FireFlink Privacy Policy

FireFlink processes and stores two categories of data from its Customers while providing FireFlink Services.

• User Account data
• Test execution data

The first category of data is personal information provided by the Customer during the Services, excluding 'Test execution data.' This includes personal information of any employee, user, or customer personnel, referred to as 'User Account data.' This data includes names, email addresses, and phone numbers. The second category of data is information, including personal information, that is stored, processed in, or transmitted via the FireFlink platform by or on behalf of our Customer. This is referred to as 'Test execution data.' This category includes data uploaded by our Customers to our Platform or accessed by our Platform during application testing, such as reports, tests, networks, browser process logs, other artifacts, authentication, licensing, test execution metadata (e.g., test status, duration, name, browsing sessions, search history), and other information provided during testing. Generally, 'Test execution data' refers to data stored or processed for the delivery of Services we provide as a data processor and includes data stored for backup.'Test execution data' does not necessarily contain identifiable personal information or sensitive personal information about customer personnel, customers, end-users, or other third parties. Please note that FireFlink does not collect or require any identifiable personal information or sensitive data by default for its functioning. From a privacy perspective, the Customer is the controller of 'Test execution data,' and FireFlink acts as a processor. This means that throughout the duration of a Customer's subscription to FireFlink's services, the Customer retains ownership and control over the 'Test execution data' in their account.

Additionally, the types of personal information we collect include:

• Transaction and Payment Information: Information related to transactions you conduct with us, including bank account details and other relevant payment information.
• Location Information: Location data provided by a mobile device interacting with our websites or applications, or associated with your IP address when you visit our websites or use our products and services.
• Public/Third Party Information: Information from third-party or public sources, or information we receive from companies partnering with us to provide our products and services.
• Consents and Preferences Information: Details of the permissions, consents, and preferences you provide to us.
• Marketing, Lead Generation/Inside Sales, and Related Information: Includes your first name, surname, email address, phone number, and company name.
• Social Media Identifiers: Information from social media posts by individuals or companies, publicly available information and identifiers, including analytics and profiles of individuals, and details from third-party owned or sold personal information.
• Marketing Event Data: Information from online and offline marketing events such as seminars, marketing campaigns (including ads), webinars, guest speakers, testimonials, workshops, business calls and meetups, trade fairs, and similar events.
• Web and Communication Data: Information such as IP address, web history data, operating system and browser type, page tracking data, traffic data, location data, blogs, and other communication data received through chatbots.
• Professional and Employment Details: Information including title/designation/role, company name, location, and contact details obtained through social networking sites, customer referrals, publicly available sources, and purchased contact lists.
• The technologies we use for automatic data collection may include:
• Cookies (or browser cookies): Cookies are small files stored on your computer's hard drive. You can decline browser cookies by adjusting your browser settings. However, doing so may limit your access to certain parts of FireFlink Services or restrict some functionalities. Unless you configure your browser to refuse cookies, our system will place cookies on your device when you visit FireFlink Services.
• Web Beacons: FireFlink Services pages and emails may include small electronic files known as web beacons (also called clear gifs, pixel tags, and single-pixel gifs). These files help us count users who visit our pages or open our emails, and gather other related website statistics, such as tracking the popularity of specific content and ensuring system and server integrity.
• We may also collect personal information about you from third-party sources, including marketers, partners, researchers, affiliates, service providers, vendors, and others who are legally permitted to share your information with us. For example, if you sign up for FireFlink Services through another website, that website may share your personal information with us.

The first category of data is personal information provided by the Customer during the Services, excluding 'Test execution data.' This includes personal information of any employee, user, or customer personnel, referred to as 'User Account data.' This data includes names, email addresses, and phone numbers. The second category of data is information, including personal information, that is stored, processed in, or transmitted via the FireFlink platform by or on behalf of our Customer. This is referred to as 'Test execution data.' This category includes data uploaded by our Customers to our Platform or accessed by our Platform during application testing, such as reports, tests, networks, browser process logs, other artifacts, authentication, licensing, test execution metadata (e.g., test status, duration, name, browsing sessions, search history), and other information provided during testing. Generally, 'Test execution data' refers to data stored or processed for the delivery of Services we provide as a data processor and includes data stored for backup.'Test execution data' does not necessarily contain identifiable personal information or sensitive personal information about customer personnel, customers, end-users, or other third parties. Please note that FireFlink does not collect or require any identifiable personal information or sensitive data by default for its functioning. From a privacy perspective, the Customer is the controller of 'Test execution data,' and FireFlink acts as a processor. This means that throughout the duration of a Customer's subscription to FireFlink's services, the Customer retains ownership and control over the 'Test execution data' in their account.

