1. Introduction

DIGITALINBRO (“we”, “us”, or “our”) provides a marketing, social media and analytic platform through a Software as a Service (SaaS) model. At DIGITALINBRO the privacy and security of our customers, third parties and visitors are of paramount importance. This Privacy Policy (“Policy”) explains how DIGITALINBRO processes information that can be used to directly or indirectly identify the data subject through the use of its website and platform.

We at DIGITALINBRO collect e-mail addresses and some personal information about clients who communicate with us via email or register with us to open an account (“Clients”). This Privacy Policy describes how we collect, process, use and share collected data and other useful information from our Clients and their Customers (“Customers’) when they use the Website www.digitalinbro.com (“Website”) and our Subscription Service (“Subscription Service”). It also describes Client’s, and Customer’s choices regarding use, access and correction of their personal data. The use of information collected through our service shall be limited to the purpose of providing the service for which the client has engaged.

If you do not agree with the data practices described in this Policy, you should not use the Website or the Subscription Service.

For the purposes of this Policy, DIGITALINBRO wants to introduce new GDPR key definitions:

Personal Data: any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

Processing: any operation or set of operations performed upon Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Controller: the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of Personal Data; where the purposes and means of processing are determined by EU or Member State laws, the Controller (or the criteria for nominating the Controller) may be designated by those laws.

Processor: a natural or legal person, public authority, agency or any other body, which processes Personal Data on behalf of the Controller.

Any information stored on DIGITALINBRO’s platform is treated as confidential. All information is stored securely and accessed by authorized personnel only. DIGITALINBRO implements and maintains appropriate technical, security and organizational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.

Identification of the controller and data processor

Current European Data Protection Law distinguishes between the Controller and the Processor of the information. In general, the Client is the Controller of the Customer Data. As a general rule, DIGITALINBRO is the Client’s Processor which processes Customer’s Personal Data on behalf of the Client.

 

2. Information we Collect and Receive

DIGITALINBRO may collect and receive Client or Customer Data in several ways:

Visitors’ Data: Customers and individuals to whom a Client grants access to a Website embedded with our Marketing Software routinely send Customer Data to DIGITALINBRO when using the Services.

Customers’ Data: Customer who may decide to sign for Client services or newsletter or products provides DIGITALINBRO with an email address, a phone number, a password, a domain and/or any other details of similar accounts. Furthermore, Clients who purchase our Services will provide us with billing information, home or working address as well as credit card and banking information.

In such cases, DIGITALINBRO servers collect information automatically when Customers access or use the Website or Services and collect them in log file format. Information may include the Internet Protocol (IP) address, the address of the web page Customers has visited before using the Website or Services, the type of browser and its configuration, the date and time they used the Services, information about browser settings and plugins, as well as language preferences and cookie information.

How We Use Personal Information

We use the personal information we collect to, among other things, anticipate and resolve problems with the Site, personalize your service, investigate misuse of Site and develop and market products and services that may be of interest to you.

DIGITALINBRO collects information about the devices that access the Services, including the type of device, operating system used, device configuration, application IDs, unique device identifiers, and failure data. Whether or not all or part of this information is collected often depends on the type of device used and its configuration.

DIGITALINBRO receives information that helps us estimate Customer’s location. We can use an IP address received through the Customer’s browser or device to determine their approximate location. DIGITALINBRO may also collect information on the location of devices according to the consent process provided by the Customer’s device.

Cookies are small text files that we send to Customer’s computer or mobile device. They are unique to their account or their browser. DIGITALINBRO uses sessions cookies to improve the overall experience of the user by memorizing their login credentials or tracking the pages throughout the duration of time the user spends on the website. DIGITALINBRO and our partners use cookies and similar technologies on our Websites and Services that help us collect information, to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our use base as a whole. You can control the use of cookies at the individual browser level, but if ou choose to disable cookies, it may limit your use of certain features or functions on our website. The Websites and Services may also include cookies and similar tracking technologies from Third Parties, which may collect other information about Customers through the Websites and Services, as well as through other websites and online services.

DIGITALINBRO contracts with Third Parties (companies and people) to provide services to our Clients and their Customers and may need to share information with them to provide information, products or services to them. In general, Third Party Services are software that integrates with our Services and they may share information with DIGITALINBRO. For example, if a cloud storage application has been activated to import files into a Landing Page, DIGITALINBRO may receive the username and email address of the user.

Third Party may also receive information from organizations, industries, website visitors, marketing campaigns, affiliates, and subsidiaries. DIGITALINBRO may combine data collected with the previous information and collect new information about the relationship between IP addresses and postal codes or countries.

