Cookie Policy

All cookies and similar tools integrated into our website and internal platform are used by Vestberry, s.r.o., with registered seat at Stare Grunty 18, 841 04 Bratislava, company ID no. (IČO): 51 882 540, registered in the Commercial Registry, kept by Bratislava I District Court under Section Sro, Insert no. 130692/B (hereinafter referred to as “Vestberry”, “we”, or “us”).

In relation to any issues related to cookies, you may contact us directly:

Via email: info@vestberry.com

By mail: Vestberry, s.r.o., Stare Grunty 18, 841 04 Bratislava

This Cookie Policy is primarily intended for visitors of our website as it provides information on how we use cookies and similar tools in connection with the use of the www.vestberry.com and our social media fan pages as well as information how we continue to use the data obtained in this way. At the same time, it aims to provide information for our clients as users of the Vestberry Platform available at www.app.vestberry.com, which is owned and operated by Vestberry as a portfolio management and reporting software. This Cookie Policy supplements and specifies our Privacy Policy.

You, as the data subject, have the right to withdraw your consent at any time, and the withdrawal of the consent does not affect the lawfulness of the consent processing prior to its withdrawal. At the same time, for reasons related to your specific situation, you, as the data subject, have the right to object to the processing of personal data carried out on

Legal ground of legitimate interests; and

Purposes of the direct marketing

Including related profiling. The such objection has the same effect as the withdrawal of the consent with cookies. 

What types of cookies do we process? 

Cookies are files that are stored on your mobile device or internet browser used by your device when browsing our website and send us information about your activity. It is a technology that helps us better control and set up our websites, understand your behavior while using them, but also target our online advertising and campaigns more specifically. We use the following basic types of cookies on our website:

Necessary cookies are essential for the website to function properly and enable basic functions such as page navigation and access to secure areas of the website or very basic traffic measurement without data sharing with a third party.

Preference cookies enable a website to remember information that changes the way the website behaves or looks like you preferred language or the region that you are in. 

Statistics cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously, and we use it for marketing analytics as part of the use of specialized tools (e.g. Google Analytics) in order to better understand and interpret data about the users of our website and the way they use our services and website, or about advertising campaigns, and subsequently use them for advertising targeting.

Marketing cookies are used to understand how visitors interact with the website. The intention is to display ads that are relevant and engaging for the individual users and thereby more valuable for publishers and third party advertisers. 

By the law, we require your prior consent for all statistics and marketing cookies, which you can withdraw at any time. 

We store the necessary cookies automatically without the need for your consent on the legal basis of the performance of the contract or legitimate interests. At the same time, we distinguish between the so-called “1st party” cookies – which we store directly resp. via our servers – and the so-called “3rd party” cookies – which are stored by our external service providers / third parties.

For what purposes and on what basis do we use cookies?

We use cookies for the following purposes and based on the following legal grounds:

Purpose of the processing – Security and optimal functioning of the website

Type of the cookies – Necessary Cookies and Preference Cookies

Legal basis – Legal obligation / Legitimate interest

Purpose of the processing – Direct marketing purposes

Type of the cookies – Marketing cookies and Statistics cookies 

Legal basis – Consent 

These unifying purposes of the processing cookies include several processing operations, which are described in more detail below:

Security and optimal functioning of the website (necessary and preferences cookies) 

Optimal functioning of the website. It concerns the processing of necessary and so-called “preference cookies” that allow us to use your chosen website settings, such as storing consent or disagreement with cookies, or the selected language settings or your configuration of the embedded video player or other active elements.

Website security. This is the processing of necessary cookies that contribute to protection against bots and to the activation of website protection against DoS/DDoS cyber-attacks. When achieving the purpose, cookies from Google ReCaptcha are also used to read and filter robot requests.

Basic measurement of website traffic. This is the processing of necessary cookies, which allow obtaining and evaluating basic statistics on the use of our website for the purposes of improving its performance and availability in case of increased traffic without the possibility of sharing them with a third party and using them for the needs of marketing analytics.

Direct marketing purposes (marketing cookies and statistics cookies) 

Ad targeting It is the processing of Marketing cookies and third-party tools (such as Meta) for targeting our advertising campaigns and displaying ads on your profiles set up on social networks or when using the Internet on a regular basis. 

Marketing analytics or statistics. This involves the processing of Marketing cookies and Statistics cookies using specialized tools (e.g Google Analytics, Hotjar) to better understand and interpret customer data, the way they use our services and websites, or advertising campaigns and then use them to target advertising. As part of this, customers may also be segmented into different demographic groups to which their ad campaigns are tailored.

We also perform these processing operations based on our legitimate interests, which are: 

Website security

Optimal functioning of the website

In justified cases, we may also use the data obtained through cookies for other compatible purposes, which we inform about in the general information on personal data protection, which is available at Vestberry’s Privacy Policy

What specific cookies do we use and what is their retention period?

You can always find a specific list of all cookies that we use on the Website in its current form in the cookie bar on our website or at this link.

