Privacy Policy
Last Updated: 23rd January, 2023Portfoliobee’s intention behind publishing this Privacy Policy is to ensure that we are compliant to the privacy and data security requirements. Herein, Portfoliobee would like to provide detailed information regarding the data we collect, process and the controls we have implemented to safeguard the information provided to us by users.
Respecting your time and with the goal of providing you with the quickest possible access to the relevant passages of the privacy statement, we offer you the following summary. The summary does not replace or supersede the detailed explanations in the Portfoliobee Privacy Statement so in case of doubt, please always refer to the relevant passage in the actual full statement below:
Summary
The privacy statement aims to explain what personal data is processed by Portfoliobee, who uses your personal data, for what purpose, for how long, and explains what rights you have in this context.
Definitions
For the purposes of this Cookies Policy:
- Company (referred to as either "the Company '', "We", "Us" or "Our" in this Privacy Policy) refers to Portfoliobee Software Private Limited.
- Website refers to Portfoliobee.org
- You mean the individual accessing or using the Website, or a company, or any legal entity on behalf of which such individual is accessing or using the Website, as applicable.
Who collects and processes your personal data?
Portfoliobee does, in the form of the respective legal entity Portfoliobee Software Private Limited, India. The Portfoliobee Privacy Statement describes in detail which processing activities of which Portfoliobee entity apply.
What personal data does Portfoliobee collect?
Portfoliobee may collect various types of personal data about you when conducting its business, including:
- Personal contact data,
- Personal data Portfoliobee must collect due to legal- and compliance-related purposes
- Personal usage, registration, and participation data which Portfoliobee may generate through your use of its web and online offerings,with the intention of enhancement of user experience.
- Application-related personal data,
For what purposes does Portfoliobee collect personal data?
Portfoliobee processes your personal data to:
pursue its business relationships with you, including ensuring your satisfaction with and keeping you up to date on the latest news about our products and services, develop and offer you its software products, cloud and other services, protect the quality and safety of its premises, facilities, products or services, secure and, if necessary, defend its protected legal assets against unlawful attacks, assert our rights or defend Portfoliobee against legal claims, ensure compliance with statutory laws and regulations applicable to Portfoliobee, operate Portfoliobee’s Internet pages, web offerings, or other online events including analyzing the behavior of the users, enabling you to create a user profile, benefit from an identity service and to promote and continuously improve your user experience, search you as a potential talent for Portfoliobee, Portfoliobee partners and others.
If you want to learn more about each of these purposes for which Portfoliobee may collect, transfer, and use your personal data, including for how long your data is being retained and specific to the General Data Protection Regulation (GDPR), the legal ground on which Portfoliobee is pursuing them, please refer to the full privacy statement below.
What are your data protection rights?
You have the right to request from Portfoliobee access to, correction of, and/or the return or the deletion of your personal data. You may request from Portfoliobee to restrict the access to your personal data or to exclude it from further processing. You may revoke a once given consent or object to processing activities which Portfoliobee may intend to pursue in a given case. When you believe that Portfoliobee was processing your personal data not in accordance with this privacy statement or under breach of applicable data protection laws, you have the right to lodge a complaint with a relevant supervisory authority. The Portfoliobee Privacy Statement describes each of these rights in detail, including how you can reach us to exercise any of these rights against Portfoliobee and how to identify, if necessary, the relevant data protection authority.
For what purposes does Portfoliobee process your personal data?
When conducting business and operating our various web presences and other communication channels, Portfoliobee processes personal data of the people it interacts with, including customers, partners, suppliers, vendors, candidates, and any other people with whom we interact.
In any of these cases, Portfoliobee may process personal data for one or more of the following business purposes:
To pursue business relationships with customers, partners, and others
Portfoliobee processes personal data to pursue its business relationships with customers, partners, and other users to fulfill pre-contractual and contractual business relations. This may include satisfying requests, processing orders, delivering an ordered product or service, or engaging in any other relevant action to establish, fulfill and maintain our business relationships.
Products and services may include any of Portfoliobee’s cloud software products, web services, apps, online-forums, webinars and events, non-marketing related newsletters, white papers, tutorials, trainings, as well as other offerings like contests, quizes or sweepstakes. When you purchase or intend to purchase products or services from Portfoliobee, Portfoliobee will use your personal data for this purpose. More specifically, Portfoliobee may use your personal data to confirm your opening of an account, manage the contract execution, send you disclosures as may be required by law, notice of payments, and other information about our products and services. Portfoliobee may respond to related inquiries, provide you with necessary support and process your feedback.
