As of February 1st 2022

Preamble

On this page we inform you (“you” or “the data subject”) about the privacy policy applicable to our spreadsheet platform ("the platform") and our website (“the website”). The platform is an offer of Rows GmbH, Am Märchenbrunnen 5, 10407 Berlin, Germany (“we” or "Rows”).

We appreciate your interest in our product. We would like you to feel secure when visiting our website and when using our platform, also with regard to the protection of your personal data. We take the protection of your personal data very seriously, and we make sure to comply with German and European data protection law.

In the following, we will inform you about the processing of personal data when using our website or platform and provide you with the Privacy Policy. If you need a Data Processing Agreement with us, please find the already signed version here.

1. Identity and contact details of the data controller

The responsible data controller in accordance with the purposes of the General Data Protection Regulation (GDPR) of the European Union and other data protection regulations is:

Rows GmbH | Am Märchenbrunnen 5 | 10407 Berlin | Germany

+49-30-23594633 | hello@rows.com | rows.com

2. Contact details of the data protection officer

The designated data protection officer is:

DataCo GmbH | Dachauer Str. 65 | 80335 Munich | Germany

+49 89 7400 45840 | datenschutz@dataguard.de | dataguard.de

3. General information on data processing

3.1. Scope of processing personal data

In general, we only process the personal data of our users to the extent necessary to provide a functioning website with our content and services. We only process it with your consent. Exceptions include cases where prior consent cannot be technically obtained and where the processing of the data is permitted by law.

In addition, Rows also might handle 4 types of personal data:

• Customer Account Data: information (First name, Last name, Email address, ....), you input at our request to set up and manage your account.
• Customer Spreadsheet Data: data, texts and other materials imported or manually inputted by in your spreadsheets you when using our services.
• Partner API Integration Data: originated in third-party systems and accessed through Rows via APIs at your request.
• Stored Integration Data: originated in third-party sources and stored in Rows' systems and databases and accessed through Rows via internal APIs at the request of users.

3.2. Legal basis for data processing

Art. 6 (1) (1) (a) GDPR when consent is appropriate for processing personal data.

Art. 6 (1) (1) (b) GDPR when the processing of personal data required for the performance of a contract of which the data subject is a party, incl. processing for pre-contractual activities.

Art. 6 (1) (1) (c) GDPR when it is necessary to process personal data to fulfil a legal obligation to which our company is subject.

Art. 6 (1) (1) (d) GDPR when vital interests of the data subject or another natural person require the processing of personal data.

Art. 6 (1) (1) (f) GDPR, when the processing of data is necessary to safeguard the legitimate interests of our company or that of a third party, and the fundamental rights and freedoms of the data subject do not outweigh the interest of the former.

3.3. Data removal and storage duration

We will delete or restrict your personal data as soon as the purpose of its storage has been accomplished. Additional storage may occur if this is provided for by the European or national legislator within the EU regulations, law, or other relevant regulations to which you are subject. We will also delete or restrict the data when the storage period stipulated by these standards expires unless there is a need to prolong the storage of the data for the purpose of concluding or fulfilling the respective contract.

4. Your rights

When your personal data is processed, you are a data subject within the meaning of the GDPR and have the following rights:

4.1. Right to information

You may request us, the data controller, to confirm whether your personal data is processed by us.

If we do process your personal data, you can request the following information from us:

• The purpose for which the personal data is processed.
• The categories of personal data being processed.
• The recipients or categories of recipients to whom the personal data have been or will be disclosed.
• The planned duration of the storage of your personal data or, if specific information is not available, criteria for determining the duration of storage.
• The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing.
• The existence of the right to lodge a complaint with a supervisory authority.
• Where personal data is not collected from yourself, any available information as to their source.
• The existence of automated decision-making including profiling under Article 22 (1) and Article 22 (4) GDPR and, in certain cases, meaningful information about the data processing system involved, and the scope and intended result of such processing on the data subject.

You have the right to request information on whether your personal data will be transmitted to a third country or an international organization. In this context, you can then request for the appropriate guarantees in accordance with Art. 46 GDPR in connection with the transfer.

4.2. Right to rectification

You have a right to rectification and/or modification of your personal data we process if it is incorrect or incomplete. We must and will correct the data without delay.

4.3. Right to the restriction of processing

You may request the restriction of the processing of your personal data under the following conditions:

• If you challenge the accuracy of your personal data for a period that enables the data controller to verify the accuracy of your personal data.
• The processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of their use instead.
• The data controller or its representative no longer need the personal data for the purpose of processing, but you need it to assert, exercise or defend legal claims; or
• If you have objected to the processing pursuant to Art. 21 (1) GDPR and it is not yet certain whether the legitimate interests of the data controller override your interests.

If the processing of personal data concerning you has been restricted, this data may – except for data storage – only be used with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

If the processing has been restricted according to these conditions, you will be informed by the data controller before the restriction is lifted.

