TypingDNA SRL1 and TypingDNA Inc.2 (referred to collectively and individually as “TypingDNA”,
“we” or “us”) realize that our platform, https://www.typingdna.com/
(the “Website”) and any
related services (the “Services”) we offer, including mobile applications, can only work if we build
a
relationship of trust with our users.
We control the purpose for which, and the manner in which, Personal Information (as defined
below) about individuals accessing the Website, trying or using our Services and/or respectively
being targeted by us for marketing purposes in relation to our provision of the Services is
processed. We are therefore the data controller under applicable data privacy laws.
Pursuant to Art. 26 of the General Data Protection Regulation3 (“GDPR”), TypingDNA SRL and
TypingDNA Inc. are joint controllers with respect to Personal Information collected via the Website
or otherwise processed by us in relation to the Website and/or our Services. Our contact details are
set out at the end of this privacy policy (“Privacy Policy”).
This Privacy Policy outlines the categories of Personal Information the Website collects from you,
that you provide to us, or that you authorize to be provided to us or that we collect from third party
resources for marketing or other legitimate purposes in relation to our Services, the purposes for
which your Personal Information might be used and the safeguards we put in place in the course of
our relationship with you to protect your Personal Information.
By continuing to use our Website and/or our Services, you expressly consent to our processing of
your Personal Information (as defined below) as described in this Privacy Policy, and to being
bound by the provisions hereof.
We are a technology company developing passive authentication and typing biometrics API (Application Programming Interfaces). Our mission is to improve security without compromising user experience. Our technology is the most available online biometric technology – it works with any keyboard, on any device and does not need more than one previous sample to start working. We provide typing biometrics authentication as a service, an API that anyone can use for 2 Factor Authentication (2FA) and fraud prevention purposes
TypingDNA provides a number of products and Services, as follows:
So we are clear about the terminology we are using, “personal data" means any information
describing or relating to an identified or identifiable individual (where an identifiable individual is
an individual who can be identified, directly or indirectly, in particular by reference to an identifier
such as a name, an identification number, location data, an online identifier or to one or more
factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of
that individual).
When we use the phrase “Personal Information” in this Privacy Policy, we mean collectively the
following categories of personal data that may be requested by us and provided by you; in various
forms on our Website (such as demo forms, registration forms, etc.), you may be asked to enter
Personal Information such as: first/last name, password, email address, phone number, Skype ID,
Internet Protocol (IP) address, location data, country, gender, date of birth, nationality, state or
province, age, company name, company website, typing biometrics, device type, device fingerprint,
cursor movements, pointing devices movements (e.g. mouse, touchpad, touchscreen, trackpad,
others), payment details (e.g. bank account number, credit card number, bank).
We may process your Personal Information under this Privacy Policy:
When you register on our Website to use our Services, or even a Demo version thereof, you will
need to provide personal information about yourself during the account creation/demo session –
this Personal Information includes: name/surname, your organization/company details (name and
website), age, job title/position, email address, phone number, line of work/industry and your
typing biometric. We can also collect and further process: your typing pattern (typing biometrics),
Internet Protocol (IP) address, location data, device type, device fingerprint, cursor movements,
pointing devices movements (e.g. mouse, touchpad, touchscreen, trackpad, others).
We collect such Personal Information from you when you register on our Website, subscribe to a
newsletter, try a demo, respond to a survey, fill out a form or enter information on our Website, or
when you provide us with feedback on our products or Services. If you are a Prospect, we collect
and process such further Personal Information about you (as stated above) from public sources as
mentioned above.
To help keep our databases current and to provide you the most relevant content and experiences,
we may combine information provided by you with information from other sources, in accordance
with applicable law. For example, from these sources, we may learn about the size, industry, and
other information about the company you work for.
Also, we use automated systems to analyse your content using techniques such as machine learning
in order to improve our Services and the Websites. This analysis may occur as the content is sent or
received using an online feature of the Website or any of our Services or apps, or when the content
is stored on our servers.
