Privacy Statement Effective as of March 18, 2016

Viseven Europe OÜ ("Viseven Europe", "Viseven", or the "Company", "We", "Us", "Our") is committed to secure and trustworthy Internet commerce and the individual’s right to privacy. This Privacy Statement describes Viseven Europe’s information practices: what information Viseven Europe and its related entities collect about you and why, what we do with that information, how we share it, and how we handle the content you place in our products and services. It also explains the choices available to you regarding our use of your personal information and how you can access and update this information.

This Privacy Policy applies to the information that we obtain through your use of "Viseven Europe OÜ" via a "Device" or when you otherwise interact with the Company.

This privacy statement covers the information practices of our:

but does not include:

A "Device" is any computer used to access the Viseven Europe OÜ Services, including without limitation a desktop, laptop, mobile phone, tablet, or other consumer electronic device.

Unless otherwise stated, our SaaS Products and our Downloadable Products are treated the same for the purposes of this document.

By registering for or using Viseven Europe OÜ Services you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy.

Content: any information or data that you upload, submit, post, create, transmit, store or display in an Viseven Europe OÜ Service.

Downloadable Products: Viseven Europe OÜ’s downloadable software products and mobile applications that are installed by customers on an infrastructure of their choice.

Information: all of the different forms of data, content, and information collected by us as described in this Privacy Policy.

Personal Information: information that may be used to readily identify or contact you as an individual person, such as: name, address, email address, or phone number. Personal Information does not include information that has been anonymized such that it does not allow for the ready identification of specific individuals.

SaaS Products: Viseven Europe OÜ’s "Cloud" hosted solutions, as well as other Viseven Europe OÜ hosted solutions that display a link to this Privacy Policy. For the avoidance of doubt, if an Viseven Europe OÜ hosted solution displays a link to a different privacy policy, then that other privacy policy shall apply.

Websites: Viseven Europe OÜ’s websites, including but not limited to viseven.com, ewizard-detailing.com, cobalt-engine.com and any related websites, sub-domains and pages.

We may change this Privacy Policy from time to time. If we make any changes, we will notify you by revising the "Effective Starting" date at the top of this Privacy Policy. If we make any material changes, we will provide you with additional notice (such as by adding a notice on the Viseven Europe OÜ Services homepages, login screens, or by sending you an email notification). We encourage you to review our Privacy Policy whenever you use Viseven Europe OÜ Services to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this Privacy Policy, you will need to stop using Viseven Europe OÜ Services and deactivate your account(s), as outlined below.

When expressing an interest in obtaining additional information about Viseven Europe’s products or accessing secure areas of our Websites, Viseven Europe requires you to provide the following personal information, such as:

You may provide this information directly when you enter it in Viseven Europe OÜ Services.

In some cases, another user (such as a system administrator) may create an account on your behalf and may provide your information, including Personal Information (most commonly when your company requests that you use our products). We collect Information under the direction of our customers and often have no direct relationship with the individuals whose personal data we process. If you are an employee of one of our customers and would no longer like us to process your information, please contact your employer. If you are providing information (including Personal Information) about someone else, you must have the authority to act for them and to consent to the collection and use of their Personal Information as described in this Privacy Policy.

We collect and store Content that you create, input, submit, post, upload, transmit, store or display in the process of using our SaaS Products or Websites. Such Content includes any Personal Information or other sensitive information that you choose to include ("incidentally-collected Personal Information").

Also, we collect other data that you submit to our Websites or as you participate in any interactive features of the Viseven Europe OÜ Services, participate in a survey, contest, promotion, sweepstakes, activity or event, apply for a job, request customer support, communicate with us via third party social media sites or otherwise communicate with us. For example, information regarding a problem you are experiencing with an Viseven Europe OÜ product could be submitted to our Support Services or posted in our public forums.

As you navigate the Company’s Websites, Viseven Europe may also collect information through the use of commonly used information-gathering tools such as cookies. Information collected includes standard information from your web browser such as your Internet Protocol (IP) address, browser type, operating system, referring/exit pages, links clicked, and actions taken while browsing.

