Privacy Policy - Mama CRM

1. Introduction

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation (EU) 2016/679 (commonly known as the “GDPR”), which applies across the European Union and we are responsible as the controller of that personal information for the purposes of those laws.

2. Key terms

It would be helpful to start by explaining some key terms used in this policy:

we, us, our	Oh Mama Software Ltd, a limited liability company incorporated under the law of the Republic of Cyprus, with registration number HE 439348, and registered officed at Amathountos 18, Strovolos, 2020 Nicosia, Cyprus.
personal information	Any information relating to an identified or identifiable individual.
special categories of personal information	Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, Genetic and biometric data. Data concerning health, sex life or sexual orientation.
website	[www.mamamcrm.com ]

3. The scope of this privacy policy

This privacy policy concerns the processing of personal information carried out in the course of services we provide via our website to businesses and organisations in Social Media Marketing Strategy, Social Media Management and Social Media CRM.

In the ordinary course of the services we collect the personal information of:

our actual or prospective customers who are individuals;
if our customer is a legal entity, the individuals who are contact persons or representatives of the legal entity and the individuals who our customer has authorised to use our services;
individuals who request information from us or provide information to us;
individuals who use our website.

Throughout our website and the services we provide, we may enable or assist you to access or link to other websites owned and operated by third parties. These other third-party websites will also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third-party websites, please consult their privacy policies as appropriate.

4. Personal information we collect about you

We may collect, use and store different kinds of personal data about you which we have grouped together as follows:

Identity Data, which includes your first name and last name.
Contact Data, which includes your email address and telephone numbers.
Account Data, which includes account details such as username & password.
Social Media Data which includes your social media account information when you choose to connect/link your social media account with your user account.
Transaction Data which includes details about payments and services you use or have purchased from us.
Employment Data which includes the name of your employer (applies only for individuals that are the contact persons or representatives of the legal entity which has purchased services from us or are users authorised by the legal entity to use the services) and your or your employer’s areas of work and business.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access our website.
Usage Data which includes information about how you use our website and services, any content or information you make public while using our website.
Communication Data which includes details of any communication you have with us or feedback you give us.
Marketing Data which includes your preferences in receiving marketing material from us.

Where we need to collect personal information by law, or in order to be able to provide our services to you or our customer and you fail to provide that information when requested, this may prevent or delay us from providing services.

We do not usually collect any special categories of personal information about you nor do we collect any information about criminal convictions and offences. If there is a good reason to collect or process such personal information, we will inform you of the reason in advance and we will only process such personal information with your explicit consent.

5. How your personal information is collected

We use different methods to collect data from and about you including through:

Directly from you. You may give us your personal data by filling in online forms, by using our services or by corresponding with us. This includes personal data you provide when you:

request a demo or apply for our services;
create an account on our website;
subscribe to use our services; or
provide information, give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Usage Data and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

6. How and why we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

for the performance of our contract with you or to take steps at your request before entering into a contract;
to comply with our legal and regulatory obligations;
for our legitimate interests or those of a third party, which include the proper performance of our contract with our customers and the provision of our services, where your interests and fundamental rights do not override our interests or those of a third party;
where you have given your consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and the legal bases which we rely on to do so:

What we use your personal information for	Type of information	Lawful basis for processing
To register you as a user of our services and create your account, or when you contact us on behalf of a legal entity, to register that entity as our customer	Identity Data Contact Data Account Data Transaction Data Employment Data Social Media Data	Necessary for our legitimate interests (record, deliver and administer our services) Performance of a contract or taking steps at your request before entering into a contract
To respond to your enquiries, fulfil your requests and to contact you where necessary	As relevant to your enquiry or request	Legitimate interests (service our users and prospective users)
To take steps towards providing you with services at your request, to process and fulfil orders and deliver services to you, including managing payments and sending you service communications	Identity Data Contact Data Account Data Transaction Data Employment Data Technical Data Usage Data Social Media Data	Performance of a contract or taking steps at your request before entering into a contract Necessary for our legitimate interests (ensuring that you are provided with the best services we can offer, record, deliver and administer our services and transactions) Necessary to comply with our legal and regulatory obligations
To run, administer and protect our business and our website, including: troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data notifying you of changes to our services, website and our terms and conditions exercising our legal rights enforcing our terms and conditions Ensuring business policies are adhered to, preventing and detecting fraud preventing unauthorised access and modifications to systems statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures	Identity Data Contact Data Account Data Transaction Data Employment Data Technical Data Usage Data	Necessary to comply with our legal and regulatory obligations Necessary for our legitimate interests (for running, administering and protecting our business and our rights, servicing our users, for running, monitoring and improving our business, making sure we are following our own internal procedures and working efficiently, preventing and detecting fraud and unauthorised access, and in the context of a business reorganisation or group restructuring exercise)) Necessary to comply with our legal and regulatory obligations
Gathering and providing information and making filings required by law or relating to audits, enquiries or investigations by regulatory bodies or authorities	Identity Data Contact Data Transaction Data	Necessary to comply with our legal and regulatory obligations Necessary for our legitimate interests (for protecting our rights and defending ourselves in the context of audits, enquiries or investigations administration)
Marketing our business and making suggestions and recommendations to you about services and opportunities that may be of interest to you	Identity Data Contact Data Transaction Data Communications Data Marketing Data	Your consent

