Privacy Policy

Last modified: 20 May 2018

This Privacy Policy describes how we, the company GOLEM - Gesellschaft für integrierte mikroelektronische Komplettlösungen Gesellschaft m.b.H., registered in Vienna, Austria, collect, use, and share information in connection with your use of our websites, services, and applications (collectively, the "Services"). This Privacy Policy (the "Privacy Policy") does not apply to information our customers may process when using our Services.

We may collect and receive information about users of our Services ("users," "you," or "your") from various sources, including: (i) information you provide through your user account on the Services (your "Account") if you register for the Services; (ii) your use of the Services; and (iii) from third-party websites, services, and partners. We, as official providers of Products and Services presented at this PharosN Portal and providing services under the terms described in the Legal section welcome and thank you for your interest in its using. There are many different ways you can use our services by subscribing for service, downloading a copy of our software, installing it locally, running it as free or paid option, learning how to maximize your business and application results with these powerful digital transformation tools, sharing your achievements and communicating with other people or creating new content.

While using our services we want you to be clear how information which you provide is used and protected for your privacy and what you can do to contribute to its protection.

Our Privacy Policy explains:

• What information we collect and why we collect it.
• How we use that information.
• The choices you have in accessing and updating your information.

We made this document in the way to keep it as simple as possible, but if you’re not familiar with any special terms like cookies, pixel tags, IP addresses, browsers, Engines then read about these in relevant sources e.g. terminology first. Your privacy matters to us as we by all reasons want to ensure long term business with you as our Customer need to secure your interests in applications based on our services and existing legal requirements in your and our countries. Please read the document carefully to get learn about our practices and if you have any questions review relevant legal sections in the Questions and Answers pages.

Information we collect

We collect information required to provide effective and secure services to all Portal Members which are implemented by Members as self-managed ones. It requires unique and secure identification, verification and monitoring of online activities along the whole Member sessions receiving services in two ways:

A: Information you give us. 

Our services require you to register for a Member Account. When you do so voluntarily you provide:

• Your personal information, including your name, residence address, email address, telephone number, birthday, language, secret passwords, location.
• Link (or unlink) on another service (e.g., Facebook or Twitter, etc).
• Information about persons and organizations which you voluntarily identify as members of your virtual organisations and recipients of our services (including yourself as single person entity)

This minimum amount of information that allows us

1. Protecting your account and personal member area by unique identification and verification. If you want to take full advantage of the service features we offer, it allows you managing your virtual organizations - VOrgs , the engines and services installed in these organizations, controlling ownership of unique and complex object models and databases running on these engines. Such databases may grow significantly during the implementation of service subscription and accumulate significant information about your objects of interests and its processes of change and provide you with valuable content for your business and life. The protected control over your data allows minimising the problems of restoring of the services after occasional interrupts of any kind, e.g. computer hardware failures, hardware replacement with more powerful one, change of key employees position in your organization, etc.
2. Providing our services in unified modality and to identifiable organizations as customers inc compliance to legal requirements by European Union
3. Identifying you and other members of your virtual organizations which you set up yourself as master or join as member
4. Monitoring quality of services and providing necessary support in using our services
5. Communicating with you to support effective and interruptible delivery of services and confirmation of payments

The information and measures are aimed at providing you with reliable online self-managed business environment while securing and protecting your intellectual rights and our business interests. 

B: Information we get from your use of our services. 

Nowadays whenever you use any website, mobile application, or other Internet service, there’s certain information that almost always gets created and recorded automatically by various parties. The same is true when you use our services. We may collect information about the services that you use and how you use them, like when you visit PharosN portal or related websites, what services and when you subscribed to, how you use it, view and interact with its content. This information includes:

• Device information

We may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). We may associate your device identifiers or phone number with your Account to improve your security and access to your account.

• Log information

When you use our services or logging content provided in your personal areas, we may automatically collect and store certain information in Engine logs. This may include:

• details of when and how you used particular service,
• Internet protocol address
• device event information such as crashes, system activity, hardware settings, your Pharos Navigator Engine ID, your client ID, browser type, the date and time of your request and referral URL.
• cookies that may uniquely identify your browser or your Account.​

• Location information

When you use a location-enabled service, we may collect and process information about your actual location, like GPS signals sent by a mobile device. We may also use various technologies to determine location, such as sensor data from your device that may, for example, provide information on nearby Wi-Fi access points and cell towers.