As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Websites and SaaS Products. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your Devices, your mobile carrier, and system configuration information. In the case of our SaaS Product, the URLs you accessed (and therefore included in our log files) include usernames as well as elements of Content as necessary for the SaaS Product to perform the requested operations. Occasionally, we connect Personal Information to information gathered in our log files as necessary to improve Viseven Europe OÜ Services for individual customers. In such a case, we would treat the combined Information in accordance with this privacy policy.

We collect analytics information when you use our Websites and SaaS Products to help us improve our products and services. In the SaaS Products, this analytics information consists of the feature and function of the Viseven Europe OÜ Service being used, the associated license identifier (SEN) and domain name, the username and IP address of the individual who is using the feature or function (which will include Personal Information if the Personal Information was incorporated into the username), the sizes and original filenames of attachments, and additional information required to detail the operation of the function and which parts of the Viseven Europe OÜ Services are being affected.

Analytics information also consists of data we collect as a result of running queries against Content across our user base for the purposes of generating Usage Data. "Usage Data" is aggregated data about a group or category of services, features or users that does not contain Personal Information.

Though we may happen upon sensitive or Personal Information as we compile Usage Data from Content across user instances, this is a byproduct of our efforts to understand broader patterns and trends. It is not a concerted effort by us to examine the Content of any particular customer.

We collect analytics information when you use our Downloadable Products to help us improve our products and services. Our Downloadable Products contain a feature that sends information about the technical operation of the Downloadable Products on your systems ("System Information") to us.

In addition, we collect analytics information from Downloadable Products that is a subset of the analytics information described above for Websites and SaaS Products. As with Websites and SaaS Products, the analytics information we collect includes elements of Content related to the function the user is performing, but with an important caveat. With the Downloadable Products, before sending the information to Viseven Europe OÜ's servers, we filter the analytics information to remove elements that we believe may contain sensitive or Personal Information.

During the installation of our Downloadable Products, the installer sends analytics information to Viseven Europe OÜ to allow us to understand where in the installation process users are experiencing trouble or dropping out. Examples of information we collect for these purposes include the name and version of the Downloadable Product and the server ID, SEN, and IP address of the customer instance.

Viseven Europe OÜ utilizes commonly used information-gathering tools, such as cookies, to collect information as you navigate the Company’s Websites ("Website Navigational Information"). This section describes the types of Website Navigational Information that may be collected on the Company’s Websites and how this information may be used.

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close your browser. Cookies enable us to track and target the interests of our users to enhance the experience on our site. Enabling these cookies is not strictly necessary for the website to work but it will provide you with a better browsing experience. You can delete or block these cookies, but if you do that, some features of this site may not work as intended.

As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you.

We also obtain information from third parties and combine that with Information we collect through Viseven Europe OÜ Services. For example, we may have access to certain information from a third party social media or authentication service if you log into Viseven Europe OÜ Services through the service or otherwise provide us with access to Information from the service. Any access that we may have to such Information from a third party social or authentication service is in accordance with the authorization procedures determined by that service. By authorizing us to connect with a third party service, you authorize us to access and store your name, email address(es), current city, profile picture URL, and other information that the third party service makes available to us, and to use and disclose it in accordance with this Privacy Policy. You should check your privacy settings on these third party services to understand and change the information sent to us through these services.

Viseven Europe OÜ uses the information collected from our Websites, Products and SaaS to perform the services requested. For example, we may use this information to:

*Investigate and prevent fraudulent transactions, unauthorized access to Viseven Europe OÜ Services, and other illegal activities;

*Enable you to communicate, collaborate, and share Content with users you designate;

We will not share or disclose any of your Personal Information or Content with third parties except as described in this policy. We do not sell your Personal Information or Content.

When you use Viseven Europe OÜ Services, Content you provide will be displayed back to you. Certain features of Viseven Europe OÜ Services allow you or your administrator to make some of your Content public, in which case it will become readily accessible to anyone. We urge you to consider the sensitivity of any data you input into Viseven Europe OÜ Services.

