This Privacy Policy applies to Cmmndr Reporting, a service of Kondiment Worldwide SRL, available at https://reporting.cmmndr.tools (the ‘Platform’), and other services provided by us and on which a link to this Privacy Policy is displayed, and all other communications with individuals through written or oral means, such as email or phone (collectively, together with the ‘Platform’, our ‘Service’).
This Privacy Policy (‘Policy’) describes the information that we gather on or through the Service, how we use and disclose such information, and the steps we take to protect such information.
By visiting the Platform or by purchasing or using the Service, you accept the privacy practices described in this Policy.
This Policy is incorporated into, and is subject to, the Cmmndr Reporting Terms of Service. Capitalized terms used but not defined in this Policy have the meaning given to them in the Cmmndr Reporting’ Terms of Service.
1. The information we collect on the Service
We collect different types of information from or through the Service. The legal bases for Cmmndr Reporting’ processing of personal data are primarily that the processing is necessary for providing the Service in accordance with Cmmndr Reporting’ Terms of Service and that the processing is carried out in Cmmndr Reporting’ legitimate interests, which are further explained in the section ‘How we use the information we collect’ of this Policy. We may also process data upon your consent, asking for it as appropriate.
1.1 User-provided information. When you use the Service, as a User, you may provide, and we may collect Personal Data. Examples of Personal Data include first name, last name, email address, or phone numbers\. Personal Data also includes other information, such as geographic area or language preferences, when any such information is linked to information that identifies a specific individual. You may provide us with Personal Data in various ways on the Service. For example, when you register for an Account, use the Service, interact with other users of the Service through communication or messaging capabilities, or send us customer service-related requests.
1.2 Information collected by Users. A User may connect User’s Client Data into the Service. Cmmndr Reporting has no direct relationship with the individuals whose Personal Data it hosts as part of User’s Client Data. Each User is responsible for providing notice to its Clients and third persons concerning the purpose for which Users collects their Personal Data and how this Personal Data is processed in or through the Service as part of User’s Client Data.
1.3 Information collected through Third Party services. The Cmmndr Reporting Service allows User to gather data from multiple third-party data sources and services, such as Google, Facebook, Tiktok, X and others. When User connects the data sources from Third-Party Services, such as Facebook, Google Analytics and Google Ads or from other data sources, the data is collected by Cmmndr with the only goal to provide the reporting services to the User according to the service functionalities. User has the choice to select which data sources connects and it the solely responsible for ascertaining that he has the right to the data provided in the data sources. User must obtain any consents and authorizations may be needed from time to time in relation to such data or other content and their processing by using the Service. We do not assume any liability for such Third-Party Services and User is exclusively responsible for obtaining any necessary licenses or consents needed for the data he provides access to Cmmndr Service.
1.4 ‘Automatically collected’ information. When a User uses the Service, we may automatically record certain information from the User’s or Visitor’s device by using various types of technology, including cookies. This ‘automatically collected’ information may include IP address or other device address or ID, web browser and/or device type, the pages or other content the User views or interacts with on the Service, and the dates and times of the visit, access, or use of the Service. We also may use these technologies to collect information regarding a Visitor or User’s interaction with email messages, such as whether the Visitor or User opens, clicks on, or forwards a message. This information is gathered from all Users.
2. How we use the information we collect
We use the information we collect in a variety of ways in providing the Service and operating our business, including the following:
2.1 Operations. We use the information to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service.
2.2 Improvements. We use the information - other than User’s Client Data - to understand and analyze the usage trends and preferences of our Users, to improve the Service, and to develop new products, services, features, and functionality.
2.3 Communications. We may use a User’s email address or other information – other than User’s Client Data – to contact that Visitor or User for:
2.4 Cookies and tracking technologies. We use automatically collected information and other information collected on the Service through cookies and similar technologies to:
You can obtain more information about cookies by visiting http://www.allaboutcookies.org. You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.
2.5 Analytics. We use Google Analytics and HotJar to measure and evaluate access to create User navigation reports for our Platform administrators. Each of these systems operates independently from us and has its own privacy policy, which we strongly suggest you review.
