Protecting the data of each of our customers (the “Customer” or “You”) is of the highest
importance to Tangram Technologies S.r.l. (“Tangram” or “Us”), and we go to great lengths to
make sure that we keep it safe. We take your trust and right to privacy seriously. Nevertheless,
the performance of our Services (as defined in section “What Is Personal Data?”) to our
Customers and continuous the strive for improvement in the quality of those Services requires
the processing of certain Personal Data (as defined in section “What Is Personal Data?”).
1. What Is Personal Data? expand_more expand_less
Tangram offers You its video encoding services through its decentralized platform (the
“Tangram Hub”), using peer-to-peer technology applied by Tangram’s own processing
network members (the “Services”) as further described in the Terms & Conditions Tangram
Free. In order to use our Services, You shall provide Us with your email address and upload
your video content (the “Content”) to the Tangram Hub.
Your email address and your IP address are elements of data processed by Us, that describe You and that are linkable to You as a person.
Additional information that Tangram may request from You in order to register and create your personal account on the Tangram Hub (i.e., name, surname, personal address, age, etc.) may qualify as data that describe You and that are linkable to You as a person.
Images or information – inserted in your Content sent to the Tangram Hub – about You or about other data subjects, whose personal data has been provided to You, may qualify as data that describe You or such other data subjects, and that may be associated to You or such other data subjects as an individual person.
Your IP address, your email address and such other personal information required for the creation of your personal account on the Tangram Hub or contained in the Content sent by You to the Tangram Hub are deemed to be “Personal Data”.
Please be aware that, should You have provided Tangram with Personal Data of other third persons, You are required to inform such other third persons about the Processing of their Personal Data by Tangram. By including Personal Data of other third persons in the Content, You are deemed to confirm to Tangram that You are authorized to use such Personal Data of other third persons by such other third persons. In any event, You shall be fully liable regarding the authorization and information to Processing (as defined in section “How And Where Does Tangram Process Personal Data?”) of Personal Data regarding such other third persons and shall hold Tangram fully harmless and indemnify it against any and all claims in this respect.
2. How And Where Does Tangram Process Personal Data? expand_more expand_less
We store and process the Personal Data that You have provided to Us as well as data that we
may infer from your use of Services (the latter generally being in anonymous form).
Your Personal Data may be subject to storage, collection, registration, organization, preservation, consultation, elaboration, modification, selection, extraction, comparison, use, interconnection, blocking, communication, transmission, cancellation and destruction (the “Processing”). Any of these operations may be performed applying those electronic or physical instruments and legal means that we deem appropriate for the security, confidentiality and protection of Personal Data.
Your Content sent to the Tangram Hub is split into fractions and each fraction is sent to peer-to- peer Tangram’s own processing network members (the “Agents”) in order to guarantee a faster, more efficient and safer encoding service.
Personal Data is processed at the Tangram’s operating offices and in any other places where the parties involved in the Processing are located. More details on the parties involved in the Processing can be found in section “Who Processes My Personal Data?”.
In order to provide our Services, transfers of Personal Data through the Tangram Hub to our servers or servers of third-party service providers may involve transferring the Customer’s Personal Data to a country within or outside the European Union.
Tangram uses its own servers and has also rented additional server capacities from third-party providers, located in the EU and the US, all of which are GDPR compliant. All of your Content, including your Personal Data, are transferred exclusively in encrypted form to these servers.
While processing Personal Data, we make sure to take all reasonably possible security measures, both technically and organizationally, to keep Personal Data safe. If You would like to know more about how we keep You and your Personal Data safe, please see section “How Safe Is It to Use Tangram?”.
3. Why Does Tangram Process Personal Data? expand_more expand_less
Tangram may process Personal Data for the following purposes:
(1) Operating the Services and/or the Tangram Hub;
(2) Providing (technical) support when You reach out to Us;
(3) Following up on legal requests for abuse reports and fraud investigations;
(4) In so far as necessary: defending Tangram in legal proceedings in relation to or as a result of your use of Tangram, following a court order, abiding by any law, regulation or governmental request, cooperating with law enforcement, cooperating in fraud investigations from third parties, safeguarding national security, defense, public security or public health;
(5) Evaluating and improving the use of the Tangram Hub and Services as well as for statistical purposes.
(6) Creating and upholding your personal account on the Tangram Hub, facilitating payment of your subscription fee, if any;
(7) Enabling You to engage in actions, promotions or events we offer from time to time. Upon having obtained your consent, we will send You periodic newsletters to keep You updated about news, features, actions or promotions we think You may find useful.
4. Is the Processing Legally Justified? expand_more expand_less
Our Processing activity is executed in conformity with the applicable legal requirements:
- the processing activities set forth in items (1), (2) and (6) above are necessary for the performance of our Services;
- the processing activities set forth in items (3) and (4) above are necessary to comply with our legal obligations; and
- the processing activities set forth in item (5) above are based on our legitimate interest.
With respect to the processing activities set forth in item (7) above, we will send You periodic information and newsletters, once You have consented to it by clicking on the respective “News” box on our website. You may disable this feature at any time by clicking on the respective “Unsubscribe” box in any periodic email You receive from Tangram.
5. For How Long Is My Personal Data Processed? expand_more expand_less
When using the Tangram Hub your uploaded Content is stored on our servers only for as long
as necessary for the completion of the Services (see details hereto in the Terms & Conditions
Tangram Free). As of the time of receipt by You of the download link, your Content is stored
only for a time frame of 3 to 24 hours, based on the available capacity of the Tangram Hub at
any given time.
