Last updated on 24/05/2018
We want to be sure that we took into account everything important to you, including:
- the information that we collect with your permission,
- how we use that information with your permission and
- the ways You can control how that information is used or shared in order to protect your rights.
1. WHO WE ARE
Final Level, Estonia 10111 Tallinn Kai tn.1
Company registration number 14081574
You also may submit inquiries regarding personal data protection, privacy and security matters to firstname.lastname@example.org.
2. We collect
You may visit our site anonymously.
If you choose to login on our website, next categories of data to and on behalf of you will be processed:
- the latest station which you’re listening
- the latest country you’re browsing
- the latest language you’re selected
- favorite station list
- Your IP number in anonymized form.
- The date and time of the latest login (based on Your consent).
After login You are issued with cryptographic token which is used both as a proof of Your consent and authorisation. This token is stored in Your cookie, and sent with each request by Your browser to ORB.
3. What do we use your information for?
Any of the information we collect from you may be used for one or more of the following purposes:
- To personalize your experience (the information will help ORB better respond to your individual needs);
- To improve our website (ORB continually strives to improve our website offerings based on the information and feedback we receive from our Users);
-To identify you as a an ORB User
-To enable secure login for you in the ORB Service
-To establish a primary channel of communication with you;
-To produce and display cookie declarations
If at any time You would like to stop sharing Your information, You can delete your data after login by clicking on "Delete my Data" or by contacting us at email@example.com.
4. Legal basis
EU General Data Protection Regulation (GDPR)
The processing of your data is either based on your consent or in case the processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract, cf. GDPR art. 6(1)(a)-(b) whatever is may be applicable.
If the processing is based on your consent, you may at any time withdraw your consent by simply deleting your personal data by clicking “Delete my data” (in case of login) or by contacting us at firstname.lastname@example.org.
We do not permit children under 13 years of age (or under 16 years of age for children residing in the EU/EEA) to register and does not knowingly collect any personal information from them. If you are under the age of 13 (or under the age of 16 if you reside in the EU/EEA), please do not register with Us. In the event that we learn affirmatively that we have obtained or collected information from or about children under 13 (or, where applicable, 16) years of age, we will use our best efforts to remove such information from our servers. If you are aware of any child under the age these age limits who have registered with us, please contact our Support Team by emailing at email@example.com.
5. How do we protect your information?
ORB implements the following technical, physical and organizational measures to maintain the safety of your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized use, unauthorized modification, disclosure or access and against all other unlawful forms of processing.
ORB uses distributed system and doing it’s best to provide the best availability possible, but service is provided as is, and ORB doesn’t responsible for any damage which might be caused by interruptions.
All personnel are subject to full confidentiality and any subcontractors and subprocessors are required to sign a confidentiality agreement if not full confidentiality is part of the main agreement between the parties.
The personal data can be only accessed through private network over an encrypted connection and only from the limited set of IPs. Also any access by authorized personnel is logged. We do not store personal information outside of the private servers even temporarily.
ORB will at all times keep you informed about changes to the processes to protect data privacy and security, including practices and policies. You may at any time request information on where and how data is stored, secured and used. ORB will also provide the summaries of any independent audits of the Service (if applicable).
All access to personal data is blocked by default, using a zero privileges policy. Access to personal data is restricted to individually authorized personnel. Authorized personnel are granted a minimum access on a need-to-have basis.
The ability to intervene
ORB enables your rights of access, rectification, erasure, blocking and objection mainly by providing built-in functions for data handling in the ServicE, and also by informing about and offering You possibility of objection when ORB is planning to implement changes to relevant practices and policies.
ORB uses security reports to monitor access patterns and to proactively identify and mitigate potential threats. Administrative operations, including system access, are logged to provide an audit trail if unauthorized or accidental changes are made.System performance and availability is monitored from both internal and external monitoring services.
Personal Data breach notification
In the event that your data is compromised, ORB will notify you and competent Supervisory Authority(ies) within 72 hours by e-mail with information about the extent of the breach, affected data, any impact on the Service and ORB's action plan for measures to secure the data and limit any possible detrimental effect on the data subjects.
