure you are fully aware of all of your data protection rights. Every Customer is entitled to:

• The right to access – You have the right to Zelos for copies of your personal data. We may charge you a small fee for this service.
• The right to rectification – You have the right to request that Zelos correct any information you believe is inaccurate. You also have the right to request Zelos to complete the information you believe is incomplete.
• The right to erasure – You have the right to request that Zelos erase your personal data, under certain conditions.
• The right to restrict processing – You have the right to request that Zelos restrict the processing of your personal data, under certain conditions.
• The right to object to processing – You have the right to object to Zelos’ processing of your personal data, under certain conditions.
• The right to data portability – You have the right to request that Zelos transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we must respond to you within one month. If you would like to exercise any of these rights, please contact us at the details given under section 11.

10. Processing of personal data from children

Our websites and services are not directed to children, and we do not knowingly collect corresponding personal information. If you are a parent or guardian of a minor child and believe that the child has provided us with personal information online, please contact us at the details given under section 11.

11. Contact details

You can reach us via the following contact details:
email: info@hillfusion.com

Mail:
Zelos Internet GmbH
Alter Wall 32
20148 Hamburg
Germany