Additionally, the types of personal information we collect include:

• Transaction and Payment Information: Information related to transactions you conduct with us, including bank account details and other relevant payment information.
• Location Information: Location data provided by a mobile device interacting with our websites or applications, or associated with your IP address when you visit our websites or use our products and services.
• Public/Third Party Information: Information from third-party or public sources, or information we receive from companies partnering with us to provide our products and services.
• Consents and Preferences Information: Details of the permissions, consents, and preferences you provide to us.
• Marketing, Lead Generation/Inside Sales, and Related Information: Includes your first name, surname, email address, phone number, and company name.
• Social Media Identifiers: Information from social media posts by individuals or companies, publicly available information and identifiers, including analytics and profiles of individuals, and details from third-party owned or sold personal information.
• Marketing Event Data: Information from online and offline marketing events such as seminars, marketing campaigns (including ads), webinars, guest speakers, testimonials, workshops, business calls and meetups, trade fairs, and similar events.
• Web and Communication Data: Information such as IP address, web history data, operating system and browser type, page tracking data, traffic data, location data, blogs, and other communication data received through chatbots.
• Professional and Employment Details: Information including title/designation/role, company name, location, and contact details obtained through social networking sites, customer referrals, publicly available sources, and purchased contact lists.
• The technologies we use for automatic data collection may include:
• Cookies (or browser cookies): Cookies are small files stored on your computer's hard drive. You can decline browser cookies by adjusting your browser settings. However, doing so may limit your access to certain parts of FireFlink Services or restrict some functionalities. Unless you configure your browser to refuse cookies, our system will place cookies on your device when you visit FireFlink Services.
• Web Beacons: FireFlink Services pages and emails may include small electronic files known as web beacons (also called clear gifs, pixel tags, and single-pixel gifs). These files help us count users who visit our pages or open our emails, and gather other related website statistics, such as tracking the popularity of specific content and ensuring system and server integrity.
• We may also collect personal information about you from third-party sources, including marketers, partners, researchers, affiliates, service providers, vendors, and others who are legally permitted to share your information with us. For example, if you sign up for FireFlink Services through another website, that website may share your personal information with us.

The legal basis we rely on varies depending on the specific Products and Services you use and the reasons you contact us. We collect and use your personal information in the following situations:

• Contractual – Fulfilling any contract we have with you or taking steps at your request before entering into a contract with you.
• Legitimate Interests – This is necessary for our legitimate business interests and is not outweighed by your privacy interests. These legitimate interests include:
• Operating and providing our Websites and Products and Services, including offering customer support and handling your orders, requests, questions, and concerns.
• Collecting data on product usage, analytics, and performance related to our Websites and Products and Services to maintain, analyze, develop, update, and enhance them.
• Keeping records of bugs, customer support requests, and similar inquiries, along with our responses.
• Using information to personalize content and features on our Websites and Products and Services.
• Detecting, investigating, and preventing activities that may breach our policies or applicable laws, such as fraud detection and prevention.
• Managing our business efficiently, including financial administration, business planning, communications, corporate governance, and auditing.
• Maintaining corporate or business records according to our retention policies and applicable laws.
• Protecting against activities that may threaten the security, integrity, or availability of our or others' products, systems, and services.
• Protecting our legal rights and defending against claims.
• Marketing and selling our Products and Services in compliance with applicable laws.
• Understanding your needs and interests better to personalize your experience with our services.
• Managing and communicating with you about your service account, if you have one, including sending service announcements, technical notices, updates, security alerts, and support and administrative messages.
• Sending you updates about FireFlink Services and blogs, or contacting you about our services that may interest you, via email.
• Gaining insights into how you and others use FireFlink Services to improve them and for other research and analytical purposes.
• Sending you FireFlink-related marketing communications, as permitted by law, if you request information, use the service, or participate in our surveys, promotions, or events, while providing you the option to opt-out
• Consent - You provide us with permission to process your personal information.
• In certain instances, we may request your consent to collect, use, or share your personal information, such as when you allow us to post your testimonials or endorsements on the Service.

Processing is based on your consent. If we rely on your consent, you have the right to withdraw it at any time by sending a request to support@fireflink.com with “Opt-out” or “UNSUBSCRIBE” in the email subject line.

Note: Even if you opt out of receiving promotional messages from us, we will continue to send you non-promotional communications, such as service-related emails, if you have an account for FireFlink Services.

• Legal Obligations – We need to process your personal information to comply with legal obligations, such as responding to a lawful subpoena or law-enforcement request, or to follow the lawful instructions of our customers when they act as the data controller.
• For compliance with the law: We may use your personal information as we deem appropriate to:
• (a) comply with applicable laws, lawful requests, and legal processes, including responding to subpoenas or requests from government authorities;
• (b) participate in legal investigations where permitted by law; and
• (c) prosecute or defend legal claims.
• Other – We may process your personal information based on another lawful basis in accordance with applicable law.