• Unique application numbers

Certain services include unique identification numbers. The information about your Engine installation (unique ID, version, its valid running subscriptions, their IDs, assignment to particular organizational group you supervise or take part in) may be sent to PharosN portal when you subscribe, install or end subscription to that service or when that service periodically contacts our Engines, such as for automatic updates.

• Engine and client information

Engine and client specific information such as your Engine ID, client ID, user ID is collected when accessing PharosN portal from your client software. It is used for associating these identifiers with your account to improve your security and access to your account.

• Local storage

We may collect and store information (including personal information) locally on your device using various methods such as browser web storage, and application data caches.

• Cookies, pixel tags and anonymous identifiers

We use various technologies to collect and store information when you use our services, and this may include sending one or more cookies or identifiers to your device. We use cookies and identifiers when you interact with our services for confirmation of your credentials in case your trusted business partners need confirmation of your credentials when you include them into the list of trusted partners on your engine.

How we use information we collect

The information we collect about all our services and members is used for providing, maintaining, protecting, improving the services, developing new ones and protecting our business and our users running services as well as for our legal obligations to comply with the laws of Austria as country of our company registration and European Union in general.

The information is required to ensure your control over your personal account and its protection against any third party attempts to access your self-managed content, while making services, logs and relevant documents available to you at any time and from any location. 

Your personal information as provided during registration is kept inside the PharosN portal, it’s not shared with their parties, and there are no global directories and public access to this information. Your personal information is presented to you in your personal area and in official documents which you may need to have such as service order, subscription confirmation, invoice, agreement.

Some personal data such as your name, picture, email and/or mobile phone contacts is provided to members of your virtual organizations which you may set, supervise or join as member to facilitate collaboration in implementation of joint activities. You see the same information about them as well.

The PharosN portal does not have public directory of its members. Its main objectives are assisting customers in effective application of PharosN digital transformation tools to developing new business opportunities, research and innovation, and learning. The portal membership is not public one unless you decide to make others know what you do, share your results, services and applications. The portal membership does not require to providing any sensitive personal data for its members such as Race, Health status, Sexual orientation, Religious beliefs, Political beliefs, Race.

We consider that you know whom and why you want to collaborate to and set your business relations. That is why initial communications between Portal Members which do not belong to the same organizational group can be made only outside the PharosN portal, meaning that one can invite you to join his/her VOrg group only if he/she knows your email account or you provided it personally. 

However the information which you may provide in your advertisements or business service offers as well as registering as Business Partner and PharosN Discovery web becomes public one and available to every Internet user.  

When you contact our support service we may keep a record of your communications to help solve any issues you might be facing. We may use your email address to inform you about services, such as letting you know about upcoming changes or improvements or notifications related to your activities as Master or Supervisor and acknowledging your activities in your personal area for example changing of your personal data, email, picture, etc.

We use information collected from your PharosN software clients IDs, cookies and other technologies, to improve your user experience and the overall quality of our services. For example, by saving your location, IP and language preferences, can improve focusing of our services to you preferences by geography and industrial branches.

We store and process personal information on PharosN portal located within European Union subject to corresponding legal protection and regulations including General Data Protection Regulation (GDPR).

Transparency, choice and control of preferences

Considering complex nature of privacy concerns in our world we want to be clear about what information we collect, how it is used and why it is done.

You can make your choices about how it is used and how you want to have interaction with PharosN portal in your personal area for

• Reviewing and managing your information presented in Personal profile.
• Ensuring access to your account by communicating with your personal emails and effective methods of reliable authentication such as 2-factor ones that offers you most protection for your access to services and its results such as complex valuable application models, real time systems and their services for different stakeholders.
• Viewing and editing your preferences about notifications, categories of you interest, news.
• Controlling with whom you share information by joining and leaving organizational groups.
• Cancelling your membership and service subscriptions.

You may set your browser to block PharosN portal cookies associated with its services. It however would require your manual login if your cookies are disabled.