Please note that registered clients can use our Services to collect typing biometrics from their own
users.
It is up to the client to decide where and how to store the typing biometrics of its users (and to
apply adequate data privacy and security measures to ensure that such data is maintained
confidential and secure from unauthorized disclosure or modification). If the client stores the
typing biometrics of its own users, it is entirely that client’s responsibility to handle such sensitive
information with care and comply with the applicable data privacy laws, in particular regarding the
end user’s consent to the collection, processing and usage of such information by the client and (in
certain cases) by TypingDNA. If we are required to store the typing biometrics of our clients’ end
users, such data is anonymized at our level. We do not associate any biometric data with any
Personal Information from any end-user.
When we refer to “you” in this Privacy Policy, such reference is limited strictly to individuals who
have provided Personal Information directly to us via our Website and/or otherwise through the
use of the Services, or to Prospects whom we identify and target for marketing-related
communications.
When we use the phrase “Anonymous Information” in this Privacy Policy, we mean information
rendered anonymous in such a way that it cannot or can no longer be used to personally identify an
individual.
Like many companies, we monitor the use of the Website by collecting aggregate information. No
personally identifiable data is collected in this process. Typically, we collect information about the
number of visitors to the Website and the originating domain name of the visitor's Internet Service
Provider. Also, we may collect non-personal information about your use of the Website and/or the
Services such as, IP address, log files, user activity, time stamps, etc. Finally, we may also collect
technical information transmitted by your device, including certain software and hardware
information (e.g. the type of browser and operating system your device uses, language preferences,
access time and the domain name of the website from which you linked to Website etc.).
This information is typically used to improve the usability, performance and effectiveness of the
Platform.
Important note: For the avoidance of doubt, any aggregate, non-personal or technical information
collected, which is or may be connected or linked to the identities of the relevant users, shall be
deemed
as ‘personal data’ (as such term is defined in the applicable data privacy laws) as long as such
connection or linkage exists or may be made using all the means reasonably likely to be used. In such
situations, the provisions in this Privacy Policy regarding personal data shall apply mutatis mutandis
to the aggregate, non-personal or technical data mentioned herein. For clarity purposes, as an
example, if we have suf icient information to link an IP address to a particular individual user (e.g.,
through login details, cookies, or any other information or technology) then that IP address is personal
data, and is subject to the full protections of data protection law and this Privacy Policy.
Domains and subdomains that contain typingdna.com are our websites and the TypingDNA Authenticator is one of our applications that is also subject to this Privacy Policy.
TypingDNA requires that you submit certain Personal Information about yourself, including your
email address and other Personal Information as stated above, when you apply for a Demo version
of our Services and/or register an account on the Website. This information is required for you to
be able to use the Website and therefore if you do not provide this information you will not be able
to use the Website.
In the course of registering for or using the Website and/or the Services, we may prompt you to
provide additional Personal Information about yourself including your name, alternate email
addresses, year of birth, and your city, state or country of residence, and you will also be asked to
answer a few questions to help make the Website and/or the Services more useful to you. When
you communicate with us through our Platform, we may collect and store any information that is
contained in your communications with us. We do not automatically include or display Personal
Information in your shared profile data.
We may collect and use the Personal Information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the Website and otherwise use our Services and/or apps, or use certain other site features in the following ways:
We will limit Personal Information that we collect and further process about you only to what is
limited for the purposes of processing mentioned above (or other limited purposes which are
consistent with the primary purposes mentioned above). We will not use your Personal
Information in a manner which is incompatible with the purposes for which it has been initially
collected and/or authorized by you, unless we obtain your prior consent. Examples of compatible
processing purposes may include those that reasonably serve customer relations, compliance and
legal considerations, auditing, security and fraud prevention and preserving or defending our legal
rights etc.
