Privacy Policy
1.Introduction
At Colman, accessible from www.sortimize.com/privacy-policy, one of our main priorities is the privacy of our visitors. This Privacy Policy document contains types of information that is collected and recorded by Colman and how we use it. If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us.
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1.1. We are committed to safeguarding the privacy of our website visitors and the service users. We strive to be compliant beyond the requirements of the GDPR for everyone, regardless of their geographic location and the nature of their activities with us.
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1.2. As per GDPR, and due to the nature of our activities, this policy applies to both scenarios of data controller and data processor:
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(a) where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
(b) where we are acting as a data processor with our service users’ store data (the data controller); in other words, where we will only process personal data on the instructions of the service user to the extent that we believe those instructions do not infringe either our Privacy Policy or the GDPR.
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1.3. In this policy, "we", "us" and "our" refer to Colman
2. How we use your personal data?
2.1. In this Section 2 we have set out:
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(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you but another data controller (e.g. Shopify and Google Analytics… etc.), the source and specific categories of that data;
(The personal data we receive outside of Shopify and Google Analytics can be: Which collection, how, how often, within which parameters the service user sorts, errors the service user receives (errors received from Shopify servers, errors related to Google Analytics, and/or errors produced when running the sorting algorithms in our application which could be due to missing data from Google Analytics or Shopify), and perhaps at a later stage, reading the service users' store and collection data in order to improve Colman's sorting algorithms & functions. Upon having a chance for a better use of the service, we may process these data to improve the ‘’Colman’’ application and provide information/reports to the service user regarding their use of Colman and collections in their online store on Shopify.)
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
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2.2. We may process data of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.
The source of usage data may be Google Analytics, or the scripts written scripts written by the Colman developer team. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is monitoring and improving our website and services.
When you connect your Google Account, we may receive your email address, and Google Analytics data of your websites available through Google Analytics. We may save this information in our database and use it to provide insights and analytics. We will not share this information with 3rd parties.
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2.3. We may process your account data ("account data"). The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter such a contract. For stores, we collect the following fields: Contact email, store name (like Digital Pals Store), Shopify domain, Shopify store id, Shopify Plan, URL. For collections, we collect data on the following fields to run our application: the id of the collections, title of the collections. "For collections, we collect data on the following fields to run our application: "We receive the following information from Google: Access token and Refresh token, Account id, Account Name, currency, Ecommerce Tracking, Enhanced Ecommerce Tracking, Time zone, Property id, Property Name, URL, the related email address that the service user uses to connect their Google Analytics account to Colman, View name.
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2.4. We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include Email address of the account linked to Google Analytics. The source of the customer relationship data may be Shopify if ever needed. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is the proper management of our customer relationships.
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2.5. We may process information relating to transactions, including purchases of goods and services, that you enter with us and/or through our website ("transaction data"). The transaction data may include your contact details, and the transaction details. The source of the transaction data is you and/or our payment services provider. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our application and business.
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2.6. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter such a contract.
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2.7. We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
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2.8. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
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2.9. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
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2.10. In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
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2.11. We may process information relating to your store data (“store data ”). We pull information from Shopify instantaneously . The store data may relate to orders, products and customers of your store and include personal information, geographic and transactional data. Our databases will only replicate certain data available on your store. The data will be read periodically. Any customer data deleted in your store will be deleted from our databases. In some cases, for development / statistics purposes, the store may be kept in its processed form rather than the data itself. We do not maintain historical copies of your store data. The legal basis for this processing is the performance of a contract between you and us.
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How we use your information
We use the information we collect in various ways, including to:
• Provide, operate, and maintain our application
• Improve, personalize, and expand our application
• Understand and analyze how you use our application
• Develop new products, services, features, and functionality
• Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes
• Send you emails
• Find and prevent fraud
• Your Google Analytics data will be used to produce insights and analytics regarding your eCommerce store.
3. Providing your personal data to others
3.1. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
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3.2. We may disclose usage data and transaction data to our suppliers or subcontractors insofar as reasonably necessary for the performance of a contract between you and us.