We take measures to protect the technical information collected by our use of these systems. The data collected will only be used on a need to know basis to resolve technical issues, administer the Platform and identify visitor preferences.
3. To whom we disclose Information
Except as described in this Policy, we do not disclose the Personal Data of a User or User’s Client Data that we collect or store on the Service to third parties without the consent of the applicable User. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
3.1 Service Providers. We work with third party service providers who provide development services, hosting, maintenance services, and other types of services for us. These third parties may have access to, or process Personal Data or User’s Client Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.
3.2 Law Enforcement, Legal Process, and Compliance. We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to:
4. Your choices
4.1 Access, Correction, Deletion. We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. If you wish to access or amend any other Personal Data we hold about you, or to request that we delete or transfer any information about you, you may contact us at [email protected]. At your request, we will have any reference to you deleted or blocked in our database.
You may update, correct, or cancel your Account information and preferences at any time by accessing your Account settings page in the upper-right hand corner of the Platform. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Service.
This provision does not apply to Personal Data that is part of User’s Client Data. In this case, the management of the User’s Client Data is subject to the User’s own Privacy Policy, and any request for access, correction or deletion should be made to the User responsible for the connection of such data into the Service.
4.2 Navigation information. You may opt out from the collection of navigation information about your visit by Google Analytics by using the Google Analytics Opt-out feature.
4.3 Opting out from Commercial Communications. If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to [email protected].
Please be aware that if you opt-out of receiving commercial emails from us or otherwise modify the nature or frequency of promotional communications you receive from us, you will continue to receive administrative messages from us regarding the Service.
Cmmndr Reporting has no direct relationship with the User’s Clients or third party whose Personal Data it may process on behalf of a User. An individual who seeks access, or who seeks to correct, amend, delete inaccurate data or withdraw consent for further contact should direct his or her query to the User they deal with directly. If the User requests Cmmndr Reporting remove the data, we will respond to its request within thirty (30) days. We will delete, amend, or block access to any Personal Data that we are storing or connecting to only if we receive a written request to do so from the User who is responsible for such Personal Data, unless we have a legal right to retain such Personal Data. We reserve the right to retain a copy of such data for archiving purposes, or to defend our rights in litigation.
5. Third-party services, data and content
5.1 The Service contains features provided by third parties, as well as information provided by third parties' APIs, including, but not limited to: Google's API, Meta's API, X (former Twitter)’s API, TikTok’s API. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
To do so, please read this online documentation from third parties we currently use, you can also use their Privacy pages to see and manage all the sites and apps that have access to some of your Google Account data.
5.2 The Service allows you to gather data from multiple third-party data sources and services, including various third-party websites (jointly “Third-Party Services”). The Third-Party Services from which the data can be gathered are selected by Cmmndr Reporting at its sole discretion and Cmmndr Reporting may, during the Term, change the Third-Party Services that are compatible with the Service. In addition, Cmmndr Reporting may discontinue the compatible Third-Party Services if the applicable service providers of the Third-Party Services discontinue the relevant services or discontinue making such services available to Cmmndr Reporting.
5.3 Cmmndr Reporting assumes no liability whatsoever for the data or other content collected from Third-Party Services, such as Meta Ads, Google Analytics and Google Ads. You are solely responsible for ascertaining that you have the right to use the Service for gathering and processing any such data by using the Service, and you must obtain any such consents and authorizations as may be needed from time to time in relation to such data or other content and their processing by using the Service. We do not assume any liability for such Third-Party Services, and you are exclusively responsible for obtaining any necessary licenses or consents needed for their use. You must familiarize yourself with the applicable terms and conditions, including any restrictions on use, in relation to any such Third-Party Services and you agree to comply with the third-party terms and conditions applicable to the Third-Party Services in addition to the terms of the Agreement.