In the context of your use of our products or services, Portfoliobee may communicate with you by post, email, live chat, contact forms, phone or any other medium to resolve your, a user’s, or a customer’s question or complaint or to investigate suspicious transactions. In case of telephone calls or chat sessions, Portfoliobee may record such calls or chat sessions to improve the quality of Portfoliobee’s services after informing you accordingly during that call and, subject to applicable law, receiving your prior consent before the recording begins.
Customer Satisfaction - Within an existing business relationship between you and Portfoliobee, Portfoliobee processes your personal data to help us understand how satisfied you are with the functionality and quality of our products and services, to provide you with relevant information on our latest product announcements, software updates or upgrades, events, special offers, and other information about Portfoliobee’s software and services that is relevant and useful to you.
To develop products and services
To the extent permitted by applicable law, Portfoliobee may process your personal data for internal research, technological demonstration and development, and to help Portfoliobee create, develop, operate, deliver, improve, upgrade or enhance Portfoliobee products and services. Portfoliobee may process personal data to create anonymized datasets which may then be used to improve Portfoliobee’s products and services.
To ensure compliance with laws and regulations
Portfoliobee processes personal data to comply with statutory obligations. Portfoliobee processes your personal data for the purpose of ensuring an adequate level of technical and organizational security of Portfoliobee's products, services, online events, facilities, and premises. For this, Portfoliobee will take the measures necessary to verify or maintain the quality and safety of a product or service which is owned, manufactured by or for, or controlled by Portfoliobee. This may comprise the use of personal data for sufficient identification and authorization of designated users, internal quality control through auditing, analysis, and research, debugging to identify and repair errors that impair existing or intended functionality, account and network security, replication for loss prevention, detecting security incidents, protection against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for such kind of activity.
If necessary, Portfoliobee uses personal data to prevent criminal activities such as any form of cybercrime, the illegal use of our products and services or fraud, to assert our rights or defend Portfoliobee against legal claims.
To comply with data protection and unfair competition law related requirements. Depending on the country in which the relevant Portfoliobee operates, and whether you have expressly consented to or opted out of receiving commercial information, Portfoliobee may process personal data necessary to accommodate your data protection and privacy choices for the receipt of such information and, when necessary to ensure compliance.
To operate Portfoliobee internet pages, web-offerings, or other online events
Portfoliobee processes personal data for the purpose of operating, providing to you and administering your use of Portfoliobee’s internet pages, web offerings, or other online events.
Creating user profiles
Certain web offerings linked to Portfoliobee’s websites, including forums, blogs, and networks, require you to register and create a user profile. Through the user profile you can share personal information about you with other users, such as your name, photo, social media accounts, postal or email address, telephone number, personal interests, skills, and basic information about your company. The user profiles serve to personalize the interactions between the users and to allow Portfoliobee to foster the collaboration and quality of communication through such offerings. The profile settings of the relevant web offering allow you to determine which information you want to share.
Identity service
The user profile may be specific to a single web offering of Portfoliobee, but it also allows you to access other web offerings of Portfoliobee. It is your choice whether or not to use any of these additional web offerings. If you do, Portfoliobee will make your personal data available to such other web offerings to provide you with initial access. Kindly note that without your consent for Portfoliobee to create such user profiles, Portfoliobee will not be able to offer such services to you where your consent is a statutory requirement that Portfoliobee can provide these services to you.
Event profiling
If you register for an event, seminar, or webinar of Portfoliobee, Portfoliobee may share basic participant information (your name, company, and email address) with other participants of the same event, seminar, or webinar to promote the interaction between the participants and to stimulate the communication and the exchange of ideas.
User experience improvement
Portfoliobee processes information that relates to your visit to our web offerings to improve your user experience, identify your individual demand and to personalize the way we provide you with the information you are looking for. For this purpose, we collect information regardless of whether you register with a user profile or not.
Cookies and similar tools
Portfoliobee processes personal data about the users of Portfoliobee websites and other web offerings using cookies or similar technologies for the purposes set out in Portfoliobee’s Cookie Statement.
To search for talent
Portfoliobee is collecting and processing personal data of qualified individuals and people interested in our career opportunities from various sources. Job applicants and candidates are asked to apply via the Portfoliobee Career Portal, regardless of whether this is done initiatively or in response to an advertised posting. Portfoliobee collects personal data by means of the Career Portal for the purposes of carrying out the application procedures and selecting applicants.
To offer Portfoliobee products and services
Portfoliobee collects and processes personal data for sales and marketing purposes. We aim to keep you updated on upcoming events and Portfoliobee’s latest products and services. If possible, we may contact you to discuss further your interest in Portfoliobee services and offerings.
