Privacy Notice - Bliro Applications

In the following, we provide information about the collection of personal data when using our applications

Bliro Windows Application
‍Bliro Mac Application
‍Bliro iPhone Application
‍Bliro Web Application
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and connecting to our APIs
api.bliro.io
‍wss.bliro.io 
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Personal data is any data that can be related to a specific natural person, such as their name or IP address.

The controller within the meaning of Art. 4 para. 7 EU General Data ProtectionRegulation (GDPR) is

‍bliro GmbH
‍Schellingstraße 112
80798 München, Germany
email: trust@bliro.io

We are legally represented by Maurice Schweitzer, Martin Thoma.

Our data protection officer can be reached via

‍Kertos GmbH
‍Briennerstraße 41
80333 München, Germany
email: dsb@kertos.io

We detail the scope of data processing, processing purposes and legal bases below.In principle, the following come into consideration as the legal basis for data processing:

- Art. 6 para. 1 s. 1 it. a GDPR serves as our legal basis for processing operations for which we obtain consent.
- Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a sitevisitor purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
- Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
- Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that arenecessary for the technical operation of our website.

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR).

In the case of data transfer to service providers in the USA, the legal basis for the data transfer is an adequacy decision of the EU Commission if the service provider has also certified itself under the EU US Data Privacy Framework.

In other cases (e.g. if no adequacy decision exists), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.

Unless expressly stated in this privacy notice, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

Data subjects have the following rights against us with regard to their personal data:

- Right of access
- Right to correction or deletion
- Right to limit processing
- Right to object to the processing
- Right to data transferability
- Right to revoke a given consent at any time.
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Data subjects also have the right to appeal to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available at https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html.

Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship. 

Mandatory data are marked as such.

As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit f GDPR. We delete the data when the results of the surveys have been evaluated.

We reserve the right to inform customers who have already used services from us or purchased goods from time to time by e-mail or other means electronically about our offers, if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 s. 1 lit. f GDPR. Our legitimate interest is to conduct direct advertising (recital 47 GDPR). Customers can object to the use of their e-mail address for advertising purposes at any time without incurring additional costs, for example via the link at the end of each e-mail or by sending an e-mail to our above-mentioned e-mail address.

Interested parties have the option to subscribe to a free newsletter. We process the data provided during registration exclusively for sending the newsletter. Subscription takes place by selecting the corresponding field on our website, by ticking the corresponding field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 para. p. 1 lit. a GDPR. Consent can be revoked at any time, e.g. by clicking the corresponding link in the newsletter or notifying our e-mail address given above. The processing of the data until revocation remains lawful even in the event of revocation.

Based on the consent of the recipients (Art. 6 para. 1 s. 1 lit. a GDPR), we also measure the opening and click-through rate of our newsletters to understand what is relevant for our audience.

Application users can log in to our applications using a single sign-on procedure. In doing so, they use the login data already created for another provider. The prerequisite is that the application user is already registered with the respective provider. When an application user logs in using a single sign-on procedure, we receive information from the provider that the application user is logged in with the provider and the provider receives information that the application user is using the single sign-on procedure on our website. Depending on the settings of the application user in his account on the provider's site, additional information may be provided to us by the provider. The legal basis of this agreement is the consent of the Application user who logs in to our site with the account (Art. 6 para. 1 s. 1 lit. a GDPR). The provider of the procedure is

Google Ireland Limited
‍Gordon House, Barrow Street
Dublin 4, Ireland
Privacy Notice: https://policies.google.com/privacy

Application users can log in to our applications using a single sign-on procedure. In doing so, they use the login data already created for another provider. The prerequisite is that the application user is already registered with the respective provider. When an application user logs in using a single sign-on procedure, we receive information from the provider that the application user is logged in with the provider and the provider receives information that the application user is using the single sign-on procedure on our website. Depending on the settings of the application user in his account on the provider's site, additional information may be provided to us by the provider. The legal basis of this agreement is the consent of the application user who logs in to our site with the account (Art. 6 para. 1 s. 1 lit. a GDPR). The provider of the procedure is