We collect, process, use and, as applicable, disclose Personal Information related to you on the basis
of the following legal grounds under the GDPR:
By using the Website and/or signing up for any of the products or Services offered by TypingDNA,
you agreeing to the terms of this Privacy Policy. This Privacy Policy is a legally binding agreement
between you (and your client, employer or another entity if you are acting on their behalf) as the
user of the Services and TypingDNA and its Affiliates. If we add any new features or tools to our
Services, they will also be subject to this Privacy Policy.
We may use your Personal Information based on your explicit consent for the following purposes:
(i) to provide you with the Website (including any related apps, Services and functionalities
thereof); (ii) to improve the quality of the Website and user experience; (iii) to fulfill any request
you make; (iv) to communicate with you; (v) to contact you regarding other products and Services
we offer if you have requested such information; (vi) or as otherwise directed by you.
To the extent necessary, we may also process your Personal Information to protect legitimate
interests of our own and of third parties such as (i) to resolve disputes and/or troubleshoot
problems; and (ii) to verify your compliance with your obligations in our Terms of Use or other
TypingDNA policies. When we process your Personal Data to meet our legitimate interests, we
balance our legitimate interests against your fundamental rights and freedoms and we implement
appropriate safeguards to ensure that your interests, rights and freedoms do not override our
legitimate interests. For more information about the balancing tests that we have carried out,
please contact us at dataprivacy@typingdna.com.
From time to time, you may be offered the opportunity to respond to requests for additional
information from TypingDNA, including but not limited to surveys, polls, questionnaires, and
feedback.
When we communicate with you regarding the products and Services we offer or develop, you will
be given the opportunity in each communication to unsubscribe and prevent future
communications of that sort. Please note that emails we send you may include a technology (called
a web beacon) that tells us whether you have received or opened the email or clicked a link in the
email.
If you do not want us to collect this information from our marketing emails, or if you wish to
unsubscribe from direct marketing communications from us, you may write to us at
dataprivacy@typingdna.com requesting the same. We will cease
using your Personal Information
for direct marketing purposes once you have requested us to do so.
Additionally, we may use your Personal Information to create Anonymous Information including
for use in future scientific research, product development and market research, if you agree to let us
do so.
Note: for the avoidance of doubt, TypingDNA does not use your Personal Data (including, in
particular, your typing pattern) for the purposes of an automated decision-making process or for
profiling.
TypingDNA uses the Website to facilitate your engagement in and use of the Website and/or the
Services we provide.
We may disclose your Personal Information: (a) to third party vendors/suppliers who help us
provide the Website and/or the Services; (b) to third parties to whom you ask us to send Personal
Information, including other users to whom you authorize us to provide certain details of your
Personal Information; (c) as required by law, such as to comply with a subpoena or otherwise in
response to a lawful request by public authorities (including to meet national security or law
enforcement requirements), or similar legal process when we believe in good faith that disclosure
is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or
respond to a government request; (d) to a parent company, any subsidiaries, joint ventures, or
other companies under common control with us (collectively, “Affiliates”), in the event we have
such Affiliates now or in the future, in which case we will require our Affiliates to honor this Privacy
Policy, or (e) to a company that merges with us, acquires us, or purchases our assets, or a successor
in interest in bankruptcy, in which case such company may continue to process your Personal
Information as set forth in this Privacy Policy.
We will share your Personal Information with third parties only in the ways that are described in
this Privacy Policy, only to the extent necessary as per the applicable purpose of the disclosure and
in strict compliance with applicable data privacy laws (including by observing the requirement to
conclude compliant data processing agreements with any third party processor carrying out their
tasks on our behalf and upon our instructions). We do not otherwise share or sell your Personal
Information with or to third parties. We may use and disclose Anonymous Information without
restriction.
We do not and will not share, disclose, sell, rent, or otherwise provide Personal Information to
other companies for the marketing of their own products or services.