Request feedback, questionnaires and surveys
To the extent allowed by applicable law, Portfoliobee may contact you for feedback regarding the improvement of the relevant material, product, or service. Portfoliobee may also invite you to participate in questionnaires and surveys. These will generally be designed so you can participate without having to provide information that identifies you as a participant. If you nonetheless provide your personal data, Portfoliobee will use it for the purpose stated in the questionnaire or survey or to improve its products and services.
To keep you up to date
Within an existing business relationship between you and Portfoliobee, Portfoliobee processes your personal data to inform you about Portfoliobee products or services which are similar or related to products and services you have already purchased or used. Portfoliobee will inform you by email or phone about such news only as far as it is allowed by law, or if Portfoliobee has collected such information in the context of the business relationship. You are entitled to object to Portfoliobee’s use for this purpose at any time by selecting the opt-out option at the bottom of each marketing related approach.
Personalized Content
Portfoliobee processes information about your interactions with Portfoliobee across its business areas and its offerings (your prior and current use of Portfoliobee products or services, your participation in and use of Portfoliobee’s web offerings, events, white papers, free trials or newsletters) to provide you with the requested products and services and to improve our personal communications with you. This data may also be used to efficiently operate Portfoliobee’s business, which also includes: the automation and aggregation of data to support various analytic and statistical efforts, performance and predictive analytics and exploratory data science to support your customer journey and to fulfill such requests. To the extent permitted by law, Portfoliobee may combine and use such information in an aggregated manner to help us understand your interests and business demands, develop our business insight and marketing strategies, and to create, develop, deliver, and improve our personalized communications with you.
What personal data does Portfoliobee process?
Portfoliobee processes various types of personal data about the people we interact with when conducting our business. Depending on the individual case, this may comprise the following types of personal data:
Contact Data
Portfoliobee processes the following categories of personal data as contact data: first name, last name, email addresses, address/location (country,state/province,city), telephone numbers, and your relationship history with Portfoliobee.
Personal data related to the business relationship with Portfoliobee
If you provide a Credit/Debit card number or bank details to order products or services, Portfoliobee will collect this information to process your payment for the requested products or services. But this information will never be saved by Portfoliobee as per RBI guidelines.
Compliance related personal data
If required by statutory law or regulation, Portfoliobee may process data categories like date of birth, academic credentials, identity cards or other ID numbers, geolocation.
Data generated through your use of, or participation in, Portfoliobee's internet pages, web, or online offerings
Usage data
Portfoliobee processes certain user-related information, e.g., info regarding your browser, operating system, or your IP address when you visit Portfoliobee’s web properties. We also process information regarding your use of our web-offerings, like the pages you visit, the amount of time you spend on a page, the page which has referred you to our page and the links on our sites you select.
Registration data
Portfoliobee may process your contact data as set out above and other information which you may provide directly to Portfoliobee if you register for any of Portfoliobee's events or other web services.
Participation data
When you participate in webinars, virtual seminars, events, or other Portfoliobee web services, Portfoliobee may process your interactions with the relevant web service to organize the event including its sessions, polls, surveys, or other interactions between Portfoliobee and/or its participants. Depending on the event and subject to a respective notification of the participants, Portfoliobee may collect audio and video recordings of the event or session.
Personal data received by third-parties, including publicly available sources
Portfoliobee generally aims to collect personal data directly from the data subjects. If you or applicable law allows Portfoliobee to do so, Portfoliobee may obtain personal data also from third party sources. These third-party sources may include:
- Third parties you directed to share your personal data with Portfoliobee.
- Third party sources and publicly available sources like business oriented social networks, institutions and organizations.
When we collect personal data from third party sources, established internal controls aim to ensure that the third-party source was permitted to provide this information to Portfoliobee and that we may use it for this purpose. Portfoliobee will treat this personal data according to this privacy statement, plus any additional restrictions imposed by the third party that provided the personal data to Portfoliobee or by applicable national law.
Personal data necessary for customer satisfaction
To the extent permitted by law or based on your consent, Portfoliobee may combine the information we collect either directly or indirectly about specific users to ensure the completeness and correctness of the data and to help us better tailor our interactions with you and determine the information which best serves your respective interest or demand.
How long does Portfoliobee process my personal data?
Portfoliobee processes your personal data only for as long as it is required:
- To make products and services requested by you.
- For Portfoliobee to comply with statutory obligations to retain personal data, resulting inter alia e.g. from applicable export, finance, tax or commercial laws.
