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        ROBOT FRAMEWORK PRIVACY POLICY
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      <h1 style="margin-top: 3rem; padding-top: 1.5rem">ROBOT FRAMEWORK PRIVACY POLICY</h1><br>
      This Privacy Policy is applicable to the personal data processed by Robot Framework Foundation("<b>Robot Framework</b>" or "<b>we</b>") relating to the users of the  <a href="https://robotframework.org/">Robot Framework website</a>  and  the  <a href="https://robocon.io/">Robocon website</a> (hereinafter jointly refered to as “<b>Service</b>”)<br><br>

      This Privacy Policy is also applicable to personal data processed by Robot Framework in regard to the representatives of our member organizations and other partners, including personal data collected in connection to our marketing activities and events. All of the aforementioned data subjects are hereinafter collectively referred to as “<b>Users</b>” or “<b>you</b>.”<br><br>

      The purpose of this Privacy Policy is to provide you with information about the processing of yourpersonal data in accordance with the General Data Protection Regulation 2016/679 (GDPR).<br><br>

      Please note that this Privacy Policy only applies to processing carried out by Robot Frameworkas a data controller. This Privacy Policy does not address, and we are not responsible for, the privacy and data processing practices of any third parties.<br><br>

      In regard to Robot Framework documentation available via Github, Github acts as the datacontroller for any user information. For more information, please see the <a href="https://help.github.com/en/github/site-policy/github-privacy-statement">Github Privacy   Statement</a>. The payment transactions for purchases of Robot Framework gear are facilitated via the Reddy platform. For more information please see the <a href="https://shop.robotframework.org/privacy-policy">Reddy Privacy Statement</a>.<br><br>

      This Privacy Policy may be updated if required in order to reflect the changes in data processing practices or otherwise. The current version can be found on our <a href="https://robotframework.org/#/privacypolicy">website</a>. We will not make substantial changes to this Privacy Policy or reduce your rights under this Privacy Policy without providing a notice thereof.<br><br><br>

      <h4>CONTACT DETAILS</h4>
      Robot Framework Ry<br>
      Business ID: 2754775-1<br>
      Pohjoinen Rautatiekatu 25, 00100 Helsinki<br>
      <a href="https://robotframework.org/">https://robotframework.org/</a><br>
      Contact person: René Rohner, Chairman of The Board, +49 173 7089491<br>
      chair@robotframework.org<br><br><br>

      <h4>PERSONAL DATA PROCESSED AND SOURCES OF DATA</h4>
      We collect two types of information concerning our Users: (i) User Data; and (ii) Analytics Data.<br><br>

      User Data is primarily received directly from you either in connection to your use of the Service or in connection to your interaction with us. In certain cases your personal data may also be directly provided to us by the company or organization you represent.<br><br>

      Analytics Data is collected automatically as you use the Service. Although we do not normally use Analytics Data to identify individuals, sometimes individuals can be recognized from it, either alone or when combined or linked with other data. In such situations, Analytics Data shall also be considered to be personal data under applicable laws and we will treat the combined data as personal data.<br><br>

      User Data and Analytics Data typically consist of the following categories of data:<br><br>

      <u>User Data</u>
      <ul>
        <li>Name;</li>
        <li>Organisation and work title;</li>
        <li>Contact information (such as email address, postal address and phone number);</li>
        <li>Any direct correspondence with Robot Framework;</li>
        <li>Information relating to your participation to our events, such as event registrations, attendance and cancellations, event feedback and special dietary restrictions you may provide;</li>
        <li>Purchase and delivery information for orders of <a href="https://shop.robotframework.org/">Robot Framework gear</a>;</li>
        <li>Direct marketing opt-outs and opt-ins.</li>
      </ul>

      <u>Analytics Data</u>
      <ul>
        <li>IP address;</li>
        <li>Device type and model;</li>
        <li>Operating system;</li>
        <li>Time of visit;</li>
        <li>Browser type and version;</li>
        <li>Language settings.</li>
      </ul><br>