- Authorization token (we generate unique cryptographically signed token on every request from the browser, we validate this token and associate it with the User’s name, email and favorites).
- Anonymous configuration:
- current station
- current country
- sound volume
7. Do we disclose any information to outside parties?
We do not sell, trade or otherwise transfer to outside parties any personally identifiable information.
This does not include trusted third parties or subcontractors who assist us in operating our website, conducting our business, or servicing you. Such trusted parties may have access to personally identifiable information on a need-to-know basis and will be contractually obliged to keep your information confidential.
We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect our or others’ rights, property, or safety. Furthermore, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
Legally required disclosure
ORB will not disclose Your data to law enforcement except when instructed by You or where it is required by law. When governments make a lawful demand for Your data from ORB, ORB strives to limit the disclosure. ORB will only release specific data mandated by the relevant legal demand. If compelled to disclose your data, ORB will promptly notify you and provide a copy of the demand unless legally prohibited from doing so.
8. Third party links
At our discretion, we may include or offer third party products or services on our website. These third party sites have separate independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked websites. Nonetheless, we seek to protect the integrity of our website and welcome any feedback about these websites.
9. Where do we store the information?
No stored data will be transferred, backed up and/or recovered by ORB outside of the European Union.
Personal data location
All data are stored in databases and file repositories hosted in Falkenstein, Germany (Hetzner DC5). All data are automatically replicated in real time to secondary hot failover databases and file repositories Falkenstein, Germany (Hetzner DC5).
Databases are continuously backed up to enable restore to any point in time within a retention period of 29 days. Backups are stored on file storage in Falkenstein, Germany (Hetzner DC7).
Installation of software on cloud customer’s system
No installation of software is required to use the Service. The login-protected Service is accessible through a standard web browser.
10. Access, data portability, migration, and transfer back assistance
You may at any time obtain confirmation from ORB as to whether or not personal data concerning you are being processed.You may at any time order a complete data copy, which you may transmit to another controller of the data. Your data will be delivered within 10 working days by ORB as files in CSV format. Logical relations between datasets will be preserved in form of unique identifiers.
11. Request for rectification, restriction or erasure of the personal data
You may at any time obtain without undue delay rectification of inaccurate personal data concerning you.
Restriction of processing personal data
You may at any time request us to restrict the processing of personal data when one of the following applies:
-if you contest the accuracy of the personal data, for a period enabling ORB to verify the accuracy of the personal data;
-if the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; or
-if ORB no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims.
You may without undue delay request the erasure of personal data concerning you, and ORB shall erase the personal data without undue delay when one of the following applies:
-if the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
-if you withdraw your consent on which the processing is based, and where there is no other legal ground for the processing;
-if you object to the processing in case the processing is for direct marketing purposes;
if the personal data have been unlawfully processed; or
if the personal data have to be erased for compliance with a legal obligation in EU or national law.
12. Data retention
Data retention policy
All End User Data, Configuration Data and System Generated Data will be erased after account deletion in 29 days.
Data retention for compliance with legal requirements
You cannot require Us to change any of the default retention periods, except for the reasons for erasure as it is stated above, but may suggest changes for compliance with specific sector laws and regulations.
We use logs all system updates, configuration changes and access to provide an audit-trail if unauthorized or accidental changes are made.You may request a data protection audit performed by an independent third party who is also accepted by ORB. You may pay a Fee associated with the request plus applicable taxes as well as any other costs related to the audit as the case may be.
ORB will cooperate with you in order to ensure compliance with applicable data protection provisions, e.g. to enable you to effectively guarantee the exercise of data subjects’ rights (right of access, rectification, erasure, blocking, opposition), to manage incidents including forensic analysis in case of security breach.
15. Terms of Service
Please also visit our Terms of Service section establishing the use, disclaimers, and limitations of liability governing the use of our web-site.
17. If you not satisfied
Also You may at any time lodge a complaint with a supervisory authority regarding ORB’s collection and processing of your personal data.
The Data Protection Inspectorate will continue to act as the supervisory authority in Estonia.
Data Protection Inspectorate, Väike-Ameerika 19, 10129 Tallinn, Estonia, www.aki.ee
Thank You for choosing ORB and enjoy your streaming!:)