When we rely on our legitimate interests to process your information, we will balance those interests against your privacy rights. We will not use your personal information if the impact on you outweighs our interests, unless we have your consent or are otherwise permitted by law.

FireFlink collects this information to better understand your needs regarding our services and to enhance your experience. We may also use this information for the following purposes:

• Providing you with FireFlink Services.
• Maintaining internal records for correspondence.
• Supplying you with requested information, processing requests or resources, and other purposes.
• Improving our service offerings and personalizing your experience.
• Periodically sending promotional emails about new services, webinars, technology events, or other information we think may interest you, using the email address you provided.
• Sending you information, including marketing communications about our business, which we think may interest you by post, email, or other means.
• Sending commercial emails to individuals or companies with whom we want to develop or maintain a business relationship, in accordance with applicable marketing laws.
• Contacting you to collect feedback or conduct surveys.
• Using the collected information to update, maintain, and track marketing and lead generation efforts in a Customer Relationship Management (CRM) tool/database.
• Handling any postings, comments, or other content you may post on our website or social media platforms.
• We may transfer personal information to our contracted service providers and advisors, who may be located in other countries. Adequate data protection measures are implemented before such data transfers.
• We may disclose your personal information to third parties if we sell or liquidate any part of our business or assets.
• We may share your personal information with third parties for specific purposes (e.g., prospecting or insurance). Any processing of personal information by a third party on our behalf will be governed by a valid written contract. This contract will outline the processing's subject matter and duration, nature and purpose, the type of personal information, categories of data subjects, and the obligations and rights of the company.
• FireFlink complies with ISO 27001 (Information Security Management Systems), ISO 27701 (Privacy Information Management System), and System and Organization Controls (SOC) to ensure appropriate technical and organizational safeguards.
• FireFlink uses and complies with UK and European Commission-approved standard contractual clauses (SCCs) for transferring Personal Data from the EU/EEA to the United States or other countries without equivalent privacy and data protection laws. We are responsible for processing such Personal Data under the SCCs and for any subsequent onward transfer to a third party providing services to us as a representative on our behalf.

• We will retain your FireFlink Account data and personal information only as long as necessary. Personal information processed for any purpose will not be kept longer than required for that purpose. If you have an ongoing relationship with us, we will keep the data as long as your relationship is active or as needed to provide services and comply with legal and contractual obligations.
• All test execution data from executed VMs or real devices is deleted immediately after the test is completed. Each test run starts with a new, clean, and sanitized machine or device. VMs are deleted after test completion, and real devices are cleaned before being returned to the public pool.
• FireFlink stores encrypted test execution data, such as logs, videos, and screenshots, for 60 days by default. Customers can request the deletion of all personal data via email, with a typical turnaround time of 48 hours.
• If you have opted to receive marketing communications from us, we retain information about your preferences for a reasonable period from your last interaction with our content or services. Information from cookies and other tracking technologies is also retained for a reasonable period from creation/receipt. When no longer needed, FireFlink will securely destroy or delete collected personal information according to our information security policies and contractual agreements.
• Non-personally identifiable and aggregated information may be stored for a longer duration.
• Compelled Disclosure: FireFlink reserves the right to use or disclose personal information if required by law or if we reasonably believe it is necessary to protect our rights, employees, or the safety of others, investigate fraud, or comply with a law, court order, or legal process.

Sharing of Data within FireFlink:

• Personal information may be shared within FireFlink to provide Products and Services to our customers.
• With global employees and offices, FireFlink may transfer information worldwide. Outside of the EU, FireFlink employees may access information from other countries, subject to controls such as geofencing to restrict access to personal information.

Data Sharing with Support Providers for Our Products and Services:

• To deliver our Products and Services, we utilize various systems, platforms, and services, some provided by FireFlink and others by third-party vendors and service providers. This encompasses everything from software in our finance department to the infrastructure for running our Products and Services, including during free trials. When we engage vendors and service providers, they serve as processors acting on our behalf. These vendors are bound by data processing agreements with us, operate according to our instructions, and adhere to the policies outlined in this document.

Data Sharing with Third Parties:

• If you're an individual located in the EEA and have provided explicit consent, we may share your personal information with specific partners of your choosing. For individuals outside the EEA, we may share your personal information with designated partners clearly identified during the sign-up process. We always transparently communicate when such information is shared, such as when we collaborate with a partner to provide an event or asset.

How to Opt Out of FireFlink Marketing:

• You have the option to opt out of receiving marketing communications from us at any time.
• If you wish to stop receiving marketing communications from us, you can utilize the "Unsubscribe" link provided in all marketing emails sent by us.