      <h4>COOKIES AND ANALYTICS TOOLS</h4>
      We use various technologies to collect and store Analytics Data and other information when you visit our Service, including <a href="https://policies.google.com/privacy/key-terms?hl=en&gl=nl">cookies</a>. These technologies are also used to integrate our social media accounts with the Service.<br><br>

      Cookies are small text files sent and saved on your device that allow us to identify visitors of our websites and facilitate the use of our Service and to create aggregate information of our visitors. The cookies will not harm your device or files. We may use cookies to tailor and improve our Service.<br><br>

      Users may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. For example, the following links provide information on how to adjust the cookie settings on some popular browsers:<br>
      <a href="https://support.apple.com/kb/PH19214?viewlocale=en_US&locale=en_US">Safari</a><br>
      <a href="https://support.google.com/chrome/answer/95647?hl=en&p=cpn_cookies">Google Chrome</a><br>
      <a href="https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies">Internet Explorer</a><br>
      <a href="https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer">Mozilla Firefox</a><br><br>

      Please note that some parts of our Service may not function properly if the use of cookies is refused.
      We use Google Analytics to compile Analytics Data and reports on visitor usage. For an overview of Google Analytics, please visit <a href="https://www.google.com/analytics/">Google Analytics</a>. It is possible to opt-out of Google Analytics with the following browser add-on tool: <a href="https://support.google.com/analytics/answer/181881?hl=en&ref_topic=2919631">Google Analytics opt-out add-on.</a><br><br><br>

      <h4>PURPOSES AND LEGITIMATE GROUNDS OF PROCESSING</h4>
      <ul>
        <li><u>Purposes of processing</u></li>
        <i>To provide our Service and to carry out our contractual obligations (legal ground: performance of a contract and legitimate interest)</i><br>
        We process personal data to be able to offer the Service to our Users and to run and maintain our operations. Personal data may be processed in order to carry out our contractual obligations towards the individual User or towards the organization the User represents. We may use the data for example to process member applications or to process orders of Robot Framework gear.

        <i>For our legal obligations (legal ground: compliance with a legal obligation)</i><br>
        We process personal data to enable us to administer and fulfil our obligations under law. This includes data processed for complying with our accounting obligations and providing information to relevant authorities.

        <i>For claims handling and legal processes (legal ground: legitimate interest)</i><br>
        We may process personal data in relation to claims handling, debt collection and legal processes. We may also process data for the prevention of fraud, misuse of our ervices and for data, system and network security.<br>

        <i>For communication and marketing (legal ground: legitimate interest)</i><br>
        We may process personal data for the purpose of contacting our Users regarding our Service and events and for informing Users of changes in our Service, overall operations or updates to the documentation and tools we provide. We may also process personal data for direct marketing purposes, for example in the form of sending newsletters.<br>

        <i>For quality improvement and trend analysis (legal ground: legitimate interest)</i><br>
        We may process information regarding your use of the Service to improve the quality of our Service, for example by analysing any trends in the use of our Service. Similarly we may process any feedback provided by you to improve our operations in general. Where possible, we will do this using only aggregated, non-personally identifiable data.

        <li><u>Legal grounds for processing</u></li>
        <li class="ml-4">We primarily process personal data on a contractual basis. For individuals acting asrepresentatives of our customer or partner organizations, personal data is primarilyprocessed based on our legitimate interest whilst fulfilling our contractual obligationstowards the organisations they represent.</li>
        <li class="ml-4">We may also process personal data based on our legitimate interests, for example in connection with analytics and marketing. When choosing to use your data on the basis of our legitimate interests, we carefully weigh our own interests against your right to privacy.</li>
        <li class="ml-4">In certain cases you may be requested to grant your consent for the processing of your personal data. In this event, the legal ground for such processing is your consent. You may withdraw your consent at any time.</li>
      </ul><br>