4.4. Right to erasure

4.4.1. Obligation to erase

If you request us to delete your personal data without undue delay, we are required to do so immediately if one of the following applies:

• Personal data concerning you is no longer necessary for the purposes for which they were collected or processed.
• You withdraw your consent on which the processing is based pursuant to Art. 6 (1) (1) (a) and Art. 9 (2) (a) GDPR and where there is no other legal basis for processing the data.
• According to Art. 21 (1) GDPR you object to the processing of the data and there are no longer overriding legitimate grounds for processing, or you object pursuant to Art. 21 (2) GDPR.
• Your personal data has been processed unlawfully.
• The personal data must be deleted to comply with a legal obligation in Union law or Member State law to which the data controller is subject.
• Your personal data was collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.

4.4.2. Information to third parties

If we, the data controller, have made your personal data public and must delete the data pursuant to Art. 17 (1) GDPR, we shall take appropriate measures, including technical means, to inform data processors who process the personal data, that a request has been made to delete all links to such personal data or copies or replications of the personal data, taking into account available technology and implementation costs to execute the process.

4.4.3 Exceptions

The right to deletion does not exist if the processing is necessary

• to exercise the right to freedom of speech and information.
• to fulfil a legal obligation required by the law of the Union or Member States to which the data controller is subject, or to perform a task of public interest or in the exercise of public authority delegated to the representative.
• for reasons of public interest in the field of public health pursuant to Art. 9 (2) (h) and Art. 9 (2) (i) and Art. 9 (3) GDPR.
• for archival purposes of public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) GDPR, to the extent that the law referred to in subparagraph (a) is likely to render impossible or seriously affect the achievement of the objectives of that processing, or
• to enforce, exercise or defend legal claims.

4.5. Right to information

If you have the right of rectification, erasure, or restriction of processing over us, the data controller, we are obliged to notify all recipients to whom your personal data have been disclosed of the correction or erasure of the data or restriction of processing, unless this proves to be impossible or involves a disproportionate effort.

You reserve the right to be informed about the recipients of your data by the data controller.

4.6. Right to data portability

You have the right to receive your personal data given to us, the data controller, in a structured and machine-readable format. In addition, you have the right to transfer this data to another person without hindrance by the data controller who was initially given the data, if:

• the processing is based on consent in accordance with Art. 6 (1) (1) (a) GDPR or Art. 9 (2) (a) GDPR or performance of a contract in accordance with Art. 6 (1) (1) (b) GDPR and
• the processing is done by automated means.

In exercising this right, you also have the right to transmit your personal data directly from one person to another, insofar as this is technically feasible. Freedoms and rights of other persons shall not be affected.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority delegated to the data controller.

4.7. Right to object

For reasons that arise from your particular situation, you have, at any time, the right to object to the processing of your personal data pursuant to Art. 6 (1) (1) (e) or 6 (1) (1) (f) GDPR; this also applies to profiling based on these provisions.

We, the data controller, will no longer process the personal data concerning you unless he can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing is for the purpose of enforcing, exercising, or defending legal claims.

If the personal data relating to you is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling associated with direct marketing.

If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

Regardless of Directive 2002/58/EG, you have the option, in the context of the use of information society services, to exercise your right to object to automated decisions that use technical specifications.

4.8. Right to withdraw the data protection consent declaration

You have the right to withdraw your consent at any time. The withdrawal of consent does not affect the legality of the processing carried out based on the consent until the withdrawal.

4.9. Automated decisions on a case-by-case basis, including profiling

You have the right to not be subject to a decision based solely on automated processing – including profiling – that will have a legal effect or substantially affect you in a similar manner. This does not apply if the decision:

• is required for the conclusion or execution of a contract between you and the data controller,
• is permitted by the Union or Member State legislation to which the data controller is subject, and where such legislation contains appropriate measures to safeguard your rights and freedoms and legitimate interests, or
• is based on your explicit consent.

However, these decisions must not be based on special categories of personal data under Art. 9 (1) GDPR, unless Art. 9 (2) (a) or Art. 9 (2) (b) GDPR applies, and reasonable measures have been taken to protect your rights and freedoms as well as your legitimate interests.

With regard to the cases referred to in (1) and (3), the data controller shall take appropriate measures to uphold your rights and freedoms as well as your legitimate interests, including the right to obtain assistance from the data controller or his representative, to express your opinion on the matter, and to contest the decision.

4.10. Right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in the Member State of your residence, or your place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you violates the GDPR.

The supervisory authority to which the complaint has been submitted shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.

5. Provision of website and creation of log files

5.1. Description and scope of data processing

Each time you access our website or platform, our system automatically collects data and relevant information from the computer system of the calling device.