If you do not want us to disclose your Personal Information to a third party, please write to us at
dataprivacy@typingdna.com in this sense. We will take all
measures which may be feasible to give
effect to such request, but may continue to disclose your Personal Information to a third party
acting as an agent/data processor performing tasks on our behalf and under our instructions, only
to the extent strictly required for such operations.
Third parties to which we may disclose your Personal Information may be located within the
European Union and elsewhere in the world (including the United States). As a result, your
Personal Information may be transferred to countries outside of the country where the Personal
Information was collected to countries whose data protection laws may be less stringent than the
laws in your country.
TypingDNA will ensure that suitable safeguards are in place to protect your Personal Information
and that the transfer of your Personal Information complies with applicable data protection laws.
For the avoidance of doubt, please note that TypingDNA Inc. is a Delaware corporation that is
enrolled in the EU-US Privacy Shield mechanism (for more details please see here:
https://www.privacyshield.gov/welcome).
Where required by applicable data protection laws, we will ensure that service providers (including
other associated companies) sign standard contractual clauses as approved by the European
Commission or other supervisory authority with jurisdiction over the relevant data exporter. You
can obtain a copy of any standard contractual clauses in place, which relate to transfers of your
Personal Information by contacting dataprivacy@typingdna.com,
although some details may be
redacted for confidentiality reasons.
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g.
the prevention or detection of crime), our interests (e.g. the maintenance of legal privilege) or
rights and freedoms of others, as provided by the GDPR and the EU-US Privacy Shield principles
(please see our dedicated Section on this below).
While we will make good faith efforts to provide you with access to your Personal Information, we
may deny or limited access to such Personal Information where: this would interfere with the
execution or enforcement of the law or with private causes of action (including the prevention,
investigation or detection of offences or the right to a fair trial); the legitimate rights and interest of
others would be violated through such disclosure; this would prejudice the confidentiality
necessary in monitoring, inspection or regulatory functions connected with sound management, or
in future or ongoing negotiations involving us. We will of course endeavour to offer you an
adequate explanation of the necessity, and reason for, restricting access in the circumstances
mentioned above.
If you exercise any of these rights, we will check your entitlement and respond without undue
delay, but not later than within a month. In complex cases or at times of receiving numerous
requests, this period may be extended by two further months of which we will inform you.
To review or update your Personal Information including user information to ensure it is accurate,
please write to us at dataprivacy@typingdna.com informing us
of any changes that may need to be
made in respect of your Personal Information and we will update such information on your behalf
and in our systems.
If you wish to delete your TypingDNA account, please write to us at
dataprivacy@typingdna.com requesting that your account be
deleted and we will proceed with this
deletion on your behalf and in our systems.
Please note that once you delete your account you will no longer be able to enjoy the full
functionality of the Website and/or (part or all) of the Services we provide. Certain information is
necessary in order for us to provide the Website; therefore, if you delete such necessary
information you will not be able to use the Website and/or the Services.
Please remember, however, if we have already disclosed some of this information to third parties,
we cannot access that information any longer and cannot force the deletion or modification of any
such information by the parties to whom we have made those disclosures. We will of course comply
with any legal obligation we may have to notify them of your request.
Please note that even though you may request the deletion of your Personal Information by us, we
may be required (by law or otherwise, such as to prevent fraud, resolve disputes, or troubleshoot
problems) to keep this information and not delete it, or to keep this information for a certain time,
in which case we will comply with your account deletion only after we have fulfilled such
requirements. When you delete your account, Personal Information will be deleted from the active
database, but (limited) Personal Information may remain in our archives where legally permitted.
If you have unsubscribed from receiving marketing information from us, we will continue to
maintain your Personal Data for any other purpose for which we still have legal grounds for
processing such Personal Data (such as the performance of a contract, for the purposes of
complying with a legal obligation or when the processing is necessary for the purpose of a
legitimate interest of us). In certain cases, if no other legal grounds exist, we will maintain limited
Personal Data (such as your email address) about you on record so as to be able to ensure for the
future that such marketing communications are no longer sent to you.