3. Sharing and Using Personal Information

Sharing Personal Information

Personal Data is not shared with or sold to other organizations for commercial purposes, except to provide products or services Clients or Customers have requested. However, under the following circumstances, it might be possible to share Personal Data:

  • In order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Terms of Service, or as otherwise required by law.
  • To comply with applicable legislation. If we receive a request for information, we may disclose Information if we believe it is reasonable to disclose this information in accordance with the requirements of applicable legislation, regulations and legal procedures.
  • During a change in DIGITALINBRO activity. DIGITALINBRO may participate in a merger, acquisition, bankruptcy, dissolution, reorganization, financing, a public offering of securities, acquisition of all or part of our company. Then, in measures that contemplate such activities (for example, due diligence), some or all of Personal Data may be shared or transferred, in accordance with standard confidentiality agreements.

Using Personal Information

  • The Website is not intended for or targeted at children under 13 and we do not knowingly or intentionally collect information about children under 13. If you believe that we have collected information about a child under 13, please contact us at support@digitalinbro.com, so that we may delete the information.
  • Client’s and Customer’s testimonials on our Website are pre-approved by them as they might contain personal information. We obtain each Client’s or Customer’s consent via email prior to posting their names and testimonials.
  • DIGITALINBRO Clients use the Subscription Service to build webpages that their Customers can visit to learn more about their business. DIGITALINBRO does not control the content of these webpages or the information that is gathered and managed by its Customers. That information belongs to them and is used, disclosed and protected by them according to their own privacy policies which are independent of DIGITALINBRO’s Policy.
  • DIGITALINBRO acknowledges the right of its Clients’ and their Customers to access their Personal Data stored on its platform, which can be amended, deleted or updated at any time.

Additional Limits on Use of Your Google User Data

Additional Limits on Use of Your Google User Data: Notwithstanding anything else in this Privacy Policy, if you provide the App access to the following types of your Google data, the App’s use of that data will be subject to these additional restrictions:

  • The App will only use access to read, write, modify or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows users to compose, send, read,and process emails and will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
  • The App will not use this Gmail data for serving advertisements.
  • The App will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for the App’s internal operations and even then only when the data have been aggregated and anonymized.

 

Referrals

If you choose to use our referral service to tell a friend about our website, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the website. DIGITALINBRO [stores] this information for the sole purpose of sending this one-time email [and tracking the success of our referral program]. Your friend may contact us at support@digitalinbro.com to request that we remove this information from our database.

4. Data Transfer and Transfer Mechanisms

DIGITALINBRO is committed to provide the highest degree of security to data processing. For these reasons, in the context of data transferring with countries outside EEA, it is paramount that controller and processors undertake adequate organizational and technical measures for data processing. DIGITALINBRO uses the following transferring instrument:

  • Standard Contractual Clause (“SCCs”): Set of data protection clauses adopted by the Commission

These are known as the ‘standard contractual clauses’ (sometimes as ‘model clauses’). There are four sets that Commission adopted under the Directive. They must be implemented by the data exporter (based in the EEA) and the data importer (outside the EEA).

The clauses contain contractual obligations on the data exporter and the data importer, and rights for the individuals whose personal data is transferred. Individuals can directly enforce those rights against the data importer and the data exporter. Within this context, DIGITALINBRO acts as data importer. Specifically, data importer means:

“the processor who agrees to receive from the data exporter personal data intended for processing on his behalf after the transfer in accordance with his instructions and the terms of the Clauses and who is not subject to a third country’s system ensuring adequate protection within the meaning of Article 25(1) of Directive 95/46/EC

In the context of SCCs, DIGITALINBRO is committed to

  • Ensure personal data should be collected only for specified, explicit and legitimate purposes; 
  • Recognizing data access to any concerned data subject while providing the opportunity to change or delete data;
  • Providing data subjects with adequate and appropriate remedies including compensation or damages through the competent court.

SCC’s provide adequate security in relation to data transfer establishing a legal framework towards:

  • Obligation of data exporter;
  • Obligations of data importer;
  • Third-party beneficiary clause;
  • Cooperation with Data Protection Authority;
  • Liability

When operating as data importer, DIGITALINBRO is free to include any other clauses on business related issues which they consider as being pertinent for the contract as long as they do not contradict the standard contractual clauses.

For further information about how DIGITALINBRO is implementing SCCs please check the Data Protection Agreement.

5. Sub-processors

Sub-processor(s): a natural or legal person, public authority, agency or any other body hired by DIGITALINBRO to process Personal Data on behalf of the Controller.

Client agrees that DIGITALINBRO may engage Sub-processors to process Personal Data on its behalf.

DIGITALINBRO will notify the Client if it adds or removes Sub-processors 10 days prior to any such changes.

Where DIGITALINBRO enters into an agreement with Sub-processors, DIGITALINBRO will ensure that equivalent data-protection terms are transferred to the Sub-processors which provides at least the same level of protection for the Client and its Customers’ Personal Data as those set-out in this Privacy Policy, to the extent applicable to the nature of the services provided by such Sub-processors.