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3.3. Financial transactions relating to our website and services may be handled by our payment services provider, Shopify. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://help.shopify.com/en/manual/your-account/manage-billing/your-invoice/apps.
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3.4. In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfer your data
4.1. Your information, including Personal Data, and your store data may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
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4.2. Colman will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of Personal Data will take place to an organization or a country without your instruction and unless there are adequate controls in place including the security of your data and other personal information.
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4.3. The hosting facilities for our website and services are situated in the Frankfurt, Europe .
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4.4. You acknowledge that the personal data you submit for publication through our website or services may be available worldwide on the internet. Although all necessary precautions have been taken by us, in some cases we cannot prevent the use (or misuse) of such personal data by others.
5.Retaining and deleting personal data
5.1. This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3. We keep your personal data only as long as necessary to provide you with the Colman Service and for legitimate and essential business purposes, such as maintaining the performance of the Colman Service, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes[as1] [as2] ..
5.4. Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5.5. We will retain your store data for the duration of the service read period. We will over-write the last version of your store data on our databases when we are reading the latest version of your store data. Any customer data or any other store data that you have deleted from your store data will also be deleted from our databases on the next read of your data or on cancelation of your services with us, for example removing our app from your store.
6. Amendments
6.1. We may update this policy from time to time by publishing a new version on our website.
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6.2. You should check this page occasionally to ensure you are happy with any changes to this policy.
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6.3. We will notify you of significant changes to this policy by email.
7. Your Rights
7.1. In this Section 7, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
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7.2. Your principal rights under data protection law are:
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(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
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7.3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can request access to your personal data by emailing support@sortimize.com
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7.4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
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7.5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
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7.6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
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7.7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
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7.8. To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
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7.9. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.10. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.11. You may exercise any of your rights in relation to your personal data by email to support@sortimize.com
8. About Cookies
8.1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
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8.2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
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8.3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you
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9. Cookies that we use
9.1. We use cookies for the following purposes:
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(a) authentication - we use cookies to identify you when you visit our website and as you navigate our website;
(b) status - we use cookies to help us to determine if you are logged into our website;
(c) personalization - we use cookies to store information about your preferences and to personalise the website for you;
(d) security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally; and
(e) analysis - we use cookies to help us to analyse the use and performance of our website and services
10. Cookies, Cookies used by our service provider and Web Beacons
Colman uses ‘’Cookies’’. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users’ experience by customizing our web page content based on visitors’ browser type and/or other information.
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Advertising Partners Privacy Policies:
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You may consult this list to find the Privacy Policy for each of the advertising partners of Colman. Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on Colman, which are sent directly to users’ browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit. It is worthy of note that Colman has no access to or control over these cookies that are used by third-party advertisers.
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Third Party Privacy Policies:
Sortimize’s Privacy Policy does not apply to other advertisers or websites. Thus, we are advising you to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options. You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers’ respective websites.
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Children’s Information:
Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity. Colman does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website (https://www.sortimize.com/) , we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
11. Use of Google Analytics Data
Our application collects and processes user behavior data through Google Analytics. Google Analytics accesses various data points to track user interactions with websites and applications. In this context, the data obtained through Google Analytics is processed for the following purposes:
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Analyzing the performance of the website or application,
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Improving the user experience,
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Optimizing services by analyzing the interests and behaviors of the target audience.
Access and Download of Google Analytics Data
Our application has the authority to access and download users' Google Analytics data. This data may include:
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How users interact with our website,
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Traffic sources,
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Duration of visits and pages visited.
The Google Analytics data obtained will only be used to improve the user experience and enhance our services, and will not be shared with third parties.
12. Our details
12. Your personal data is processed by Podo Pals, as the data controller, within the scope of the Personal Data Protection Law No. 6698 ("KVKK") and relevant legislation.
12.2 You can contact us by email, using hello@podopals.com
12.3 Our website can be accessed at https://www.podopals.com/