Based on your registration with Us and your consent for the processing activities set forth above, we keep your Personal Data, such as your name, address, email and other Personal Data in our database for a maximum period of three years, whereupon it will be deleted. You have the right at any time to request the deletion of all of your Personal Data (more details on deletion of Personal Data can be found in sections “What Are My Rights As Customer?” and “Questions?”).
6. Who Processes My Personal Data? expand_more expand_less
Tangram Technologies S.r.l., Via Luigi Canonica 29, Milan, Italy, is the data controller.
Contact email: firstname.lastname@example.org.
Tangram has several data processors to operate the Services we offer to You through the Tangram Hub. We may need to share some of your Personal Data with them to provide the Services to You.
Tangram’s data processors can be categorized as:
- Tangram’s directors, officers, employees, agents, counsels or other advisers (the “Representatives”);
- Tangram’s Agents;
- Tangram’s legal advisors;
- Tangram’s IT persons;
- Tangram’s auditors;
- Tangram’s administrators; and
- Tangram’s third-party service providers entrusted with its client relationship management.
Unless we tell You differently, our data processors do not have any right to use the Personal Data we share with them beyond what is necessary to assist Us in providing our Services to You.
When we cooperate with data processors and they process your Personal Data on our behalf, we make sure that your Personal Data will be handled with the same integrity and security as we do.
7. How Safe Is It To Use Tangram? expand_more expand_less
Tangram carries out the Processing of Personal Data in compliance with the principles of
correctness, fairness, lawfulness, transparency and confidentiality, and in accordance with any
applicable law (such as the European GDPR and the Swiss FADP) or additional rules protecting
Tangram takes appropriate technical and organizational measures to protect your Personal Data against loss or other forms of unlawful processing.
The transfer of Personal Data by the Tangram Hub to and from the servers we use is encrypted. Your Personal Data is only accessible by the persons indicated under “Who Processes My Personal Data?”. We monitor Processing activity to ensure the safety and accuracy of Personal Data.
8. What Are The Conditions For Me to Use The Tangram Free Service? expand_more expand_less
In addition to the content limitations set forth in our Terms & Conditions, there is only one
condition: You have to be at least 16 years old.
However, Tangram reserves the right not to provide Services to persons, who have in the past violated our Terms & Conditions.
9. What Are My Rights As Customer? expand_more expand_less
The rights with respect to Personal Data include your rights and the right of the data subjects,
whose Personal Data has been provided to Tangram by You, at any time: (i) to receive
confirmation regarding the Processing of Personal Data and the persons involved in the
Processing of Personal Data, (ii) to access Personal Data, (iii) to obtain Personal Data in a
structured and organized way, (iv) to object to the Processing of Personal Data, (v) to obtain
rectifications of, to apply restrictions on, to withdraw consent to the use of, Personal Data, (vi)
to have Personal data erased or transformed into anonymous form and (vi) to be informed about
any data breach of Personal Data.
Your consent, or the consent of the data subjects, whose Personal Data has been provided to Tangram by You, to the Processing of Personal Data, may be withdrawn at any time, without affecting the lawfulness of Processing based on consent before its withdrawal. If You withdraw your consent, we will no longer process your Personal Data, but we will no longer be able to provide You with the Services.
If You need more information on your Personal Data, let Us know by sending Us an email to email@example.com. If You change your mind and no longer want Us to process your Personal Data, simply terminate to use Our Services and ask Us to delete your Personal Data.
At any time, You can send your request to access, correction or deletion of your Personal Data to Tangram.
What is a cookie?
A cookie is a small text snippet sent from the web server to the Customer’s internet browser and saved in the Customer’s computer. Cookies are designed to hold a small amount of data specific to the Customer or the website that had sent them. At your next visit on that website, these files will be re-sent to the website that generated them in order to improve your use of the site in question.
“Third parties” cookies, on the other hand, are sent from websites that You are not directly visiting. It occurs namely when accessing certain elements (like images, links, etc.) that are hosted by a different server from the one of the visited website.
Some cookies are necessary for the correct use of the website and cannot be disabled. Others, like the ones regarding memorization of preference parameters, can be disabled.
There are various kinds of cookies, each one having a specific purpose. In order to improve our Services and for marketing activities, Tangram uses the following cookies:
Technical cookies or “first-party” cookies
These cookies are managed by the owner and/or the publisher of the website and are strictly needed for the proper operation of the website but also provide aggregate data for internal surveys regarding the numbers of website-visits, the popularity of the website and traffic flow information.
Technical cookies do not collect information that may be used for advertisements, neither do they track the Customer’s personal browsing history.
In order to install these cookies, the consent of the Customer is not required (as all data collected remains anonymized). If the Customer refuses the installation of these cookies, his/her access to the website will automatically be denied.
“Third party” cookies
These cookies are installed on the Customer’s browser by a party that is not the owner and/or the publisher of the visited website. There are various types of such “third party” cookies, among which:
Analytics Cookies: used to collect and analyze data. They do not identify the individual Customer.
What are cookies needed for?
Cookies help to improve our services and your browsing experience. The advantage for a Customer to have cookies installed on his/her computer consists in the fact that he/she is no longer required to provide the same information every time he/she accesses the same website, as his/her personal information is remembered by the website through the cookies. Examples are: your language preferences, logging into an account, remembering your email address, and acceptance of the Terms & Conditions.
How to disable cookies?
Through the use of our website, the Customer’s consent to the installation of cookies is assumed by Tangram. Customers who do not wish to receive cookies may block “first party”, and/or “third party” cookies following the instructions provided by each browser, set forth hereinafter.
12. Questions? expand_more expand_less
If You have any questions, email Us in English or in Italian. If You have questions about the
way Tangram processes your Personal Data or the personal information Tangram stores about
You, please contact Tangram by sending an email with your question to firstname.lastname@example.org.
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