      <h4>INTERNATIONAL TRANSFERS</h4>
      Robot Framework stores personal data primarily within the European Economic Area. However, we have service providers in several geographical locations. As such, we, our service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area or outside of your domicile.<br>
      We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which it is processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers based on the <a href="https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en">Standard Contractual Clauses</a> or through other appropriate safeguards, such as the <a href="https://www.privacyshield.gov/welcome">Privacy Shield Framework</a>.<br><br><br>
      <h4>PERSONAL DATA RECIPIENTS</h4>
      We do not share personal data with third parties outside of Robot Framework’s organizationunless one of the following circumstances applies:
      <ul>
        <li><i>For legal reasons</i></li>
        <li>We may share personal data with third parties outside of our organization if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, property or safety of Robot Framework, our Users or the public in accordance with the law. When possible, we will inform you about such transfer and processing.</li>
        <li><i>To authorized service providers</i></li>
        <li>We may share personal data to authorized service providers who perform services for us(including data storage, sales, marketing and support services). Our agreements with ourservice providers include commitments that the service providers agree to limit their useof personal data and to comply with privacy and security standards at least as stringentas the terms of this Privacy Policy.</li>
        <li><i>For other legitimate reasons</i></li>
        <li>If Robot Framework is involved in an acquisition or similar reconstructing, we maytransfer personal data to the third party involved. However, we will continue to ensure theconfidentiality of all personal data. We will give notice to those concerned when thepersonal data are transferred or become subject to a different privacy policy as soon asreasonably possible.</li>
        <li><i>With explicit consent</i></li>
        <li>We may share personal data with third parties outside of our organization for otherreasons than the ones mentioned before, when we have your explicit consent to do so.You have the right to withdraw this consent at all times.</li>
      </ul><br>

      <h4>STORAGE PERIOD</h4>
      <ul>
        <li>Robot Framework does not store personal data longer than is legally permitted and necessary for purposes of providing the Service or the relevant parts thereof, or for another individual purpose for which your personal data is being processed. The storage period depends on the nature of the information and the purposes of processing. The maximum period may therefore vary per use.</li>
        <li>We will store Analytics Data relating to the Service 50 months</li>
      </ul><br>

      <h4>YOUR RIGHTS</h4>
      <ul>
        <li><i>Right to access</i></li>
        <li>You have the right to access your personal data processed by us. You may contact us and we will inform what personal data we have collected and processed regarding you.</li>
        <li><i>Right to withdraw consent</i></li>
        <li>In case the processing is based on a consent you have granted to us, you may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use our Service. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.</li>
        <li><i>Right to rectify</i></li>
        <li>You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us.</li>
        <li><i>Right to erasure</i></li>
        <li>You may also ask us to erase your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.</li>
        <li><i>Right to object</i></li>
        <li>You have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of the Service or for compliance with a legal obligation. If you object to the further processing of your personal data, this may lead to fewer possibilities to use the our Service.</li>
        <li><i>Right to restriction of processing</i></li>
        <li>You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use our Service.</li>
        <li><i>Right to data portability</i></li>
        <li>You have the right to receive your personal data from us in a structured and commonly used format and to independently transmit those data to a third party.</li>
        <li><i>How to use the rights</i></li>
        <li>The above mentioned rights may be used by sending a letter or an e-mail to us on the addresses set out above. We may request the provision of additional information necessary to confirm your identity.</li>
        <li>We reserve the right to reject requests that are unreasonably repetitive, excessive or manifestly unfounded.</li>
      </ul><br>


      <h4>DIRECT MARKETING</h4>
      <ul>
        <li>Notwithstanding any consent granted beforehand for the purposes of direct marketing, you have the right to prohibit us from using your personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the unsubscribe possibility offered in connection with any direct marketing messages.</li>
      </ul><br>

      <h4>INFORMATION SECURITY</h4>
      <ul>
        <li>We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability restore the data. We regularly test our systems, and other assets for security vulnerabilities.</li>
        <li>Should despite of the security measures, a security breach occur that is likely to have negative effects on your privacy, we will inform you and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.</li>
      </ul><br>

      <h4>LODGING A COMPLAINT</h4>
      <ul>
        <li>In case you consider our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection.</li>
      </ul>

      In Finland, the local supervisory authority is the Data Protection Ombudsman (<u>https://www.tietosuoja.fi</u>).

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