DIGITALINBRO will remain responsible for each Sub-processor’s compliance with the obligations under this Privacy Policy and for any acts or omissions of such Sub-processor that causes DIGITALINBRO to breach any of its obligations under this Privacy Policy.

Entity Name Purpose Applicable Services Entity Country
Intercom Inc. DIGITALINBRO Live Chat Agent runs over Intercom, Inc (“Intercom”). Intercom has access to DIGITALINBRO Client’s basic information which are: Name, email, phone, company, Ip address, website visits and user agent. Intercom also processes communications contained in the messages and the ticket requests between DIGITALINBRO users and DIGITALINBRO’s support team. DIGITALINBRO Support United States
Cloudflare, Inc. Cloudflare, Inc. (“Cloudflare”) provides content distribution, security and DNS services for web traffic transmitted to and from the Services. This allows DIGITALINBRO to efficiently manage traffic and secure the Services. The primary information Cloudflare has access to is information in and associated with the DIGITALINBRO website URL that the End-User is interacting with (which includes End-User IP address). All information (including Service Data) contained in web traffic transmitted to and from the Services is transmitted through Cloudflare’s systems, but Cloudflare does not have access to this information. All United States
Woopra Woopra, Inc. (“Woopra”) is a third-party analytics provider that DIGITALINBRO uses to capture how users interact with the Service. DIGITALINBRO uses this information to analyze and improve the Services. The primary information Woopra has access to is information in and associated with the DIGITALINBRO website URL that the Client and End-User is interacting with, such as time spent on page, items clicked (including Service Data contained in those items), Client email addresses, End-User email addresses, etc. All United States
Pipedrive Pipedrive is a cloud-based sales software company accessible as a web application and mobile app. It is considered a customer relationship management tool (CRM) for salespeople in scaling companies. Main User Accounts United States
Zapier Zapier is an American for-profit corporation and a web-based service that allows end users to integrate the web applications they use. All United States
duitku.com Main User Accounts Indonesia

 

6. Changes

DIGITALINBRO may modify this Policy at any time. Legislation, regulations and industry standards evolve, so these changes may be necessary; or maybe they could be due to changes in our activity. We will post the changes on this page and encourage you to review our Policy to stay informed. Should we implement changes that substantially alter your privacy rights, DIGITALINBRO will provide additional notice. If you do not agree with the changes in this Policy, you will be unable to properly use DIGITALINBRO Services and Website.

7. Security

DIGITALINBRO takes the security of its Clients and Customers’ data very seriously. DIGITALINBRO strives to protect the other information that they provide us with loss and misuse, as well as against unauthorized disclosure or access. These measures take into account the sensitivity of information we collect, process and store, as well as the state of current technology. DIGITALINBRO uses industry leading 256-bit SSL encryption to keep any information collected and/or transmitted to our Website or Third-Party apps secure. Furthermore, Personal Data we collect are anonymized or at least pseudonymized.

8. Data Retention

DIGITALINBRO will keep the Client Data in accordance with the Client’s instructions, including any terms applicable in the Agreement with the Customer and in the use of the functionality of the Services by the Client, as well as in accordance with the provisions of the applicable legislation.

We will retain any Personal Data and data we collect in behalf of our clients for as long as the account is active and for a period of time consistent with the original purpose of collection, including to pursue our legitimate business interests, comply with our legal obligations, resolve disputes and enforce applicable agreements.

The Controller has the duty of limiting the period for which Personal Data is stored. The Controller will periodically review and evaluate that time period in order to respect data privacy expectations.

9. Payment Information

When you make a purchase on the Offerings, any credit card information you provide as part of your Payment Information is collected and processed directly by our payment processor duitku.com. We never receive or store your full credit card information. 

10. Account Removal

If you want to remove your account from our database, please fill out this form.

You need to provide a valid ID in order for this to be processed.

11. Report System Abuse

DIGITALINBRO serves thousands of businesses and digital agencies. While we work hard on vetting each business that uses our platform, abuse can be inevitable.

To report system abuse, please follow the following instructions:

  1. To report email send abuse, please forward the email, along with the email header to abuse@digitalinbro.com.
  2. To report landing page abuse, please email abuse@digitalinbro.com with the direct page link.
  3. To report other messaging abuse, please send a snapshot of the message and the hyperlink used
  4. To report page compromises or other security issues, please email abuse@digitalinbro.com with the page link.

12. Questions

Any questions, concerns, or complaints regarding this Privacy Notice or the way we collect and handle your information as a Processor, please contact our Data Protection Officer (DPO) by email at support@digitalinbro.com.

DIGITALINBRO will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner.

 

Physical Address: Ruko Pasar Laris H5 Kalideres Cengkareng Jakarta Barat

Contact Number +6221 29543737

Email : support@digitalinbro.com