How to Opt Out of Third-Party Marketing, such as from Our Customers:

• Our customers are responsible for their own marketing emails and communications, and we do not have the authority to unsubscribe you from their communications.
• You can opt out of our customers' marketing communications by clicking on the "unsubscribe" link located at the bottom of their emails or by directly contacting them

How to Opt Out of FireFlink Marketing:

• You have the option to opt out of receiving marketing communications from us at any time.
• If you wish to stop receiving marketing communications from us, you can utilize the "Unsubscribe" link provided in all marketing emails sent by us.

How to Opt Out of Third-Party Marketing, such as from Our Customers:

• Our customers are responsible for their own marketing emails and communications, and we do not have the authority to unsubscribe you from their communications.
• You can opt out of our customers' marketing communications by clicking on the "unsubscribe" link located at the bottom of their emails or by directly contacting them

Certain vendors and service providers, including those in the United States, are based outside the EEA and UK. When we transfer your personal information outside the EEA and/or UK, we ensure a similar level of protection by implementing one of the following safeguards:

• We transfer your personal information only to countries with adequate protection for personal data under applicable law.
• When using specific service providers, we employ contracts approved for use in the UK and/or EEA, providing the same level of protection.
• With certain service providers, we implement supplemental safeguard measures, which may include technical, contractual, and/or organizational measures.

Please reach out to us if you require further information about the specific mechanism used by us when transferring your personal data out of the UK and/or EU.

Updates to Your Personal Data: You have the right to request access, correction, updates, or deletion of your Personal Data. You can also object to the processing, ask for restriction of processing, or request portability of your Personal Data. If we collected and processed your Personal Data with your consent, you may withdraw your consent at any time. However, withdrawing your consent will not affect the lawfulness of any processing conducted prior to withdrawal, nor will it affect processing conducted on lawful grounds other than consent.

Contact us (support@fireflink.com) if you wish to update your personal information

In case you have previously subscribed or agreed to us for sharing your personal information for direct marketing purposes, you may opt-out the same anytime by writing an email to support@fireflink.com.

Your Rights: Subject to applicable law, you have the following rights in relation to your Personal Data:

Right of Access: Upon request, we will confirm if we are processing your Personal Data and provide you with a copy of that data along with certain other details. Additional copies may require a reasonable fee

Right to Rectification: If your Personal Data is inaccurate or incomplete, you can request that we correct or complete it. If we shared your Personal Data with others, we will inform them of the correction where feasible. Upon request and where possible and lawful, we will also disclose to whom we shared your Personal Data so you can contact them directly.

Right to Erasure: You may ask us to delete or remove your Personal Data, such as when you withdraw your consent. If we shared your data with others, we will inform them of the erasure where feasible. Upon request and where possible and lawful, we will also disclose to whom we shared your Personal Data so you can contact them directly.

Right to Restrict Processing: You can request to restrict or 'block' the processing of your Personal Data in certain circumstances, such as when you dispute the accuracy of the data or object to its processing. We will notify you before lifting any processing restriction. If we shared your Personal Data with others, we will inform them of the restriction where feasible. Upon request and where possible and lawful, we will also disclose to whom we shared your Personal Data so you can contact them directly.

Right to Data Portability: You have the right to receive your Personal Data from us in a structured, commonly used, and machine-readable format. You may request your data for reuse elsewhere.

Right to Object: You can request at any time that we cease processing your Personal Data, particularly for direct marketing. However, if we have compelling legitimate grounds for processing your Personal Data based on our legitimate interests, we may continue processing.

Rights in Relation to Automated Decision-Making and Profiling: You have the right not to be subject to decisions based solely on automated processing of your Personal Data, including profiling, that significantly affect you, unless such profiling is necessary for entering into or performing a contract between you and us, or you explicitly consent.

Right to Withdraw Consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect processing prior to notice of withdrawal.

Right to Lodge a Complaint with the Data Protection Authority: If you have concerns about our privacy practices, including how we handled your Personal Data, you can report them to the authorized data protection authority.

You may exercise your rights by writing an email at support@fireflink.com where you request your specific rights.

Legitimate Interest: "Legitimate interests" refers to FireFlink’s interests in conducting and managing our organization. For instance, we have a legitimate interest in processing your Personal Data to analyze how you use the Services and to ensure network and information security, as outlined in this Privacy Policy. When processing your Personal Data for our legitimate interests, we carefully weigh any potential impact on you and your rights under data protection laws. Our legitimate interests do not automatically supersede your interests. We refrain from using your Personal Data for activities where our interests conflict with your interests, unless we obtain your consent or such activities are mandated or permitted by law. You have the right to object to processing based on our legitimate interests. For further details on your rights, please refer to the "Your Rights" section above

If you have any queries regarding FireFlink's privacy policies and practices, please reach out to us at support@fireflink.com.