Please note that any processing of your Personal Data prior to the deletion of your account with us,
or your request that we no longer contact you for direct marketing purposes will remain valid
under the legal grounds then prevailing.
You can exercise any of your rights as stated above, by sending us a request to
dataprivacy@typingdna.com. We will endeavor to respond to any
such request as soon as possible,
and in any event within the legal deadline.
The security of your personal information is important to us. We use appropriate technical and
organizational methods to protect the Personal Information submitted to, or otherwise processed
by, us, both during transmission and once we receive it from loss, misuse or unauthorized access,
disclosure, alteration and destruction, taking into account the risks involved in the processing and
the nature of the Personal Information.
We take great care in implementing and maintaining the security of the Website, the Services we
provide and of your Personal Information. We have put in place appropriate technical and
organizational measures to protect your Personal Information against accidental or unlawful
destruction, loss, alteration, unauthorized disclosure or access and against all other unlawful forms
of processing, in accordance with the law. In addition, we employ industry standard procedures and
controls to ensure the safety of your personal data, such as: secure network typology which
includes Firewall systems; encrypted communication, authentication and access control, external
and internal audit tests, etc.
Your Personal Information (including typing biometrics) is stored on virtual servers hosted by
different cloud services and third party SaaS (Software as a Service) providers, in a secured
database behind secured networks and is only accessible by a limited number of persons who have
special access rights to such systems and are required to keep the information confidential. In
addition, all sensitive information you supply, and which is being transferred between the browser
and the server is encrypted via Secure Socket Layer (SSL) technology. We store sensible data
encrypted via AES256 (Advanced Encryption Standard 256).
We implement a variety of security measures when a user enters, submits, or accesses their
information to maintain the safety of your personal information. We do not use vulnerability
scanning and/or scanning to PCI standards.
No method of transmission over the Internet, or method of electronic storage, is 100% secure,
however. Therefore, although we take reasonable steps to safeguard information, we cannot be
responsible for the acts of those who gain unauthorised access or abuse the Website and we make
no warranty, express, implied or otherwise, that we will prevent such access.
As you use the Website and/or the Services, certain Anonymous Information may be collected and stored via cookies and similar technologies,
such as your Internet protocol address, domain names, browser type, click-stream data, and access times.
A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on this Website.
We do not link the information we store in cookies to any Personal Information you submit while on our site without your express consent.
We use cookies to:
We may also use trusted third-party services that track this information on our behalf.
We may use both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate our site.
A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time.
We may also set persistent cookies to store your passwords, so you do not have to enter it more than once. Persistent cookies will enable
us to track and target the interests of our users to enhance the experience on our site.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies.
You do this through your browser settings. Since each browser is a little different, look at your browser's Help Menu to learn
the correct way to modify your cookies preferences. If you disable cookies in your browser, some features will be disabled.
Some of the features that make your Website experience more efficient may not function properly.
We may use the Anonymous Information we collect from you to customize the content and layout of the Website and/or the Services and/or the Services
for you and improve our internal operations of the Service of the Service and the content of our Website. With your opt-in consent, we may combine this
Anonymous Information with your Personal Information such that the information is no longer anonymous.
Google Analytics, Google Ads
These are services of Google Inc. ("Google"). Google Analytics uses so-called "cookies", text files that are stored on your computer and that allow an
analysis of the use of the Website by you. The information generated by the cookie about your use of theise Website and/or the Services and/or the Services
(including your IP address) is transmitted to a Google server in the USA and stored there anonymously. Google will use this information to evaluate your use
of the Website, to compile reports on website activity for website operators and to provide other services related to website activity and Internet usage.