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. Promotional and Marketing communications

We may use your personal information to send you updates (usually by email or text message) about our services.

We rely on your consent to send you promotional and marketing communications and we will ask for this consent separately and clearly.

Where you have provided your consent for promotional and marketing communications, you have the right to withdraw it at any time by:

emailing, calling or writing to us—see below: ‘How to contact us’
using the ‘unsubscribe’ link in emails or ‘STOP’ number in text messages

We will always treat your personal information with the utmost respect and never share it for marketing purposes with other organisations outside our group.

8. Who we share your personal information with

We routinely share personal information with:

to your employer or agency engaged by your employer, we may disclose information about you such as Identity Data, Technical Data and Usage Data to assist your employer or the entity in managing its use of the Services (this applies when our customer is a legal entity and our customer authorises you to use our services;
service providers such as third parties we use to help deliver our services, including hosting partners (such as Supabase, Cloudflare and Resend), cloud providers, payment service providers (such as Stripe);
companies within our group.

We only allow third parties to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies, authorities and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

9. Data storage and security

All information you provide to us is stored on our secure servers and located in the EEA. Our servers are protected by firewalls establishing a barrier between our reliable and secure internal network and the Internet, and IP restrictions, limiting access to whitelisted addresses.

Any payment transactions will be carried out by our chosen third-party provider of payment processing services (currently, Stripe) and will be encrypted. We will not store or collect details of the credit or debit cards you provide.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In this connection, we encrypt data in transit and at rest, where appropriate. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

10. How long your personal information will be kept

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

We will usually keep your personal information while we are providing services to you or our customer. Thereafter, we will keep your personal information for as long as is necessary:

to respond to any questions, complaints or claims made by you or on behalf our customer;
to show that we treated you in accordance with the law; and
to keep records required by law. For example, we have to keep basic information about our financial transactions with our customers for six years after the year in which they take place for tax purposes.

Different retention periods apply for different types of personal information. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. When it is no longer necessary to retain your personal information, we will delete or anonymise it.

11. Transferring your personal information out of the EEA

We do not transfer your personal data outside the EEA.

12. Your rights

You have the following rights in relation to your personal information:

Access	The right to be provided with a copy of your personal information.
Rectification	The right to require us to correct any mistakes in your personal information. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
To be forgotten	The right to require us to delete your personal information (in certain circumstances). This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Restriction of processing	The right to require us to restrict processing of your personal information (in certain circumstances). This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
Data portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
To object	The right to object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Not to be subject to automated individual decision-making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
Withdraw consent	The right to withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

For further information on each of those rights, including the circumstances in which they apply, please contact us or visit the website of the Commissioner for the Protection of Personal Data (www.dataprotection.gov.cy).

If you would like to exercise any of those rights, please:

email, call or write to us—see below: ‘How to contact us’;
let us have enough information to identify you;
let us have proof of your identity; and
let us know what right you want to exercise and the information to which your request relates.

You will not have to pay a fee to access your personal information or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

13. How to complain

We hope that we can resolve any query or concern you may raise about our use of your information.

The GDPR also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Cyprus is the Commissioner for Personal Data Protection who can be contacted at 1 Iasonos street, 2nd floor, 1082 Nicosia; tel: 22818456; fax: 22304565; email: commissioner@dataprotection.gov.cy; www.dataprotection.gov.cy.

14. Changes to this privacy policy

This privacy policy was published on 11/11/2024.

We may change this privacy policy from time to time. When we do we will post the updated privacy policy on our website and we will also inform you via email if you are on our mailing list.

15. How to contact us

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:
Amathountos 18, Strovolos, 2020 Nicosia, Cyprus
Email: info@mamacrm.com Tel: 00357 22 042 200