- To fulfill Portfoliobee’s legitimate business purposes as further described in this privacy statement, unless you object to Portfoliobee’s use of your personal data for these purposes;
- until you revoke a consent you previously granted to Portfoliobee to process your personal data.
- To learn more about how you may revoke consent, please see guidance below in the section titled, “What are your data protection rights".
- Portfoliobee may process your personal data for product or service development until this is no longer necessary or Portfoliobee is informed that your relationship with the Portfoliobee customer has changed.
Who are the recipients of your personal data?
Your personal data may be passed on to the following categories of third-parties:
Right to access, correct and delete
You can request from Portfoliobee at any time access to information about which personal data Portfoliobee processes about you and, if necessary, the correction or deletion of such personal data. Please note, however, that Portfoliobee can or will delete your personal data only if there is no statutory obligation or prevailing right of Portfoliobee to retain it. If you request from Portfoliobee to delete your personal data, you may not be able to continue to use any Portfoliobee service that requires Portfoliobee’s use of your personal data.
Right to receive personal data back from Portfoliobee
If Portfoliobee uses your personal data based on your consent or to perform a contract with you, you can further request from Portfoliobee a copy of the personal data you provided to Portfoliobee. In this case, please contact dataprotectionofficer@Portfoliobee.org and specify the information or processing activities to which your request relates. Portfoliobee will carefully consider your request and discuss with you how it can best be fulfilled.
Right to restrict
You can request from Portfoliobee to restrict your personal data from further processing in any of the following events:
- You state the personal data about you is incorrect, subject to the time Portfoliobee requires to check the accuracy of the relevant personal data,
- There is no legal basis for Portfoliobee to process your personal data and you demand Portfoliobee to restrict your personal data from further processing,
- Portfoliobee no longer requires your personal data, but you state you require Portfoliobee to retain such data to claim or exercise legal rights or to defend against third party claims, or
- In case you object to the processing of your personal data by Portfoliobee based on Portfoliobee’s legitimate interest (as further set out below), subject to the time required for Portfoliobee to determine whether it has a prevailing interest or legal obligation in processing your personal data.
Right to object
If and to the extent Portfoliobee is processing your personal data based on Portfoliobee's Legitimate Interest, specifically where Portfoliobee pursues its legitimate interest to engage in direct marketing or to apply profiling in relation to direct marketing, you have the right to object to such a use of your personal data at any time. When you object to Portfoliobee's processing of your personal data for direct marketing purposes, Portfoliobee will immediately cease to process your personal data for such purposes. In all other cases, Portfoliobee will carefully review your objection and cease further use of the relevant information, subject to Portfoliobee’s compelling legitimate grounds for continued use of the information, which may override your interest in objecting, or if Portfoliobee requires the information for the establishment, exercise, or defense of legal claims.
Right to revoke consent
Wherever Portfoliobee is processing your personal data based on your consent, you may at any time withdraw your consent by unsubscribing or giving us respective notice of withdrawal (dataprotectionofficer@Portfoliobee.org). In case of withdrawal, Portfoliobee will not process personal data subject to this consent any longer unless legally required to do so. In case Portfoliobee is required to retain your personal data for legal reasons your personal data will be restricted from further processing and only retained for the term required by law. However, any withdrawal has no effect on past processing of personal data by Portfoliobee up to the point in time of your withdrawal. Furthermore, if your use of an Portfoliobee offering requires your prior consent, Portfoliobee will no longer be able to provide the relevant service (or services, if you revoke the consent for Portfoliobee to use your profile under the Portfoliobee Identity Authentication Service for multiple Portfoliobee offerings), offer or event to you after your revocation.
Right to lodge a complaint
If you take the view that Portfoliobee is not processing your personal data in accordance with the requirements in this privacy statement or under applicable data protection laws, you can at any time, to the extent required by applicable law, lodge a complaint with your locally relevant data protection authority, specifically when you are located in an EEA country, or with the data protection authority of the country or state where Portfoliobee has its registered seat.
How can you exercise your data protection rights?
Please direct any requests to exercise your rights to dataprotectionofficer@Portfoliobee.org.
How will Portfoliobee verify requests to exercise data protection rights?
Portfoliobee will take steps to ensure it verifies your identity to a reasonable degree of certainty before it will process the data protection right you want to exercise. When feasible, Portfoliobee will match personal data provided by you in submitting a request to exercise your rights with information already maintained by Portfoliobee. This could include matching two or more data points you provide when you submit a request with two or more data points that are already maintained by Portfoliobee.
Portfoliobee will decline to process requests that are manifestly unfounded, excessive, fraudulent, represented by third parties without duly representing respective authority or are otherwise not required by local law.