Google may also transfer this information to third parties if required by law or as far as third parties process this data on behalf of Google. Third parties,
including Google, place ads on websites on the Internet. Third-party providers, including Google, use stored cookies to serve ads based on previous visits by
a user to this website. You can prevent the installation of cookies by setting your browser software accordingly; however, please note that in this case you may
not be able to use all features of this Website to the fullest extent. You can also visit the page to disable Google advertising. By using this Website, you
consent to the processing of data about you by Google in the manner and for the purposes set out above.
Twitter Ads
The Website uses cookies and other similar technologies, such as Twitter pixels to measure performance of our Twitter Ads campaigns.
Hotjar
Hotjar is an analytics and feedback tool that we use to understand how our Website is used and improve usability. Hotjar sets cookies to help us track behaviour across pages and to control visitor polls. The cookies carry no personally identifiable information.
Hubspot
HubSpot offers a full platform of marketing, sales, customer service, and CRM software – plus the methodology, resources, and support – for inbound marketing. When you visit our Website, HubSpot's tracking code sets a number of tracking cookies to track Website visitors and contacts. It leaves behind a cookie on your computers that helps HubSpot identify them on future visits.
Linkedin Insight Tag
The LinkedIn Insight Tag allows the collection of data on website visits, including URL, referrer URL, IP address, device and browser properties (user agent), and timestamp. IP addresses are shortened or hashed (if used to reach members across devices). The tool permits the tracking of the behaviour of users after they click on a LinkedIn ad and are redirected to the website of the advertising or promoted company. Conversion measurement allows the measurement, evaluation, and optimisation of the effectiveness of LinkedIn ads for reasons of statistics and market research.
The personal data collected is transmitted to LinkedIn by the LinkedIn Insight Tag and processed by LinkedIn for the purpose of conversion measurement. LinkedIn may provide Us with anonymised reports on conversion measurement. It cannot be ruled out that LinkedIn may link the transmitted personal data with other personal data, e.g., from an existing LinkedIn account. LinkedIn also uses data that does not identify you to improve the relevance of ads and to reach members across devices. It is not excluded that LinkedIn uses corresponding data for further purposes of its own.
The integration of the LinkedIn Insight Tag allows us to place target group-oriented ads on LinkedIn and to obtain real-time information about the professional goals and preferred content of the website visitors.
It cannot be ruled out that the data is transmitted to insecure third countries such as the U.S.
The LinkedIn Insight Tag is also used to display LinkedIn ads to people with whom we have already been in contact (“retargeting”).
If you click on a LinkedIn ad, a cookie for conversion tracking will be stored on your computer.
If you access our website and the cookie has not yet expired, we will be able to recognise that you have clicked on the ad and were thus redirected to our website. LinkedIn as the service provider will receive this information as well.
The lawful basis for the use of the LinkedIn Insight Tag is your consent in accordance with Article 6 (1) (a) GDPR.
For further information on how your data is processed at or by LinkedIn, please visit https://www.linkedin.com/legal/privacy-policy.
The Platform may contain links to websites hosted and operated by companies other than us
(“Third-Party Websites”) to which you can export (part of) your Personal Information on the
Website.
We do not disclose your Personal Information to these Third-Party Websites without your explicit
consent. Note that any information you disclose to Third Party Websites is no longer under our
control and no longer subject to this Privacy Policy.
You should review the privacy policy practices of any such Third-Party Website to understand how
that Third-Party Website collects and uses your Personal Information should you have decided to
disclose your Personal Information to them. We are not responsible for the content or performance
of these Third-Party Websites. We are in no way responsible or liable for the manner in which a
Third-Party Website treats any Personal Information that you choose to provide to such a
Third-Party Website and use of Third-Party Websites is strictly at your own risk.
We may use a third-party tracking service such as Google Analytics to track and analyze
Anonymous Information from users of the Platform. Such third parties may use cookies to help
track user behaviour. The use of cookies by third parties is not covered by this Privacy Policy. We
do not have access or control over these cookies.