As a natural result of using Viseven Europe OÜ Services, you may create Content and grant permission to other Viseven Europe OÜ users to access it for the purposes of collaboration. Some of the collaboration features of Viseven Europe OÜ Services display your profile information, including Personal Information included in your profile, to users with whom you have shared your Content. Where this information is sensitive, we urge you to use the various security and privacy features of the Viseven Europe OÜ Services to limit those who can access such information. Your sharing settings may make any Information, including some Personal Information, that you submit to the Viseven Europe OÜ Services visible to the public, unless submitted to a restricted area.

You should be aware that the administrator of your instance of Viseven Europe OÜ Services may be able to:

We work with third party service providers to provide website, application development, hosting, maintenance, back-up, storage, virtual infrastructure, payment processing, analysis and other services for us. These service providers may have access to or process your Information for the purpose of providing those services for us. Please be aware that you are providing your Information to these third parties acting on behalf of Viseven Europe OÜ.

The Viseven Europe OÜ Services may include links to other websites whose privacy practices may differ from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

The Viseven Europe OÜ Services may contain social media features, such as the Twitter "tweet" button. These features may collect your IP address, which page you are visiting on the Viseven Europe OÜ Services, and may set a cookie to enable the feature to function properly. Social media features and Widgets are either hosted by a third party or hosted directly on our Viseven Europe OÜ Services. Your interactions with these features are governed by the privacy policy of the company providing it.

We may disclose your Information (including your Personal Information) to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies and terms of service, (c) to protect the security or integrity of Viseven Europe OÜ ‘s products and services, (d) to protect Viseven Europe OÜ, our customers or the public from harm or illegal activities, or (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.

We may share or transfer your Information (including your Personal Information) in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You will be notified via email and/or a prominent notice on the Viseven Europe OÜ Services of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

We may also share aggregated or anonymized information that does not directly identify you with the third parties described above. We will share your Personal Information with third parties when we have your consent to do so.

We do not share Personal Information about you with third parties for their marketing purposes (including direct marketing purposes) without your permission. We will share your personal information with third parties only in the ways that are described in this Privacy Statement. We do not sell your personal information to third parties.

We may provide your personal information to companies or their Websites that provide services to help us with our business activities such as customer support or billing for our services. These companies are authorized to use your personal information only as necessary to provide these services to us.

Viseven Europe OÜ hosts data with hosting service providers in numerous countries. The servers on which Personal Information is stored are kept in a controlled environment. While we take reasonable efforts to guard your Personal Information, no security system is impenetrable and due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. In addition, we cannot guarantee that any incidentally-collected Personal Information you choose to store in Websites or SaaS Products are maintained at levels of protection to meet specific needs or obligations you may have relating to that information.

Where data is transferred over the Internet as part of a Website or SaaS Product, the data is encrypted using industry standard SSL (HTTPS).

Where Downloadable Products are used, responsibility of securing access to the data you store in the Downloadable Products rests with you and not Viseven Europe OÜ. We strongly recommend that administrators of Downloadable Products configure SSL to prevent interception of data transmitted over networks and to restrict access to the databases and other storage used to hold data.

Viseven Europe OÜ offers customers and visitors who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the "unsubscribe" link located on the bottom of the Company’s marketing emails.

The security of your personal information and our Customers’ information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Websites, or within our products and services, you can contact us at support@viseven.com.

Viseven Europe OÜ reserves the right to update this Privacy Statement to reflect changes to our information practices. We will provide notification of material changes to this statement through the Company’s Websites or to our Customer via email prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Questions regarding this Privacy Statement or the information practices of the Company’s Websites should be directed to Viseven Europe as follows:

Mail:

Privacy Viseven Europe OÜ

Lõõtsa Str. 2a, Lasnamäe district, Tallinn, Harju County, 11415, Estonia

Email: legal@viseven.com

This policy was effective March 2014

The policy revised November 2014

The policy was last revised February 2015

The Policy was last reviewed March 2016

The Policy was last reviewed April 2017