Privacy Policy

BACKGROUND:

EDMdesigner.com Ltd, the legal owner of Chamaileon.io, understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, Chamaileon.io (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site and/or you will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

“Account”
means an account required to access and/or use certain areas and features of Our Site;

“Cookie”
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 14, below;

“Cookie Law”
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

“personal data”
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and

“We/Us/Our”
means EDMdesigner.com Ltd., a limited company registered in Hungary under company number 09 09 026449, whose registered address is Ground Floor 41, 4–6 Simonffy Street, Debrecen, 4025, Hungary, and whose main trading address is Ground Floor 41, 4–6 Simonffy Street, Debrecen, 4025, Hungary.

2. Information About Us

  1. Our Site is owned and operated by EDMdesigner.com Ltd., a limited company registered in Hungary under company number 09 09 026449, whose registered address is Ground Floor 41, 4–6 Simonffy Street, Debrecen, 4025, Hungary, and whose main trading address is Ground Floor 41, 4–6 Simonffy Street, Debrecen, 4025, Hungary.
  2. Our VAT number is HU24883483.
  3. Our Data Protection Officer is Roland Pokornyik, and can be contacted by email at roland@edmdesigner.com, by telephone on +36-70-608-4433, or by post at Ground Floor 41, 4–6 Simonffy Street, Debrecen, 4025, Hungary.
  4. We are regulated by Hungarian law.

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites, and We advise you to check the privacy policies of any such websites before providing any data to them.

4. What is Personal Data?

Personal data is defined by the GDPR (EU Regulation 2016/679) as “any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.”

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. Your Rights

As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

  1. The right to be informed about Our collection and use of personal data.
  2. The right of access to the personal data We hold about you (see section 13).
  3. The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 15).
  4. The right to be forgotten – i.e., the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 8, but if you would like Us to delete it sooner, please contact Us using the details in section 15).
  5. The right to restrict processing (i.e., prevent the processing of your personal data).
  6. The right to data portability (obtaining a copy of your personal data to re-use with another service or organization).
  7. The right to object to Us using your personal data for particular purposes.
  8. Rights with respect to automated decision-making and profiling.
  9. The right to withdraw consent at any time if We rely on your consent to process your personal data (withdrawing consent will not affect the lawfulness of processing before the withdrawal).

If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 15 and We will do Our best to resolve the issue for you. If We are unable to help, you also have the right to lodge a complaint with the relevant supervisory authority (for example, the UK’s Information Commissioner’s Office or Hungary’s National Authority for Data Protection and Freedom of Information (NAIH)).

For further information about your rights, please contact the Information Commissioner’s Office or your local data protection authority.

6. What Data Do We Collect?

Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data. We adhere to the principle of data minimization, meaning we only collect personal data that is adequate, relevant, and limited to what is necessary for the purposes described.

  • Name
  • Business/company name and billing information
  • Job title
  • Profession
  • Contact information such as email addresses and telephone numbers
  • Demographic information such as postcode, physical address, preferences, and interests
  • IP address
  • Web browser type and version
  • Operating system
  • A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to
  • Profile picture

7. How Do We Use Your Data?

  1. All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times.

  2. Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), because we must comply with a legal obligation, or because it is in Our legitimate interests (provided that those interests are not overridden by your rights and freedoms). Specifically, We may use your data for the following purposes:

    • Providing and managing your Account
    • Providing and managing your access to Our Site
    • Personalizing and tailoring your experience on Our Site
    • Supplying Our products and services to you
    • Personalizing and tailoring Our products and services for you
    • Communicating with you, including responding to emails or calls from you
    • Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time)
    • Market research
    • Analyzing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience

  3. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone and/or text message with information, news and offers on Our products and services. We will not send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR.

  4. Automated Decision-Making and Profiling

    • Intercom: We may send you emails and in-app messages based on your user activity via the Intercom platform.
    • Automated Profiling: We collect and process information about you and your business in the Intercom support software to tailor your user experience and provide a better service that meets your requirements based on your personal and/or business profile and user activity.
    • Non-EU Residents Only: We periodically record unidentified application usage data (e.g., user session recordings with Smartlook software) to provide a better user experience within the Chamaileon application.

  5. Third-Party Services

    • Third parties (including but not limited to Google, LinkedIn, HubSpot, Intercom, Hotjar, Smartlook, Microsoft Clarity) whose content (tracking code, cookies) appears on Our Site may use third-party Cookies, as detailed in section 14. Please note that We do not control the activities of such third parties, nor the data they collect and use, and we advise you to check the privacy policies of any such third parties.

  6. Your Right to Withdraw Consent

    • You have the right to withdraw your consent to Us using your personal data at any time and to request that We delete it.

  7. Data Retention

    • We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following period (or its retention will be determined on the following bases):
    • Marketing/product update contact information data is in use and stored securely for until you withdraw consent.
    • Identification, communication, billing info for customers is used and stored while the product is in use and is stored for additional 5 years after the last transaction.