We may update this Privacy Policy to reflect changes to our information practices. If we make any
material changes, we will notify you by email (sent to the email address specified in your account)
or by means of a notice on this Website prior to the change becoming effective. We encourage you
to periodically review this page for the latest information on our privacy practices. Continued use of
our Platform following notice of such changes will indicate your acknowledgement of such changes
and agreement to be bound by the terms and conditions of such changes.
Any changes to this Privacy Policy may affect our use or disclosure of Personal Information
collected prior to the changes. If you do not agree to any of the changes, you must notify us prior to
the effective date of the changes that you wish to terminate your account with us. Continued use of
our Platform following such notice of such changes shall indicate your acknowledgement of such
changes and agreement to be bound by the terms and conditions of such changes.
We endeavour to ensure that Personal Information are kept as current as possible and that
irrelevant or excessive data are deleted or made anonymous as soon as reasonably practicable. We
retain Personal Information about you only for as long as it serves a purpose of processing
mentioned in this Privacy Policy. This does not prevent us from processing your Personal
Information for longer periods of time, to the extent such processing reasonably serves other
purposes, including for statistical analysis.
However, some Personal Information may be retained for varying time periods in order to comply
with legal and regulatory obligations and for other legitimate business reasons. We will generally
retain your Personal Information only so long as it is required for purposes for which it was
collected. Where your Personal Information is no longer required, we will ensure it is either
securely deleted or stored in a way which means it will no longer be used by the business.
Subject to the principles set out in the above paragraph, we may delete your account 5 years after
your last accessing of the Website and/or of any of our (current or future) Services, if you do not
wish an earlier deletion of Personal Information. Note: we may continue to use Your typing pattern
if we have used such typing pattern to build the algorithm, to further develop and improve the
algorithm. If we do so, we undertake to anonymise/de-personalise Your typing pattern in such a
way that it can no longer be linked to You and therefore no longer constitute Personal Information
about You.
The Website and our Services are not directed to children and children are not eligible to use our
Website and/or any of our Services.
Protecting the privacy of children is very important to us. We do not collect or maintain Personal
Information from people we actually know are under 18 years of age, and no part of our Website is
designed to attract people under 18 years of age or persons under the age of legal consent in any
jurisdiction (“Legally of Age”).
Do not attempt to access the Website and/or create an account and/or apply for a demo version of
our Services if you are not Legally of Age. If we later learn that a user is not Legally of Age, we will
take steps to remove that user’s information from our databases and to prevent the user from
utilizing the Website and/or any of our Services.
If you are the parent of a legal guardian of a person that is not Legally of Age who has registered on
our Website, or who you believe has otherwise provided Personal Information to us, please contact
us using the details set out at the end of this Privacy Policy to have the information deleted.
Information voluntarily provided by persons not Legally of Age via emails, message boards, chat
sessions etc. may be used by other parties to generate unsolicited emails. We encourage parents
and legal guardians to inform children about how to use the Internet in a safe and responsible
manner.
General remarks
TypingDNA Inc. is a US-based corporation and a self-certified participant under the EU-US Privacy
Shield mechanism for compliance with data protection requirements when transferring Personal
Information from the European Union to the United States. Its certification can be checked in the
Privacy Shield List, available here: https://www.privacyshield.gov/list.
This section of the Privacy Policy regulates TypingDNA Inc.’s additional commitments and
undertakings in accordance with the EU-US Privacy Shield Framework. Please visit the dedicated
website of the EU-US Privacy Shield at https://www.privacyshield.gov/welcome for more
details.
As a participant in the EU-US Privacy Shield mechanism, TypingDNA Inc. is subject to the
investigatory and enforcement powers of the Federal Trade Commission.
Commitment to comply with Privacy Shield principles
TypingDNA Inc. complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S.
Department of Commerce regarding the collection, use, and retention of personal information
transferred from the European Union to the United States. TypingDNA Inc. has certified to the
Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict
between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles
shall govern.