We collect the following data:

• Browser type and version used
• Operating system of your device
• Your internet service provider
• Your IP address and country
• Date and time of access
• Web pages from which the user’s system accessed our website

We store this data in log files of our system, separate from your other personal data.

5.2. Purpose of data processing

The temporary storage of the IP address by the system is necessary for the delivery of the website to your computer. For this purpose, we have to keep your IP address for the duration of the session.

We store your data in log files to ensure the functionality of our website. We also use it to optimize the website and to ensure the security of our IT systems. We do not analyze your data for marketing purposes.

For these purposes, our legitimate interest lies in the processing of data in compliance with Art. 6 (1) 1 (f) GDPR.

5.3. Legal basis for data processing

The legal basis for the temporary storage of data and log files is Art. 6 (1) (1) (f) GDPR.

5.4. Duration of storage

We will delete your IP address as soon as it is no longer necessary for the purpose of its collection. The session is complete when the collection of data for the provision of the website is accomplished.

If we store your IP address in log files, this is the case after seven days at the latest. Storage beyond this is possible. In this case, we delete or alienate your IP addresses so that an identification of the calling client is not possible.

5.5. Objection and removal

The collection of data for the provision of the website as well as the storage of data in log files are essential for the operation of the website. Therefore, you may not object to these processes.

6. Use of cookies

6.1. Description and scope of data processing

Our website and platform use cookies. Cookies are text files that are stored in the internet browser or the internet browser on the user’s computer system. If a user calls up a website, a cookie can be stored on the user’s operating system. These cookies contain a string of characters that allows the browser to be uniquely identified when the website is reopened.

We use cookies to make our website and platform more user-friendly. Some elements of our website and platform require your browser to be identified even after a page break.

The following data is stored and transmitted in the cookies:

• Language settings

We also use cookies, which enable us to analyse the browsing behaviour of our users.

As a result, the following data will be transmitted:

• Entered search queries
• Frequency of page views
• Use of website functionalities

The user data collected in this manner is pseudonymised by technical measures. It is therefore not possible to assign the data to the user accessing the site. We store this data separately from other personal data of our users.

6.2. Purpose of data processing

The purpose of using technical cookies is to simplify the use of websites for users. Some functions of our website and platform cannot be offered without the use of cookies. These require that the browser is recognized even after a page change.

We need cookies for the following purposes:

• Application of language settings
• Storage of search terms

The user data collected by technical cookies is not used to create user profiles.

These cookies are used to improve the quality of our website respectively platform and its content. Through the analysis cookies, we learn how our services are used and can constantly improve it.

Our legitimate interests are to provide you with a working connection and to ensure a comfortable use of our website and platform. Also, we need to process your personal data to solve occurring safety and security issues, and to ensure system stability.

6.3. Legal basis for data processing

The legal basis for the processing of personal data using cookies is Art. 6 (1) (1) (a) GDPR.

The legal basis for the processing of personal data using technical cookies is Art. 6 (1) (1) (f) GDPR, legitimate interests.

6.4. Duration of storage and possibility of objection and removal

Cookies are stored on your device and then transmitted from there to our site. Therefore, you as a user also have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it is possible that not all functions of the website can be used to their full extent.

If you use the Safari browser version 12.1 or higher, cookies will be automatically deleted after seven days. This also applies to opt-out cookies, which are used to prevent the use of tracking mechanisms.

7. Registration and data processing on the platform

7.1. Scope of the processing of personal data

On our platform, we offer users the opportunity to register by providing personal data. The data is entered in an input mask and transmitted to us and stored. The data is not passed on to third parties without consent. We collect the following data during the registration process:

• First name
• Last name
• Email address
• Password, encrypted as a hash
• Information why the platform is intended to be used
• Date and time of registration

As part of the registration process, you give your consent to the processing of this data.

7.2. Purpose of the processing of personal data

User registration is required for the provision of certain content and services on our platform. You need a user account to access our platform and work with spreadsheets. We also send you a limited number of emails to help your onboarding to our platform.

7.3. Legal basis for the processing of personal data

The legal basis for registration is consent pursuant to Art. 6 para. 1. p. 1 lit. a GDPR. In addition, we process personal data on the basis of our legitimate interest in providing a functional platform (Art. 6 para. 1 p. 1 lit. f GDPR).

7.4. Data deletion and storage period

We will delete the data as soon as it’s no longer required to achieve the purpose for which it was collected. We do not store your data if your registration is cancelled during the process.

7.5. Right of objection and revocation

You can send an informal email to privacy@rows.com to have the stored data changed or your account deleted at any time.

If the data is necessary for the fulfilment of a contract or for the implementation of pre-contractual measures, a premature deletion of the data is only possible if contractual or legal obligations do not stand in the way of a deletion.

8. Newsletter

8.1. Description and scope of data processing

You can subscribe to a newsletter on our website free of charge. This happens in the same input mask and at the same time as you register for the platform (see VI. Registration and data processing on the platform). If you give your consent to receiving our newsletter and confirm in a double-opt in process, we will send you our periodic newsletter using the following personal data:

• Email address
• Last name
• First name

The data will be used exclusively for sending the newsletter.

8.2. Purpose of data processing

We collect your email address and name to deliver the newsletter to you and address you by your name.

8.3. Legal basis for data processing

The legal basis for the processing of data provided by the user after registration for the newsletter is Art. 6 (1) (1) (a) GDPR if the user has given their consent.

8.4. Duration of storage

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. Your email address and name will therefore be stored as long as the newsletter subscription is active.

8.5. Objection and removal

You can cancel the subscription for the newsletter at any time. For this purpose, every newsletter contains an opt-out link.

You can also withdraw the consent to the storage of personal data collected during the registration process.

9. Contact via email

9.1. Description and scope of data processing

You can contact us via the email address provided on our website. In this case your personal data transmitted with the email will be stored.

We will use the data exclusively for the processing of the conversation.

9.2. Purpose of data processing

If you contact us via email, this also constitutes the necessary legitimate interest in the processing of the data.

9.3. Legal basis for data processing

The legal basis for the processing of data transmitted while sending an email is Art. 6 (1) (1) (f) GDPR. If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) GDPR.

9.4. Duration of storage

We will delete the data as soon as it is no longer necessary to achieve the purpose for which it was collected. For personal data sent by email, this is the case 6 months after the respective conversation with the user has ended. The conversation ends when it can be concluded from the circumstances that the matter in question has been conclusively resolved.

9.5. Objection and removal

You can withdraw consent to the processing of your personal data at any time. If you contact us by email, you can object to the storage of your personal data at any time.In such cases, the conversation cannot be continued. All personal data that has been stored in the course of the contact will be deleted.

10. Hosting

The website and the Rows platform are hosted on servers of a service provider commissioned by us.

Our service provider is Google Cloud Platform.

The servers automatically receive information in so-called server log files, which your browser automatically transmits when you visit the website. The stored information is:

• Browser type and version
• Used operating system
• Referrer URL
• Host name of the accessing computer
• Time and date of the server request
• Your IP address

This data will not be merged with other data sources. The data is collected on the basis of Art. 6 (1) (1) (f) GDPR. We have a legitimate interest in the technically error-free presentation and optimization of our website - and server log files are therefore recorded.

The server of the website is geographically located in the European Union (EU) or the European Economic Area (EEA).

11. Usage of plugins and other tools

11.1 Use of Google Analytics

11.1.1. Scope of processing of personal data

We use Google Analytics, a web analysis service. Google Analytics examines, among other things, the origin of visitors, their length of stay on individual pages and the use of search engines, thus allowing better monitoring of the success of advertising campaigns. Google places a cookie on your computer. This allows personal data to be stored and evaluated, in particular the user's activity (in particular which pages have been visited and which elements have been clicked on), device and browser information (in particular the IP address and the operating system), data on the advertisements displayed (in particular which advertisements have been displayed and whether the user has clicked on them) and also data on advertising partners (in particular pseudonymised user IDs). The information generated by the cookie about your use of this website will be transmitted to and stored by Google on servers in the United States. However, if IP anonymization is enabled on this online presence, Google will previously truncate your IP address within member states of the European Union or other signatory states to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.

Part of the terms of use of Google Analytics as a Google advertising product are so-called standard data protection clauses (Art. 46 (2) (1) (c) GDPR). These are to be classified as an appropriate guarantee for the protection of the transfer and processing of personal data outside the EU.

On behalf of Rows, Google will use this information to evaluate your use of the Rows website, to compile reports on the activities of the website and to provide further services associated with the use of the website and the Internet use to Rows. The IP address transmitted by your browser as part of Google Analytics is not combined with other data from Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of our website.

Further information on the collection and storage of data by Google can be found under https://policies.google.com/privacy?gl=EN&hl=en. Google Analytics is provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and its representative in the European Union, Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (“Google”).

11.1.2. Purpose of data processing

The purpose of processing your personal data is to specifically address you as a target group that has already expressed an initial interest by visiting the website, as described in Sections V. and VI. of this Privacy Policy.

11.1.3. Legal basis for the processing of personal data

The legal basis for the processing of personal data is your given consent in accordance with Art. 6 (1) (1) (a) GDPR.

11.1.4. Duration of storage

Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law. Advertising data in server logs is anonymized by Google's own statements to delete parts of the IP address and cookie information after 9 and 18 months respectively.

11.1.5. Possibility of revocation of consent and removal

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation. \ You may prevent the collection and processing of your personal data by Google by preventing the storage of cookies by third parties on your computer, by using the "Do Not Track" function of a supporting browser, by deactivating the execution of script code in your browser or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser. You can also prevent the collection of data generated by the cookie and related to your use of the online presence (including your IP address) to Google and to prevent the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en. \ With the following link you can deactivate the use of your personal data by Google: https://adssettings.google.de.

Further information on objection and removal options against Google can be found at: https://policies.google.com/privacy?gl=EN&hl=en.

11.2. Use of Customer.io

11.2.1. Scope of the processing of personal data

We use Customer.io to send onboarding emails and our newsletter. The following data is processed in the process:

• First and last name
• Email address

To use the Customer.io service, personal data may be transferred to US servers. Part of the data processing agreement with Peaberry are so-called standard data protection clauses (Art. 46 (2) (c) GDPR). These are to be classified as appropriate safeguards for the protection of the transfer and processing of personal data outside the EU. A copy of the standard data protection clauses can be requested by sending us an informal email.

Customer.io is provided by Peaberry Software Inc. d/b/a Customer.io, 921 Washington Street, Suite 820, Portland, PRe., 97205 USA. For more information on Customer.io, please click here:

• Privacy policy: https://customer.io/legal/privacy-policy/
• DPA: https://customer.io/legal/dpa/.

11.2.2. Purpose of the data processing

The purpose of the processing is to deliver onboarding emails and newsletters to interested parties, as described in Sections VII. and VIII. of this Privacy Policy.

11.2.3. Legal basis for the processing of personal data

The legal basis for the processing of users' personal data is generally the user's consent pursuant to Art. 6 (1) (a) GDPR.

11.2.4. Duration of storage

Your personal information will be stored for as long as necessary to fulfil the purposes described in this privacy policy or as required by law, e.g. for tax and accounting purposes.

11.2.5. Revocation and removal options

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out based on the consent until the revocation.

11.3. Use of Segment

11.3.1. Scope of the processing of personal data

We use Segment to process data from our cookies and log files and integrate it into our other tools, e.g. to send you onboarding emails and our newsletter, and to operate a chat interface for customer service requests inside our platform. Cookies are stored on your device, which contains information of the other cookies specified in this privacy policy.

Segment is provided by Segment Technologies Ireland, Limited, 3rd Floor, Kilmore House, Park Lane, Spencer Dock, Dublin 1, Ireland. Further information can be found here: https://segment.com/legal/privacy/.

11.3.2. Purpose of data processing

Segment is used to route data to other tools to fulfil the purposes described in Sections 7. to 9. of this Privacy Policy.

11.3.3. Legal basis for the processing of personal data

The legal basis for the processing of users' personal data is generally the user's consent in accordance with Art. 6 (1) (a) GDPR.

11.3.4. Duration of storage

Your personal information will be stored for as long as necessary to fulfil the purposes described in this privacy policy.

11.3.5. Revocation and removal options

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out based on the consent until the revocation.

You can prevent the collection as well as the processing of your personal data by Segment by preventing the storage of third-party cookies on your computer, using the "Do Not Track" function of a supporting browser, deactivating the execution of script code in your browser or installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.

11.4. Use of Sendgrid

11.4.1. Scope of the processing of personal data

We use Sendgrid to send you transactional emails, e.g. for your registration, workspace confirmation, or password reset. We ensure that login information is sent confidentially to the relevant recipient and any risk of unauthorised disclosure is reduced.

The following data is processed in the process:

• First and last name
• Email address

Sendgrid is provided by Sendgrid Inc., 1801 California St, Denver, CO 80202, USA, acquired by Twilio Inc. in 2019. Further information can be found here:

• Privacy policy: https://www.twilio.com/legal/privacy
• GDPR info: https://sendgrid.com/resource/general-data-protection-regulation-2/

11.4.2. Purpose of data processing

The purpose of the processing is our legitimate interest in the secure provision of login data and password reset functionality.

11.4.3. Legal basis for the processing of personal data

The legal basis for the processing of personal data is the user's given consent in accordance with Art. 6 (1) (1) (a) GDPR.

11.4.4. Duration of storage

Your personal information will be stored for as long as necessary to fulfil the purposes described in this Privacy Policy or as required by law.

11.4.5. Revocation and removal options

You can send an informal email to privacy@rows.com to have the stored data changed or your account deleted at any time.

If the data is necessary for the fulfilment of a contract or for the implementation of pre-contractual measures, a premature deletion of the data is only possible if contractual or legal obligations do not stand in the way of a deletion.

You can find further information on objection and erasure options against Sendgrid at: https://www.twilio.com/legal/privacy.

11.5. Use of Intercom

11.5.1. Scope of the processing of personal data

We use Intercom for email, push messages and live chats with our users and customers. For this purpose, Intercom uses cookies that enable the recognition of your activity (in particular which pages have been visited and which elements have been clicked on) and device and browser information (in particular the IP address and the operating system).

Intercom is a service of Intercom Inc., 55 2nd Street, 4th Floor, San Francisco, CA 94105, USA. Further information on the collection and storage of data by Intercom can be found here: https://www.intercom.com/legal/privacy.

11.5.2. Purpose of data processing

The purpose of the processing is Plugin to improve the user experience and to improve communication with our users, in particular to provide customer support.

11.5.3. Legal basis for the processing of personal data

The legal basis for the processing of users' personal data is generally the user's consent in accordance with Art. 6 (1) (a) GDPR.

11.5.4. Duration of storage

Your personal information will be stored for as long as necessary to fulfil the purposes described in this privacy policy or as required by law, e.g. for tax and accounting purposes

11.5.5. Revocation and removal options

You have the right to revoke your declaration of consent under data protection law at any time. The withdrawal of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the withdrawal.

You can prevent Intercom from collecting and processing your personal data by preventing the storage of third-party cookies on your computer, by using the "Do Not Track" function of a supporting browser, by deactivating the execution of script code in your browser, or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.

You can find further information on objection and reassure options against Intercom at: https://www.intercom.com/legal/privacy.

11.6. Use of Hotjar

11.6.1. Scope of the processing of personal data

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. We will stop using Hotjar 4 weeks after you created your account. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. While Hotjar records your screen while you are using Rows, all your spreadsheet content is fully anonymized and rendered fully unreadable. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

Hotjar is a service of the Hotjar Ltd, Dragonara Business Centre, 5th floor, Dragonara Road, Paceville St Julian's STJ 3141, Malta. Further information can be found here:

• Privacy policy: https://www.hotjar.com/legal/policies/privacy/
• GDPR info: https://www.hotjar.com/legal/compliance/gdpr-commitment/

11.6.2. Purpose of data processing

The purpose of the processing is our legitimate interest in improving our services for you.

11.6.3. Legal basis for the processing of personal data

The legal basis for the processing of personal data is the user's given consent in accordance with Art. 6 (1) (1) (a) GDPR.

11.6.4. Duration of storage

Your personal information will be stored for as long as necessary to fulfil the purposes described in this Privacy Policy or as required by law.

11.6.5. Revocation and removal options

You can send an informal email to privacy@rows.com to have the stored data changed or your account deleted at any time. If the data is necessary for the fulfilment of a contract or for the implementation of pre-contractual measures, a premature deletion of the data is only possible if contractual or legal obligations do not stand in the way of a deletion. You can find further information on objection and erasure options against Hotjar at: https://help.hotjar.com/hc/en-us/articles/360002735873-How-to-Stop-Hotjar-From-Collecting-your-Data.

11.7. Use of OpenAI

11.7.1. Scope of the processing of personal data

We use OpenAI for our AI Analyst to generate data analysis and summaries for you with the help of artificial intelligence. When you use the AI Analyst in a table, to protect your privacy we send to OpenAI just an summarization of the dataset, including the header of the dataset, a limited sample containing at most 5 rows of data, and basic stats of the dataset, like min and max. Therefore we only send personal data to OpenAI if you include personal data, such as names, in the first row or column of the table that contains data, and in the example rows. We do not send full tables to OpenAI to protect your privacy. OpenAI is a service of OpenAI, L.L.C., 3180 18th St, San Francisco, CA, 94110, USA. Further information on the collection and storage of data by Intercom can be found here: https://openai.com/policies/privacy-policy.

11.7.2. Purpose of data processing

The purpose of the processing is to generate data analysis for you with the help of artificial intelligence.

11.7.3. Legal basis for the processing of personal data

The legal basis for processing your personal data is Art 6 (1) (b) GDPR, as the processing is necessary for the fulfilment of contractual relationships if you do want to use our AI-Analyst-Feature.

11.7.4. Duration of storage

The personal data of the data subject will be erased or restricted as soon as the purpose of its storage has been accomplished. Additional storage may occur if it was provided for by the European or national legislator within the EU regulations, law, or other relevant regulations to which the data controller is subject. Restriction or erasure of the data also takes place when the storage period stipulated by the aforementioned standards expires, unless there is a need to prolong the storage of the data for the purpose of concluding or fulfilling the respective contract.

12. Content delivery networks

12.1. Description and scope of data processing

On our website we use functions of the content delivery network Google Cloud CDN. A Content Delivery Network (CDN) is a network of regionally distributed servers connected via the Internet to deliver content, especially large media files such as videos. Google Cloud CDN provides web optimization and security services that we use to improve the load times of our website and to protect it from misuse. When you visit our website, a connection to the servers of Google Cloud CDN is established, e.g. to retrieve content. This allows personal data to be stored and evaluated in server log files, the user's activity (e.g. which pages have been visited) and device and browser information (e.g. IP address and operating system).

Google Cloud CDN is a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Further information on the collection and storage of data by Google Cloud CDN can be found here: https://policies.google.com/privacy?hl=en.

12.2. Purpose of data processing

Google Cloud CDN features are used to deliver and accelerate online applications and content.

12.3. Legal basis for data processing

The data is collected on the basis of Art. 6 (1) (1) (f) GDPR. We have a legitimate interest in the technically error-free presentation and optimization of his website - and server log files are therefore recorded.

12.4. Duration of storage

Your personal information will be retained for as long as necessary to fulfil the purposes described in this Privacy Policy or as required by law.

12.5. Objection and removal

Information about objection and removal options regarding Google Cloud CDN can be found at: https://policies.google.com/privacy?hl=dede/privacypolicy/.

13. Payments and billing

When using Rows, you can choose a subscription plan, including paid subscription plans. Our payment and billing processes are handled by using Chargebee and Stripe.

13.1. Description and scope of data processing

We offer our customers to complete the payment process by credit card. We transfer customers to the platform of the payment service provider in question. After completion of the payment process, we receive the customer's payment data from the payment service provider Stripe and process it in our billing system Chargebee.

Our payment service providers comply with the requirements of the "Payment Card Industry (PCI) Data Security Standards" and have been certified by an independent PCI Qualified Security Assessor.

The following data will be transmitted regularly as part of payment via credit card:

• Purchase amount
• Date and time of purchase
• Credit card number
• Credit card validity period
• Card validation code (CVC)
• IP address of the user's device

Payment data is passed on to:

Stripe Inc., 510 Townsend Street San Francisco, CA 94103, USA.

The following data will be transmitted regularly as part of billing:

• Purchase amount
• Date and time of purchase
• First and last name
• Address
• Email address

Billing data is passed on to:

Chargebee Inc., 340 S Lemon Ave #1537, Walnut, CA, 91789, USA..

Not all of the above-mentioned data is sent to the corresponding service providers, but only the data that is necessary for payment and billing processes.

Further information on the data protection guidelines as well as rejection and removal options for payment service providers can be found here:

• Stripe: https://stripe.com/de/privacy
• Chargebee: https://www.chargebee.com/privacy/

13.2. Purpose of data processing

The transmission of payment data to payment service providers serves to process payments, e.g. if you purchase a product and/or use a service.

13.3. Legal basis for data processing

The legal basis for data processing is Art. 6 (1) (1) (b) GDPR, since the processing of the data is necessary for the execution of the concluded sales contract.

13.4. Duration of storage

All payment data as well as data on possible chargebacks are only stored as long as they are required for payment processing and a possible processing of chargebacks and debt collection as well as for combating misuse.

Furthermore, payment data may be stored beyond this if and as long as this is necessary to comply with statutory retention periods or to prosecute a specific case of misuse.

Your personal data will be deleted at the end of the statutory retention period, i.e. after 10 years at the latest.

13.5. Objection and removal

You can withdraw your consent to the processing of your payment data at any time by notifying the data controller or the payment service provider used. However, the payment service provider used may still be entitled to process your payment data if and as long as this is necessary for the contractual payment processing.

14. Information on data not collected by the data controller

Through integrations with other tools (e.g. Gmail, Salesforce), personal data from other data controllers and processors can be imported into our platform. This happens if you activate the corresponding integrations and agree to the terms of use and privacy policy of these third-party providers; or if you use integrations activated by default when signing up (see applicable third-party terms in the Integrations Terms of Use). Furthermore, personal data may be communicated from Rows to third parties through this process at your request and on your behalf. This only takes place with your active consent, which you can revoke at any time by stopping the relevant functionality of our platform in your user account.

In addition, you may be managing personal data yourself through Rows for which we are only acting as a processor. In this case you must communicate certain information to data subjects in accordance with Art. 13 GDPR and conclude a Data Processing Agreement (DPA) with us. You can access and execute an already signed version of our DPA here.

15. Application via email

15.1. Scope of data processing

You can send us your application via email. All our open vacancies can be found on GitHub.

We process your email address and the information you provide in the email:

• First name
• Last name
• Email address
• Curriculum vitae

15.2. Purpose of data processing

We process your personal data from the application form solely to process your application.

15.3. Legal basis for data processing

The legal basis for the processing of the data is the completion of the contractual relationship with you, Art. 6 (1) (1) (b) Alt. 1 GDPR and § 26 (1) (1) BDSG (Federal Act of Data Protection).

15.4. Duration of storage

After completion of the application procedure, we will store the data for up to six months. Your data will be deleted after six months at the latest. In case of a legal obligation, the data will be stored within the framework of the applicable provisions.

15.5. Objection and removal

As an applicant, you have the possibility to object to the processing of personal data at any time. In such a case, your application will no longer be considered.

If you want to change or delete your Personal Data related to your application, please send us an email to join@rows.com.

All personal data stored during electronic job applications will be deleted in this case

16. Corporate web profiles on social networks

We use corporate profiles on social and professionally oriented networks. We maintain a corporate presence on the following networks.

16.1 Twitter

Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, Ireland.