5.4 Furthermore, the Service may contain links to web pages and content of third parties as a service to those interested in this information. We do not monitor, endorse, or adopt, or have any control over any third-party web pages or content. We undertake no responsibility to update or review any such web pages or third-party content and can make no guarantee as to its accuracy or completeness. Additionally, if you follow a link or otherwise navigate away from the Service, please be aware that these Terms will no longer govern. You should review the applicable terms and policies, including privacy and data gathering practices, of any web page, third-party content or service provider to which you navigate from the Service. You access and use third-party content at your own risk.
5.5 With respect to Google services, our tools will only have rights to access your Google Analytics/Ads/YouTube data (depending on which service you are logging in to), and nothing else on your Google account. You can revoke Cmmndr Reporting’ right to access your data at any point from your Google account control panel (https://security.google.com/settings/security/permissions). With respect to Google services, use and transfer of information received from Google APIs to the Services will adhere to Google API Services User Data Policy, including the Limited Use requirements.
6. Data Security
We maintain administrative, physical, and technical safeguards for protection of the security, confidentiality and integrity of Personal Data. This includes, for example, firewalls, password protection, and other access and authentication controls. We use SSL technology to encrypt data during transmission through the public internet. Those safeguards will include, but will not be limited to, measures for preventing access, use, modification or disclosure of Personal Data by our personnel except:
If you believe your Personal Data has been compromised, please contact us at [email protected].
If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.
6.1 Personal Data collection and storage. Personal Data is collected and stored at the following times/places, and for the following purposes:
6.2 User Data and User’s Client Data collection and storage. We store aggregate User Data. This is to increase the Services’ performance only, in order to prevent the Platform from calling third-party platform APIs every time a User views or edits a dashboard. User Data connected from third-party platforms is usually read-only; therefore, there is no way we can add, update, or delete it. In a case where third-party platforms grant edit capabilities to the Service, we do not edit, update, or delete User Data account information under any circumstance.
User Data and User’s Client Data is stored in the following places in order to provide the Cmmndr Reporting Services and prevent or address service or technical problems:
For more information or to address any concerns, please contact [email protected]
7. Sub-processors and transfers to third countries
7.1 Regardless of the hosting, if you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you may be transferring your User’s Client Data and Personal Data outside of those regions for storage and processing by our service providers listed in the Cmmndr Reporting Terms of Service. We will comply with GDPR requirements providing adequate protection for the transfer of personal information from Europe to the U.S.. Also, we may transfer your data to the U.S., the EEA, or other countries or regions deemed by the European Commission to provide adequate protection of personal data in connection with storage and processing of data, fulfilling your requests, and operating the Service.
7.2 Parts of cloud based services are delivered by third-parties providers (Amazon Web Services and Google Cloud) and the parties acknowledge that any personal data processed within the cloud service shall be exclusively governed by the terms and conditions for the cloud service as stipulated and amended from time to time by the cloud service provider.
7.3 The Customer acknowledges that Cmmndr Reporting needs to engage other processors for carrying out specific processing activities, and that Cmmndr Reporting wishes to deliver standard services to its customers in a consistent, secure and efficient manner. Cmmndr Reporting shall ensure that sub-processors are bound by a written agreement that requires them to provide at least the level of data protection required by Cmmndr Reporting. Cmmndr Reporting shall inform the Customer of changes concerning its sub-processors, including the identity and location of new or replaced sub-processors. A list of sub-processors (including their name, country, processing activities and country/area where processing activities are carried out) is available at Cmmndr Reporting web page or other location as designated by Cmmndr Reporting from time to time.
7.4 Where a sub-processor fails to fulfil its data protection obligation, Cmmndr Reporting shall remain fully liable to the Customer for the performance of that sub-processor’s obligations.
7.5 If the Customer has a reasonable objection to any new or replacement sub-processor, it shall notify Cmmndr Reporting of such objection in writing within ten (10) days of the notification. In case the Customer objects to the use of a specific sub-processor, the parties shall enter into good faith negotiations on how to resolve the issue. In case the negotiations do not solve the issue and the Customer opposes Cmmndr Reporting’ use of a specific sub-processor either party shall, for a justified reason and as a final remedy, be entitled to terminate the relevant Agreement on thirty days’ written notice.