Information you share

Accessing and updating your personal information

Whenever you use the PharosN portal services, you have full access to your personal information and can export it for you profile portability. It should be entered by you personally and you are responsible for its correctness. If this information is incorrect then there could be the following optional reasons:

1. You made some errors during initial registration, which was not corrected later and confirmed as correct one.
2. There are changes in your life, etc which you have not introduced in due course.
3. You found that someone changed your data which means that your account was accessed by other persons using your credentials
4. Someone registered on under your name and you occasionally learnt about it (false identity). 
5. Your account is not available meaning technical problem or its cancellations due to non compliance to Terms of Services (TOS).

In the cases #1 and #2 you have ways to update it quickly to keep legal compliance to TOS. When updating your personal information, we may ask you to verify your identity before we can act on your request.

In the case #3 you need promptly change your login and password and review possible reasons of the problem. Then notify the support about each such case.

In the case #4 you shall notify the support about each such case keeping in mind that there are namesakes and we identify every user not only by names but some other unique identifiers.

We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be impractical.

Wherever you can access your account and introduce corrections yourself it can be done for free, except where it would require a disproportionate effort. We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active Engines and may not remove information from our backup systems.

Information we share

You personal account is managed by you only. This personal information is not shared with third parties and complies to General Data Protection Regulation by European Union unless one of the following circumstances applies:

• With your consent

You use tools and instruments in your personal area which allows you releasing your personal information by inviting someone to join your virtual organization or accept invitation of other persons to join their organizations/associations. When you become a business partner and want to publish your business offers at PharosN Discovery you share your personal information outside the PharosN portal.

• With our portal administrators

In rare cases when there are issues related to your account and access to services it shall be managed by PharosN portal administrator who able to:

1. view your personal data, statistics regarding your account, services you use
2. change your account password
3. suspend or terminate your account access
4. access or retain information stored as part of your account
5. receive your account information in order to satisfy applicable law, regulation, legal process or enforceable governmental request
6. restrict your ability to delete or edit information or privacy settings.

• For legal reasons

We may share personal information with organizations or individuals if there is a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• meet applicable law, legal process or enforceable governmental request accordingly to European Union regulations including tax reporting and accounting
• enforce applicable Terms of Service, including investigation of potential violations
• detect, prevent, or otherwise address fraud, security or technical issues
• protect against harm to the rights, property or safety of the Provider of Services, our users or the public as required or permitted by law.

We may share aggregated, non-personally identifiable information publicly and with our partners like publishers, advertisers or connected sites. For example, we may share information publicly to show trends and statistics about the general use of our services.

If we as Provider of Services are involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.

Information security

We do our best efforts to protect PharosN portal and its Members from unauthorized access to or unauthorized alteration, disclosure or destruction of information kept in its databases. In particular:

• We provide all our online services using standards protection SSL/TSL
• Your engine encrypts its backup files with strong AES 256 encryption generating its on-fly password automatically, thus no one knows it but your engine only! 
• We offer and recommend you two step verification when you access your Account
• We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems
• We restrict access to personal information to employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

Right to Forget

Our Privacy Policy supports your right to initiate “Forget me” action offered in your personal area by PharosN portal. By click on the button “Forget me” you can initiate erasing your personal data in the PharosN portal databases which is realised in 7 days after the command. As it was described in the Terms of Services you will lose access to the Portal services including subscriptions, your VOrgs, log files and ability to control your applications models. If you however decide to login into the PharosN portal within this interval of 7 days your personal data and access will be still kept unless you initiate its deletion again.

Children’s privacy

We do not collect information from children under the age of 14, and children under 14 are prohibited from using our Services.

Application

Our Privacy Policy applies to all of the services offered by PharosN portal.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you or in your or in their advertisements, sites that may include services, or other sites linked from our services.

Implementation and Changes

Please regularly review our compliance with our Privacy Policy. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will notify you as Member about any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes).

If you have any questions or concerns about this Privacy Policy, please feel free to email us at support “at-sign” win2biz.com.

The data controller of your personal information is GOLEM - Gesellschaft für integrierte mikroelektronische Komplettlösungen Gesellschaft m.b.H., Austria.