8. How and Where Do We Store Your Data?

  1. We only keep your personal data for as long as We need to in order to use it as described above in section 7, and/or for as long as We have your permission to keep it.
  2. Some or all of your data may be stored outside of the European Economic Area (“EEA”). If We do transfer personal data outside the EEA, We will ensure that appropriate safeguards are in place to protect it, in accordance with GDPR regulations.
  3. Data Security Measures
    • We have implemented suitable technical and organizational measures to safeguard and secure personal data collected through Our Site.
    • These measures include encryption of data in transit, secure storage systems, access controls, and regular monitoring of our infrastructure for vulnerabilities.
    • We maintain an Information Security Management System (ISMS) aligned with ISO/IEC 27001.
  4. Data Breach Notification
    • In the unlikely event of a personal data breach, We have procedures in place to notify the appropriate supervisory authority without undue delay (within 72 hours where feasible) and to inform affected individuals when required by law.

9. Do We Share Your Data?

  1. We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, those third parties may require access to some or all of your data. Where any such data is required, We will ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the third party’s legal obligations.
  2. We may compile statistics about the use of Our Site, including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymized and will not include any personally identifying data. We may from time to time share such anonymized data with third parties such as prospective investors, affiliates, partners, and advertisers.
  3. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data—for example, where We are involved in legal proceedings or complying with legal requirements, a court order, or a governmental authority.

10. What Happens If Our Business Changes Hands?

  1. We may, from time to time, expand or reduce Our business. This may involve the sale and/or transfer of control of all or part of Our business. Any personal data that you have provided will, where relevant to any part of Our business that is transferred, be transferred along with that part. The new owner or controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
  2. In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted, you will not be given the option to have your data deleted or withheld from the new owner or controller (the data will necessarily transfer with the business unit).

11. How Can You Control Your Data?

  1. In addition to your rights under the GDPR set out in section 5, when you submit personal data via Our Site you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt out of receiving emails from Us, which you can do by unsubscribing using the links provided in Our emails, and at the point of providing your details or by managing your Account).

12. Your Right to Withhold Information

  1. You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site, you may be required to submit or allow the collection of certain data.
  2. You may restrict Our use of Cookies. For more information, see section 14.

13. How Can You Access Your Data?

You have the right to ask for a copy of any personal data We hold about you (where such data is held). Under the GDPR, no fee is payable, and We will provide any and all information in response to your request free of charge. Please contact Us for more details at roland@edmdesigner.com, or using the contact details below in section 15.

14. Our Use of Cookies

  1. Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data are protected and respected at all times.
  2. By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than Us. Third-party Cookies are used on Our Site for analytics, marketing, and providing you with a more personalized experience.
  3. All Cookies used by and on Our Site are used in accordance with current Cookie Law.
  4. Before Cookies are placed on your computer or device, you will be shown an info bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however, certain features of Our Site may not function fully or as intended without them.
  5. Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary.” Your consent will not be sought to place these strictly necessary Cookies, but it is still important that you are aware of them.
  6. The following first-party Cookies may be placed on your computer or device:
Name of Cookie Purpose Provider
__hssrc Session tracking chamaileon.io
__hstc Visitor tracking chamaileon.io
_clck Microsoft Clarity chamaileon.io
_clsk Microsoft Clarity session recording chamaileon.io
_ga Google Analytics tracking chamaileon.io
_ga_6SG7FBVSSZ Google Analytics session chamaileon.io
_ga_99R15L1T5R Google Analytics session chamaileon.io
_ga_Q11H2C2MQK Google Analytics session chamaileon.io
_ga_WP8S2LM8BD Google Analytics session chamaileon.io
_gcl_au Google Ads conversion tracking chamaileon.io
_gid Google Analytics tracking chamaileon.io
_lfa Leadfeeder tracking chamaileon.io
cookieyes-consent Consent management chamaileon.io
hubspotutk HubSpot tracking chamaileon.io
intercom-device-id Intercom session tracking chamaileon.io
intercom-id Intercom user ID chamaileon.io
intercom-session Intercom session ID chamaileon.io
nQ_cookieId Tracking for lead intelligence chamaileon.io
  1. The following third-party Cookies may be placed on your computer or device:
Name of Cookie Purpose Provider
MUID Microsoft Clarity tracking clarity.ms
IDE Google advertising tracking doubleclick.net
ar_debug Debugging doubleclick.net
  1. Our Site uses analytics services provided by Hotjar, Google, Intercom, and Smartlook. Website analytics refers to a set of tools used to collect and analyze anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, allows Us to improve Our Site and the products and/or services offered through it. You do not have to allow Us to use these analytics Cookies; however, while Our use of them does not pose any risk to your privacy or the safe use of Our Site, it does help Us to continually improve Our Site, making it a better and more useful experience for you.
  2. The analytics service(s) used by Our Site use Cookies to gather the required information.
  3. The analytics service(s) used by Our Site use the following Cookies:
Name of Cookie Purpose Provider
_ga Analytics tracking google.com
_gid Analytics tracking google.com
_gcl_au Ads conversion tracking google.com
  1. In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most browsers accept Cookies, but this setting can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
  2. You can choose to delete Cookies on your computer or device at any time. However, you may lose information that enables you to access Our Site more quickly and efficiently, including (but not limited to) login and personalization settings.
  3. It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by your browser’s developer and your device’s manufacturer if you are unsure about adjusting your privacy settings.

15. Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at roland@edmdesigner.com, by telephone on +36-70-608-4433, or by post at Ground Floor 41, 4–6 Simonffy Street, Debrecen, 4025, Hungary. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 13, above).

16. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site, and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date with our latest privacy practices.