7.6 Cmmndr Reporting and its sub-processors may transfer or process personal data outside the EU/EEA area.
7.7 When transfer of personal data by Cmmndr Reporting to a sub-processor outside the EU/EEA, is permitted as stated above, in case of any transfer Cmmndr Reporting shall ensure that transfer is only made to (a) a country deemed by the Commission to have an adequate level of protection, (b) entities having entered into the EU Commission standard contractual clauses approved by the European Union concerning the transfer of personal data to outside the EU/EEA or provided other appropriate safeguards as described in Article 46 of the GDPR.
7.8 Subject to the above and subject to Cmmndr Reporting keeping the Customer informed of any transfer of personal data outside the EU/EEA, the Customer gives its consent to the transfers and authorizes Cmmndr Reporting to conclude processor to processor standard contractual clauses based on the European Commission Decision 2021/915 of 4 June 2021 to transfer Personal Data to processors located outside the EU/EEA.
8. Data Transfer
We may transfer, process and store Personal Data we collect through the Services in centralized databases and with service providers located in the U.S. The U.S. may not have the same data protection framework as the country from which you may be using the Services. When we transfer Personal Data to the U.S., we will protect it as described in this Privacy Policy.
The Service is hosted in the EU. Regardless of the hosting, if you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you may be transferring your User’s Client Data and Personal Data outside of those regions for storage and processing by our service providers listed in the Cmmndr Reporting Terms of Service. We will comply with GDPR requirements providing adequate protection for the transfer of personal information from Europe to the U.S.. Also, we may transfer your data to the U.S., the EEA, or other countries or regions deemed by the European Commission to provide adequate protection of personal data in connection with storage and processing of data, fulfilling your requests, and operating the Service.
9. Data controller and data processor
Cmmndr Reporting does not own, control or direct the use of any of the User’s Client Data stored or processed by a User via the Service. Only the Users are entitled to access, retrieve, and direct the use of such User’s Client Data. Cmmndr Reporting is largely unaware of what User’s Client Data is actually being stored or made available by a User to the Service and does not directly access such User’s Client Data except as authorized by the User, or as necessary to provide Services to the User.
Because Cmmndr Reporting does not collect or determine the use of any Personal Data contained in the User’s Client Data, and because it does not determine the purposes for which such Personal Data is collected, the means of collecting such Personal Data, or the uses of such Personal Data, Cmmndr Reporting is not acting in the capacity of data controller in terms of the European Union’s General Data Protection Regulation (Regulation (EU) 2016/679, hereinafter ‘GDPR’) and does not have the associated responsibilities under the GDPR.
Cmmndr Reporting should be considered only as a processor on behalf of its Users with regards to any User’s Client Data containing Personal Data that is subject to the requirements of the GDPR.
Except as provided in this Privacy Policy, Cmmndr Reporting does not independently cause User’s Client Data containing Personal Data stored in connection with the Services to be transferred or otherwise made available to third parties.
The User is the data controller under the Regulation for any User’s Client Data containing Personal Data, meaning that such party controls the manner such Personal Data is collected and used as well as the determination of the purposes and means of the processing of such Personal Data.
Cmmndr Reporting is not responsible for the content of the Personal Data contained in the User’s Client Data or other information stored on its servers (or its subcontractors’ servers) at the discretion of the User, nor is Cmmndr Reporting responsible for the manner in which the User collects, handles disclosure, distributes, or otherwise processes such information.
10. Changes and updates to this Policy
Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.
About us
The data operator is Kondiment Worldwide S.R.L. (hereinafter ‘Kondiment’), a company headquartered in Bucharest, Str. General Gheorghe Manu, no. 7, District 1, registered with the Trade Registry (ORC), under no. J40 / 2418 / 27.02.2014, having fiscal code (RO) 32853995. If you have any questions about this Privacy Policy or Cmmndr Reporting Service practices, or if you are seeking to exercise any of your statutory rights. You may contact us at [email protected] or at our mailing address.