The given list also contains other necessary information, including the lifetime of cookies or the length of their functionality. According to the storage time of cookies in your device or internet browser, cookies can be divided into short-term cookies (so-called session cookies), which are deleted after closing the browser or ending the session, and long-term cookies (so-called persistent cookies), which remain stored in your device and are deleted until after a certain period of time or by actively deleting cookies, which you can do at any time.

You can view the cookie bar at any time by clicking on this active button “Manage Cookies”:

Through the interaction with the “Manage cookies”, you will see the cookies bar again, in which you only need to change your original preference to disagreement with one click (see image below). 

[Insert print screen when added to website]

The setting changes take effect immediately. You can also revoke your consent by making a request sent to info@vestberry.com, but this process is not immediate and automatic. We, therefore, recommend that you change the settings directly on the website as described above.

How to prevent cookies from being stored on your device? 

If you do not give your consent through our cookie bar (in terms of applicable types of cookies), these cookies will not be stored on your device. Disabled marketing and statistics cookies have no impact on the functionality of the website. You can delete all types of cookies at any time through the settings of your internet browser, but if you delete even the necessary cookies, some settings and functions of our website may not work optimally. 

In relation to specific cookies of third parties, it is also possible to use the so-called opt-out mechanisms by which you prevent the use of specific third-party cookies not only in relation to our website, but in general to the use of any other websites, or in relation to specific social networks that you use and have set up your own user account. 

Google Analytics

By installing the add-on in your internet browser, you will prevent the storage of cookies from the Google Analytics service and, in general, not only on our website, but also on any other websites. The add-on is available here.

Google and many other third parties involved in displaying personalized behavioural advertising on the Internet

If you do not want to display personalized ads, you can use the initiative www.youronlinechoices.com. By controlling preferences, you can disable multiple cookies to display these ads in relation to the participating companies that use cookies. Turning them off does not mean that your ad will no longer be shown to you but will not be based on your behaviour.

Facebook (Meta)

If you have your own Facebook account, you can also use the cookie management controls integrated directly into this social network, which are available here.

At the same time, through the settings of your internet browser, it is possible to delete those cookies that are stored in your browser. Follow the information below, depending on which browser you’re using: 

Google Chrome

Safari (iPhone)

Safari (Mac)

Mozilla Firefox

Samsung Internet (Mobile)

Microsoft Edge

Internet Explorer

Opera

If you want to increase your protection against unauthorized monitoring of your device and behavior on the Internet through cookies (especially third parties), use the “Do Not Track” function (or Blocking third party cookies), which you can turn on according to the type of browser used according to the following instructions:

Firefox

Internet Explorer

Edge

Chrome

Safari

Opera

Do we transfer your data to third countries outside the EU / EEA?

Yes, but only in necessary and to a minimal extent. Some of our suppliers we use when using cookies, have their registered office or their other group companies are established in the United States of America, which are generally considered to be a third country which does not guarantee an adequate level of the personal data protection. In many cases, the data may not physically leave servers located in the EU but processing due to the supplier’s location may be subject to the law of a third country. We therefore carry out these cross-border transfers only in strict accordance with the law (in particular the GDPR) and only if, in our conclusions and findings, sufficient risk mitigation measures and safeguards are taken for the protection of fundamental rights and freedoms of the data subjects, as required by the Court of Justice in Case C-311/18 (Schrems II).

Google Cloud EMEA Limited with registered seat at 70 Sir John Rogerson’s Quay, Dublin 2, Ireland 

(Google Analytics, Google Tag Manager, Google Search Console, Google Ads Pixel)

Google´s Privacy Policy

New type of standard contractual clauses approved by the relevant decision of the European Commission (module 1 and module 2) and appropriate additional measures with further explanation of the settings.

 

Meta Platforms Ireland Limited with registered seat 4 Grand Canal Square Grand Canal Harbour Dublin 2, Ireland

(Page Insights, Custom audiences, Measurements and Analytics)

Facebook´s Privacy Policy 

Standard contractual clauses are used, namely a combination of old (standard contractual clauses for the transfer of personal data to third country intermediaries approved by European Commission Decision 2010/87 / EC of 5 February 2010) and new clauses (module 3) inserted into European Addendum for Facebook data transfers and supplementary measures clarified here:

Clarification of standard contractual measures

Clarification of adopted supplementary measures

Information for law enforcement bodies

Information about law enforcement request for user data

 

LinkedIn Ireland Unlimited Company with registered seat at Wilton Place,
Dublin 2, Ireland

LinkedIn´s Privacy Policy 

A new type of standard contractual clauses approved by the relevant European Commission decision is used (module 2), which also describes the additional measures taken.

 

Liidio Oy with registered seat at Keskuskatu 6 E, 00100 Helsinki (Leadfeeder)

Leadfeeder’s Privacy Policy 

More information about compliance with the GDPR are available on Leadfeeder’s website.

Leadfeeder stores data in US and EU via Amazon Web Services, the data protection is guarded by an EU Commission Standard Contractual Clauses agreement in place with Amazon Web Services, as a part of our Data Processing Agreement with them.

 

G2.com, Inc. with its registered seat at 100 S. Wacker Dr. Ste. 600, Chicago, IL 60606 (G2)

G2´s Privacy policy

Data Processing Addendum with EU SCC (module 2) which also describes the additional measures taken.

 

Microsoft Corporation with its registered address at One Microsoft Way, Redmond Washington, 98052-6399 USA

Microsoft Privacy Policy

Microsoft Products and Services Data Protection Addendum (DPA) with EU SCC

 

Is the storage of cookies on my device a contractual or legal requirement and what are the consequences if I prevent their storage? 

The provision of any type of cookies, which we are processing is not a legal requirement and therefore their non-provision has no negative consequences with legal significance for you. 

However, the processing of the necessary and functional cookies can be considered necessary for the provision of the digital services you are interested during visit and usage of our website. Non provision of such cookies may have certain effects on your experience and proper working of website functionalities and third party add-ons or plug-ins integrated to website. Basic website functionalities will always work but as the consequence may worse your comfort and optimal configuration of settings stemmed from your preferences and choices made in the past or in services provided by third parties. 

In the case of all other types of cookies (e.g. analytics or advertisement), their provision is exclusively voluntary and is governed by the granting or non-granting of your consent. Failure to give this consent has no negative consequences for you.

How do we use cookies when managing our profiles on social networks? 

Simple links are also available on our website, which allow immediate connection between our website and our profile established on a social network or other platform (among others Twitter, Facebook, Instagram, LinkedIn, CrunchBase, G2.com). In these cases, these are not active plug-ins that would cause such data processing that would require the consent of logged-in or non-logged-in users of these social networks. 

However, in the case of interaction with icons depicting individual social networks, the social network provider may process cookies and personal data, on which we do not have to have any control and influence. Vestberry is not responsible for the use of cookies realized by the social network provider for its own purposes. For more information on the processing of cookies, it is therefore necessary to familiarize yourself with the rules of their processing published by social network providers here:

Facebook / Instagram Cookie Policy

Twitter Cookie Policy

LinkedIn Cookie Policy

Vestberry is responsible for processing your data only to a certain extent, for example if you visit our profile, if we communicate with each other on a social network or if we target advertising on social networks. On our profiles on social networks, we may process your personal data and cookies for analytical and statistical purposes together with the relevant social network providers as so-called joint controllers within the meaning of the GDPR. Based on this fact, we are obliged to inform you about the basic parts of the agreements that we have concluded under Art. 26 GDPR:

Joint-Controllership Addendum concluded with Meta (Facebook / Instagram)

Page Insights Joint-Controllership Addendum concluded with LinkedIn 

Further information about how we use social networks for our own purposes you may find in our Privacy Policy.

Do we use third party plug-ins, SDKs or surveillance pixels integrated in our websites? 

As part of our website security against cyber-attacks, we currently use Google reCAPTCHA. By using our website, you acknowledge that the ReCAPTCHA API works by collecting information about the hardware and software related to your end device used when browsing our website and sending it to Google for analysis. This data is used to improve this service and for general security purposes and will not be used to display personalized advertising by Google. Further details on the processing of personal data can be found in the Google´s Privacy Policy, Terms of Service and additional information for Google reCAPTCHA, which also apply to the provision of this service.

We use the Meta Pixel provided on our website for purposes of advertisement and analytics. Meta Pixel is operated by Meta Platforms, Inc., 1601 S California Ave, Palo Alto, California 94304, USA (Meta). This allows Meta to identify visitors of our websites in order to display interest processing advertisement (“Facebook Ads”) to the users of our website when visiting the social network Facebook or other interest-based websites that also use this process.

We also use the Meta Pixel and the Conversions API to ensure that our Facebook Ads match the potential interest of users and are not annoying. With the help of the Facebook Pixel, we can track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion”).

Your actions are stored in one or more cookies. These cookies enable Meta to match your user data (such as IP address, user ID) with the data of your Facebook account. The collected data is anonymous and not visible to us and can only be used in the context of advertisements. You can prevent the linking with your Facebook account by logging out before you take any action.

You can find more specific information about Meta Pixel and how Meta processes data more in detail on Meta Data Policy and Facebook’s help page. You can also view your Facebook ads settings and update your preferences at any time.

On our website simple links (links) are also available enabling an immediate connection between our website and our profile established on a social network or other platform (e.g. Twitter, Facebook, Instagram, LinkedIn, CrunchBase, G2.com). With regard to the connection and use of social networks, we recommend that you familiarize yourself with the privacy policies of the providers of the social media platforms through which we communicate. In our policies we only explain basic issues regarding the management of our profiles or the profiles of our clients. We only have typical administrator rights when processing your personal data through our or client profiles. We assume that by using social networks you understand that your personal data is primarily processed by the providers of social network platforms (such as Facebook, LinkedIn or Twitter) and we have no control over and are not responsible for this processing, the further provision of your personal data to third parties and the cross-border transfer to third countries carried out by these platform providers social networks for own purposes. We are not interested in processing your personal data from the special category of personal data on any social network profile. Any provision of additional information from you that would reveal such sensitive data will be considered an accidental acquisition of the so-called observed data, which will not be further systematically processed, except for their deletion or anonymization.

Discover the power of Vestberry Platform