Email should come from the registered email ID.
Can I use Portfoliobee’s products and services if I am a minor or child?
Persons under the age of 13 and persons who do not have full legal capacity are not permitted to use the Website. Portfoliobee asks them not to provide their personal data.
Our Service does not address anyone under the age of 13.We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.
Additional Country and Regional Specific Provisions
Where Portfoliobee is subject to privacy requirements in the EU, EEA, or other GDPR relevant countries
Who is the Data Protection Officer of the Controller?
You can reach Portfoliobee’s data protection officer any time at dataprotectionofficer@Portfoliobee.org.
What are the legal permissions for Portfoliobee to process personal data?
Portfoliobee is processing your personal data for the business purposes set out above based on the following legal permissions:
General remark regarding Portfoliobee’s processing of personal data based on your prior consent
Portfoliobee may process your personal data for the specific processing purposes based on your prior consent.
General remark regarding Portfoliobee’s processing of personal data based on legitimate business interest
Where we refer to GDPR Article 6.1 (f) and consequently Portfoliobee’s legitimate business interest as our legal permission to process your personal data, Portfoliobee is pursuing its legitimate business interests
- to efficiently manage and perform its business operations,
- to maintain and operate intelligent and sustainable business processes in a group structure optimized for the division of labor and in the best interest of our employees, customers, partners, and shareholders
- to operate sustainable business relationships with Portfoliobee customers and partners including you
- serve you with the best possible user experience when using Portfoliobee's web services, products/services
- comply with extraterritorial laws and regulations, or
- assert or defend itself against legal claims.
We believe that our interest in pursuing these business purposes is legitimate and thereby not outweighed by your personal rights and interest to refrain from processing. In any of these cases, we duly factor into our balancing test:
the business purpose reasonably pursued by Portfoliobee in the given case,
the categories, amount and sensitivity of personal data that is necessarily being processed,
the level of protection of your personal data which is ensured by means of our general data protection policies, guidelines, and processes, and the rights you have in relation to the processing activity.
Pursue business relationships with customers, partners, and others
When pursuing business relationships with customers, partners and others, Portfoliobee may be processing personal data based on:
- GDPR Article 6.1 (b) if necessary, to fulfill (pre-)contractual obligations with you,
- GDPR Article 6.1 (c) if necessary, to fulfill legal requirements applicable to Portfoliobee,
- GDPR Article 6.1 (f) if necessary, to maintain our business relationships with you, ensure your satisfaction as a user or customer representative, and provide you with information about other Portfoliobee products and services as indicated by your interest or demand (legitimate interest to operate sustainable business relationship with Portfoliobee customers and partners), or
- a legal permission under other national laws equivalent to any of the above, when applicable.
Ensure compliance with laws and regulation
- When ensuring compliance with applicable laws and regulations, Portfoliobee may process your Personal data based on
- GDPR Article 6.1 (c) if necessary, to fulfill legal requirements under European Union or EU Member State law to which Portfoliobee is subject,
- GDPR Article 6.1 (f) if necessary, to fulfill laws and regulations extraterritorial to the EU (legitimate interest to comply with extraterritorial laws and regulations),
- or the equivalent articles under other national laws, when applicable.
Operate Portfoliobee internet pages, web offering, or other online events
When operating its internet pages, web-offerings or other online events ("web-services") and depending on the respective operating purpose, Portfoliobee is processing your personal data on the basis of the following legal permissions:
GDPR Article 6.1 (b) and (f) to provide the web services and functions, create and administer your online account, updating, securing, troubleshooting the service, providing support, improving, and developing the web service, answering and fulfilling your requests or instructions, (legitimate interest to efficiently perform or manage Portfoliobees business operation)
GDPR Article 6.1 (c) and (f) to manage and ensure the security of our web services and prevent and detect security threats, fraud or other criminal or malicious activities and as reasonably necessary to enforce the web services terms, to establish or preserve a legal claim or defense, to prevent fraud or other illegal activities, including attacks on our information technology systems (legitimate interest to efficiently perform or manage Portfoliobee’s business operation and assert or defend itself against legal claims)
GDPR Article 6.1 (a) if it is necessary that we ask you for your consent to process your personal data
or equivalent legal permissions under other relevant national laws, when applicable. Cookies and similar tools
When tracking and evaluating the usage behavior of users of our web services by means of cookies or similar technologies, Portfoliobee is processing your personal data on the basis of the following legal permissions:
Collection of data from third-parties, including publicly available sources
When collecting personal data about you from third-parties, the legal basis for the collection by Portfoliobee may be based on: