1. Introduction
This Privacy Policy explains how M.M. INTERACTIVE SOLUTIONS LTD (“Centrify 360”, “we”, “us” or “our”) collects, uses, discloses, and protects personal data when you visit our websites (including centrify360.com and docs.centrify360.com) and when you use Centrify 360 products and services, including the Centrify 360 ETL managed application for Microsoft Azure and related connectors and analytics content (collectively, the “Services”).
We are committed to protecting your privacy and processing personal data in compliance with applicable data protection laws, including the EU General Data Protection Regulation (“GDPR”) where it applies.
2. Data controller and contact details
For processing activities described in this Privacy Policy, the data controller is:
M.M. INTERACTIVE SOLUTIONS LTD
Konstantinopoleos 16
Aglantzia 2107
Nicosia, Cyprus
Email: info@centrify360.com
When we process personal data on behalf of our customers as part of providing the Centrify 360 platform (for example, processing Dynamics 365 Business Central data in your Azure subscription), we act as a data processor, and the customer acts as the data controller.
3. Scope of this policy
This policy covers:
- Visitors to our websites and documentation portals.
- Prospective customers, partners, and trial users.
- Authorized users of Centrify 360 Services, including the Azure managed application, Business Central connector, and Power BI content.
- Individuals whose personal data may be included in customer data processed by Centrify 360 on behalf of our customers.
Where we process personal data solely on behalf of a customer, the customer’s privacy notice and instructions will primarily govern how that data is used.
4. Personal data we collect
Depending on how you interact with us, we may process the following categories of personal data:
- Account and contact data: Name, company name, role, email address, phone number, billing details, and subscription information.
- Authentication and access data: Login identifiers, tenant IDs, role assignments, and audit information related to user access and administrative actions.
- Support and communication data: Content of emails and support tickets, chat logs, and other correspondence with our team.
- Website and usage data: IP address, browser type, device identifiers, pages visited, referrer URLs, time and date of visits, and interactions with documentation and marketing content (collected via cookies and similar technologies, where permitted by law).
5. How we collect personal data
We may collect personal data:
- Directly from you when you request information, start a trial, sign a contract, register for an account, or contact support.
- Indirectly from your use of our websites and Services, through logs, telemetry, and usage analytics.
- From our partners and resellers who resell, implement, or support Centrify 360 (for example, to register opportunities or provision access for your users).
6. Legal bases for processing
Where GDPR or similar laws apply, we rely on one or more of the following legal bases:
- Performance of a contract: To provide and operate the Services you have requested, including deployment of the Azure managed application and related support.
- Legitimate interests: To maintain and improve our Services, secure our infrastructure, prevent abuse or fraud, and communicate with you as a business contact, where these interests are not overridden by your privacy rights.
- Consent: For certain marketing communications, cookies, or where required by law.
- Legal obligations: To comply with accounting, tax, and other regulatory requirements.
7. How we use personal data
We use personal data for the following purposes:
- To provision, configure, and operate the Centrify 360 Services you subscribe to.
- To provide customer support, technical assistance, and incident response.
- To maintain and improve the security, performance, and reliability of our Services.
- To send marketing communications where permitted, and to analyze interest in our products and features (you can opt out of marketing at any time).
- To comply with our legal and regulatory obligations.
We do not sell personal data.
8. Data retention
We retain personal data only for as long as necessary for the purposes described in this policy, including:
- For the duration of your subscription or contractual relationship and a reasonable period thereafter for backups, dispute handling, and legal obligations.
- For shorter periods where you unsubscribe from marketing or request deletion.
9. Sharing and sub‑processors
We may share personal data with:
- Service providers and sub‑processors who support our operations (for example, cloud hosting providers, monitoring and logging services, email delivery, and customer support tools).
- Microsoft Azure and related services, where necessary to deploy and operate the managed application in your subscription.
- Partners and resellers, where you purchase Centrify 360 through a partner or request local implementation and support.
- Professional advisers, such as lawyers, accountants, and auditors, where necessary.
- Public authorities, where required by law or in response to valid legal processes.
We require sub‑processors to implement appropriate security measures and process personal data only in accordance with our instructions and applicable data protection laws. A current list of sub‑processors is available on request and may be updated from time to time.
10. Security
We take appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures include, as applicable:
- Use of secure communication protocols (such as HTTPS/TLS).
- Access controls and role‑based permissions.
- Encryption at rest and in transit where supported by the underlying cloud services.
- Logging, monitoring, and audit capabilities.
- Secure development and operational practices, including updates and vulnerability management.
You are responsible for maintaining the security of your own Azure environment, Business Central configuration, user accounts, and authentication mechanisms
11. Customer responsibilities
As a customer:
- You are responsible for configuring Centrify 360, the Azure managed application, and Dynamics 365 Business Central in a way that complies with your own legal and regulatory obligations.
- You should ensure that you have an appropriate legal basis for processing personal data in Centrify 360 and that you provide adequate privacy notices to your end users.
- You should limit the data you synchronize to what is necessary for your reporting and analytics purposes.
Where required, we will enter into a data processing agreement (“DPA”) with you that supplements this Privacy Policy and governs our processor obligations.
12. Data subject rights
Subject to applicable law, individuals may have the right to:
- Access their personal data and obtain a copy.
- Request correction of inaccurate or incomplete data.
- Request deletion of personal data, or restriction of processing.
- Object to certain processing, including direct marketing.
- Withdraw consent where processing is based on consent (without affecting prior processing).
- Data portability, in some circumstances.
- Lodge a complaint with a supervisory authority.
You can contact us using the details in section 2 to exercise your rights in relation to data we control directly.
13. Cookies and tracking technologies
Our websites and documentation portals may use cookies and similar technologies to:
- Enable core site functionality.
- Remember your preferences (for example, language settings).
- Analyze usage of our content to improve our Services.
- Support marketing and campaign measurement, where permitted.
Where required by law, we will request your consent before setting non‑essential cookies. You can manage your cookie preferences through your browser settings and, where provided, through our cookie banner or settings page.
14. Children’s privacy
Our Services are intended for business users and are not directed at children. We do not knowingly collect personal data from children under the age of 16. If you believe that a child has provided us with personal data, please contact us so we can delete it.
15. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our Services, legal requirements, or business practices. The “Last updated” date at the top of the policy will indicate when it was last revised. We encourage you to review this page regularly for the latest information.
Where changes are material, we may provide additional notice (for example, by email or through the Services).
16. How to contact us
If you have any questions or concerns about this Privacy Policy or our data protection practices, please contact us at:
M.M. INTERACTIVE SOLUTIONS LTD
Konstantinopoleos 16
Aglantzia 2107
Nicosia, Cyprus
Email: info@centrify360.com