Microsoft Corporation
One Microsoft Way
Redmond, WA 98052-6399 USA
Privacy Notice: https://privacy.microsoft.com/de-de/privacystatement

Application users can log in to our applications using a single sign-on procedure. In doing so, they use the login data already created for another provider. The prerequisite is that the application user is already registered with the respective provider. When an application user logs in using a single sign-on procedure, we receive information from the provider that the application user is logged in with the provider and the provider receives information that the application user is using the single sign-on procedure on our website. Depending on the settings of the application user in his account on the provider's site, additional information may be provided to us by the provider. The legal basis of this agreement is the consent of the application user who logs in to our site with the account (Art. 6 para. 1 s. 1 lit. a GDPR). The provider of the procedure is

Apple Inc.
One Apple Park Way
Cupertino, CA 95014, United States
Privacy Notice: https://www.apple.com/legal/privacy/en-ww/

Application users can log in to our applications using an email address and password directly. In doing so, this information is securely stored by Auth0.  When an application user logs in using email address and password, we receive information from the provider that the application user is logged in with the provider  .  The legal basis of this agreement is the consent of the application user who logs in to our site with the account (Art. 6 para. 1 s. 1 lit. a GDPR).  The provider of the procedure is

Auth0, Inc.
10900 NE 8th Street, Suite 700
Bellevue, WA 98004, USA
Privacy Notice: https://auth0.com/privacy

For the processing of payments, we use payment processors who are themselves data controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 s. 1 lit. b GDPR).These payment processors are:

Stripe Payments Europe, Ltd.
25 North Wall Quay
Dublin 1, D01 H104, Ireland
Privacy Notice: https://stripe.com/en-de/privacy

SevDesk GmbH
Im Unteren Angel 1
77652 Offenburg, Germany
Privacy Notice: https://sevify.app/help/app/privacy

Our website sets cookies. Cookies are small text files that are stored in the web browser on the end device of an application user. Cookies help to make the site more user-friendly, effective and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter "Technically Necessary Cookies"), the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in providing customers and other Application users with a functional website.

Specifically, we set technically necessary cookies for the following purpose or purposes:
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- Cookies that apply language settings
- Cookies that store log-in data

We use HubSpot to manage our enterprise relationships and as an integration endpoint for users. The provider is
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HubSpot, Inc.
25 First Street
Cambridge, MA 02141, USA

For enterprise relationship management, the provider processes contact data (e.g. e-mail addresses, telephone numbers), meta/communication data (e.g. emails, meeting notes) and contractual data (e.g. contract durations, price information) in the USA.
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For integration, the processing only occurs after the user has provided explicit consent and connected their Bliro account to their HubSpot account.  The provider processes personal information related to the user as name and email address. Furthermore, the provider processes meeting summaries that have actively and explicitly been sent from Bliro to the provider following user action.The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in sufficiently authenticating users of our applications.
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The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy notice at https://legal.hubspot.com/privacy-policy.

We use Intercom to communicate with users. The provider is
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R&D Unlimited Company
2nd Floor, Stephen Court, 18-21 St. Stephen's Green
Dublin 2, Ireland
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The provider processes usage data (e.g. web pages visited, interest in content, access times), contact data (e.g. e-mail addresses, telephone numbers), and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in optimizing the interaction with our webApplication users.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy notice at https://www.intercom.com/legal/privacy.

We use Microsoft Azure to manage application infrastructure. The provider is
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Microsoft Corporation
One Microsoft Way
Redmond, WA 98052-6399 USA
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The provider processes user e-mail addresses, user-provided integration tokens, and all assets associated with the user’s usage of the application.  For calls, this includes call transcripts, summaries, insights and manual notes.  For telemetry, this includes IP addresses, device information, and user interactions.
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For outlook calendar integration, the processing only occurs after the user has provided explicit consent and connected their Bliro account to their Microsoft account.  This includes user e-mail addresses and calendar entries.
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The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in sufficiently authenticating users of our applications.
All data is processed in the West Central Germany region.We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy notice at https://privacy.microsoft.com/de-de/privacystatement.