On our company profile we provide information and offer Twitter users the possibility of communication. If you carry out an action on our Twitter company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by Twitter, we cannot make any binding statements regarding the purpose and scope of the processing of your data.

We integrated social media platforms on our website via links, which may result in social media providers receiving data from you if necessary.

Publications on the company profile can contain the following content:

• Information about services
• Advertisement
• Customer contact

Every user is free to publish personal data.

The legal basis for data processing is Art. 6 (1) (1) (a) GDPR.

In order to ensure appropriate safeguards to protect the transfer and processing of personal data outside the EU, the transfer of data to and processing of data by Twitter shall be based on appropriate safeguards pursuant to Art. 46 et seq. GDPR, in particular by concluding so-called standard data protection clauses pursuant to Art. 46 para. 2 c) GDPR.

The data generated on the company profile is not stored in our own systems.

You can object at any time to the processing of your personal data that we collect within the framework of your use of our Twitter corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to privacy@rows.com. For further information on the processing of your personal data by Twitter and the corresponding objection options, please click here: https://twitter.com/de/privacy.

16.2. YouTube

YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, United States.

On our company profile we provide information and offer YouTube users the possibility of communication. If you carry out an action on our YouTube company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by YouTube, we cannot make any binding statements regarding the purpose and scope of the processing of your data.

We integrated social media platforms on our website via links, which may result in social media providers receiving data from you if necessary.

Publications on the company profile can contain the following content:

• Information about services
• Advertisement
• Customer contact

Every user is free to publish personal data.

The legal basis for data processing is Art. 6 (1) (1) (a) GDPR.

In order to ensure appropriate safeguards to protect the transfer and processing of personal data outside the EU, the transfer of data to and processing of data by YouTube shall be based on appropriate safeguards pursuant to Art. 46 et seq. GDPR, in particular by concluding so-called standard data protection clauses pursuant to Art. 46 para. 2 c) GDPR.

The data generated on the company profile is not stored in our own systems.

You can object at any time to the processing of your personal data that we collect within the framework of your use of our YouTube corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to privacy@rows.com. For further information on the processing of your personal data by YouTube and the corresponding objection options, please click here: https://policies.google.com/privacy?gl=DE&hl=en.

16.3. GitHub

GitHub Inc., 88 Colin P. Kelly Jr. St., San Francisco, CA 94107, USA.

On our company profile we provide information and offer GitHub users the possibility of communication. If you carry out an action on our GitHub company profile (e.g. comments, contributions etc.), you may make personal data (e.g. clear name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by GitHub, we cannot make any binding statements regarding the purpose and scope of the processing of your data.

We integrated this platform on our website via links, which may result in GitHub receiving data from you if necessary.

Publications on the company profile can contain the following content:

• Information about open job positions
• Candidate contact

The legal basis for data processing is Art. 6 (1) (1) (a) GDPR.

Part of GitHub’s terms of use are so-called EU standard contractual clauses (Art. 46 (2) (1) (c) GDPR). These are to be classified as an appropriate guarantee for the protection of the transfer and processing of personal data outside the EU.

The data generated on the company profile are not stored in our own systems.

You can object at any time to the processing of your personal data that we collect within the framework of your use of our GitHub corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to privacy@rows.com. For further information on the processing of your personal data by GitHub and the corresponding objection options, please click here: https://docs.github.com/en/github/site-policy/github-privacy-statement.

16.4. LinkedIn

16.4.1. Description and scope of data processing

LinkedIn, Unlimited Company Wilton Place, Dublin 2, Ireland.

On our site we provide information and offer users the possibility of communication.

The corporate profile is used for job applications, company information, advertisements, public relations, and active sourcing.

We do not have any information on the processing of your personal data by the companies jointly responsible for the corporate profile. Further information can be found in the privacy policy of: https://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv.

If you carry out an action on our company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public.

Part of LinkedIn's terms of use are so-called EU standard contractual clauses (Art. 46 (2) (1) (c) GDPR). These are to be classified as an appropriate guarantee for the protection of the transfer and processing of personal data outside the EU.

16.4.2. Legal basis for data processing

The legal basis for the processing of your data in connection with the use of our corporate web profile is Art. 6 (1) (1) (f) GDPR and § 26 (1) (1) BDSG (Federal Act of Data Protection) in case of applications.

16.4.3. Purpose of the data processing

Our corporate web profile serves to inform users about our services. Every user is free to publish personal data.

16.4.4. Duration of storage

We store your activities and personal data published via our corporate web profile until you withdraw your consent. In addition, we comply with the statutory retention periods.

16.4.5. Objection and removal

You can object at any time to the processing of your personal data which we collect within the scope of your use of our corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to the email address stated in this privacy policy.

You can find further information on objection and removal options here: https://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv.

This privacy policy has been created with the assistance of DataGuard.