Onward transfers to third parties
Where TypingDNA Inc. transfers your Personal Information to third parties acting as data
controllers, it will only do so on the basis of a contract with such third party controller which
provides that your Personal Information may be processed only for limited and specified purposes
consistent with the consent you have provided to us, and that the recipient will provide at least the
same level of protection of your Personal Information as regulated under the EU-US Privacy Shield
framework. Such contract will further provide that the third-party controller shall be required to
notify us if it makes a determination that it can no longer meet its obligations under the EU-US
Privacy Shield framework, and it shall cease processing your Personal Information or take other
reasonable and appropriate steps to remediate.
In the context of an onward transfer, TypingDNA Inc. shall have responsibility for the processing of
Personal Information which it subsequently transfers to a third party acting as an agent/data
processor on its behalf. TypingDNA Inc. shall remain liable if such agent/data processor processes
such Personal Information in a manner that is inconsistent with the Privacy Shield principles (unless
we are able to prove that we are not responsible for the event giving rise to the damage).
Complaints and Disputes
If you reside in the United States and have a complaint about the manner in which we collect or
process your Personal Information, we encourage you to bring complaints directly to us at
TypingDNA Inc., at the following contact details dataprivacy@typingDNA.com. We undertake to
respond to you not later than 45 days after filing your complaint.
As required under the EU-US Privacy Shield Framework, TypingDNA Inc. must offer a readily
available independent recourse mechanisms, so that any potential complaints and disputes related
to our processing of your Personal Information can be investigated and expeditiously resolved at no
cost to you.
To meet this requirement, TypingDNA Inc. has chosen the International Centre for Dispute
Resolution, the international division of the American Arbitration Association (ICDR-AAASM) to
Resolution, the international division of the American Arbitration Association (ICDR-AAASM) to
resolve this type of disputes. Please go to https://go.adr.org/privacyshield.html for
further details
on how such independent recourse mechanism works and how to file a complaint.
You also have an option to arbitrate any residual claims, in accordance with Privacy Shield Annex I
(available here: https://www.privacyshield.gov/article?id=A-Scope).
Please note that your option
for arbitration may be enforced only if we have failed to resolve your claims/ complaints to your
satisfaction, and this remains the case after availing yourself to the independent recourse
mechanism referred to above.
Representation
For the purposes of Art. 27 GDPR, TypingDNA SRL is hereby appointed as the representative of
TypingDNA Inc. in the territory of the European Union and may be addressed, in addition to or
instead of, TypingDNA Inc. by, in particular, supervisory authorities and data subjects, on all issues
related to personal data processing performed by TypingDNA Inc., for the purposes of ensuring
compliance with the GDPR.
If you have questions or comments about this Privacy Policy, or wish to exercise any of your data
subject rights under the GDPR, or otherwise make any request as specified further in this Privacy
Policy, please contact us at:
dataprivacy@typingdna.com
If you are dissatisfied with our use of your Personal Information or our response to any exercise of
your rights under the GDPR, you have the right to complain to the data protection authority:
http://www.dataprotection.ro/ or avail yourself of the independent recourse mechanism under the
EU-US Privacy Shield Framework, as referred to above. In order to ensure timely resolution, we
encourage you to reach out to us first with respect to any queries, questions or complaints you may
have in relation to our processing of your Personal Information. We will endeavour to respond as soon
as practicable.
Last Updated: October 2022
1 TypingDNA SRL, a Romanian limited liability company headquartered in Romania, Oradea, Str.
Santului 2E, 1st floor, registered with the Trade Registry under no. J5/1153/2016,
unique registration code 36172414;
2 TypingDNA Inc., a US, Delaware company headquartered in 81 Prospect Street, Brooklyn, NY,
11201;
3 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the
protection of natural persons with regard to the processing of personal data and on the free movement of
such data;