We use Salesforce as an integration endpoint for users.  The provider is
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Salesforce Inc.
C/O THE CORPORATION TRUST COMPANY
CORPORATION TRUST CENTER, 1209 ORANGE ST
WILMINGTON, Delaware, 19801, United States
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The processing only occurs after the user has provided explicit consent and connected their Bliro account to their Salesforce account.  This includes personal information related to the user as name and email address. Furthermore, the provider processes meeting summaries that have actively and explicitly been sent from Bliro to the provider following user action.
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The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in sufficiently authenticating users of our applications.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy notice at https://www.salesforce.com/company/legal/privacy/.

We use Slack as an integration endpoint for users.  The provider is
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Slack Technologies, LLC
50 Fremont Street
San Francisco, CA, 94105, United States
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The processing only occurs after the user has provided explicit consent and connected their Bliro account to their Slack account.  This includes personal information related to the user as name and email address. Furthermore, the provider processes meeting summaries that have actively and explicitly been sent from Bliro to the provider following user action.
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The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in sufficiently authenticating users of our applications.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy notice at https://slack.com/trust/privacy/privacy-policy.

You can connect Bliro with your Google account via Google’s OAuth 2.0 and Gmail API. As such, your data is also subject to Google’s API Services User Data Notice. We access your Google data only after you grant explicit permission through the Google OAuth consent screen. You can revoke our access at any time via your Google Account settings. We share data with Google only as needed for the integration (for example, extracting information from your Google calendar for better meeting notes results). We affirm that Google Workspace APIs are not used to develop, improve, or train generalized AI and/or ML models.

We use Amplitude to monitor user usage information. The provider is
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Amplitude, Inc.
201 Third Street, Suite 200
San Francisco, CA 94103, United States
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The provider processes user e-mail addresses, device information, and user interactions. This includes call transcripts and AI prompts.
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The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in sufficiently authenticating users of our applications.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy notice at https://amplitude.com/privacy.

We use Sentry to monitor technical telemetry. The provider is
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Functional Software, Inc.
45 Fremont Street, 8th Floor
San Francisco, CA 94105
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The provider processes IP addresses, device information and user interactions, such as error messages received and actions taken within the application.
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The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in sufficiently authenticating users of our applications.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy notice at https://sentry.io/privacy/.

We use Speechmatics to transcribe speech during calls. The provider is
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Cantab Research Limited
296 Cambridge Science Park, Milton Road
Cambridge, CB4 0WD, United Kingdom
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The provider processes call participant speech, including any and all personal information that may be spoken while transcription is active.
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The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in sufficiently authenticating users of our applications.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy notice at https://www.speechmatics.com/legal/privacy-policy.

We use MongoDB to store and process all data within the Bliro application. The provider is
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MongoDB, Inc.
229 W. 43rd Street, 5th Floor
New York, NY 10036
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The provider processes user email addresses, device information and user interactions, including full call transcripts, AI prompts and responses, and integrations.
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The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in sufficiently authenticating users of our applications.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy notice at https://www.mongodb.com/legal/privacy/privacy-policy.

Bliro Applications are distributed on several platforms, based on which application is being requested.  These scenarios are for distribution only and we do not process or control any user data that may be captured by these platforms for this purpose.

We use Amazon Web Service to distribute versions of the Bliro Desktop and Mac applications. The provider is
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Amazon Web Services Germany GmbH
Teutonenstraße 35
14129 Berlin, Germany
Privacy Notice: https://aws.amazon.com/privacy/

We use Apple App Store to distribute versions of the Bliro iPhone application. The provider is
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Apple Distribution International Ltd. – German Branch
Arnulfstraße 19
80335 München, Germany
Privacy Notice: https://www.apple.com/legal/privacy/en-ww/

We are represented in social media networks in order to present our organization and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies access the data.

If users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

We reserve the right to change this privacy notice with effect for the future. A current version is always available at trust.bliro.io.

If you have any questions or comments regarding this privacy notice, please feel free to contact us using the contact information provided in section 1.1 of this document.