Wcm Software Privacy Policy
Policy last updated: January 31, 2019
Welcome to Wcm Software Privacy Policy!
Wcm Software cares deeply about the privacy of its visitors
and users, and is fully committed to protect their personal information and use
it properly in compliance with data privacy laws. This policy describes how we
may collect and use personal information, and the rights and choices available
to our visitors and users regarding such information.
We strongly urge you to read this policy and make sure you fully understand
it, before you access or use any of our services.
Capitalized terms which are not defined herein shall have the meaning
ascribed to them in our Terms of Use.
1. Please read carefully!
This Wcm Software Privacy Policy (“Privacy Policy”) describes
how we (Wcm Software ,“WCM”, “we” or “us”) collect and use
information pertaining to each of our unregistered visitors and customers, including users with Paid Services
(each, a “Visitor”, “Customer”, “User” (respectively),
or “you”), in connection with their access to and use of WCM Website, WCM Platform (“WCM Platform” , “Customer Platform” or “Customer Account”) and related services (collectively, the “Services”).
The purpose of this Privacy Policy is to provide you with a clear
explanation of when, why and how we collect and use your personal information,
as well as an explanation of your statutory rights. This Privacy
Policy is not intended to override the terms of any contract you have with us,
or any rights you might have under applicable data privacy laws.
Read this policy and make sure you fully understand our practices in relation
to your personal information, before you access or use any of our Services.
If you read and fully understand this Privacy Policy, and remain opposed
to our practices, you must immediately leave this website, application or
service, and avoid or discontinue all use of any of our Services. If you
have any questions or concerns regarding this policy, please contact us at
info@wcm.software
2. What information do we collect?
2.1. Visitor and Customer (“User”) Information
We collect two types of information regarding our Visitors and Users:
1. Un-identified and
non-identifiable information pertaining to a Visitor or un-identified User,
which may be made available to us, or collected automatically via his/her use
of the Services (“Non-personal Information”). Such Non-personal Information
does not enable us to identify the Visitor or User from whom it was collected.
The Non-personal Information collected by us mainly consists of technical and
aggregated usage information, such as Visitors’ and Users’ browsing on the
Services, non-identifying information regarding the Visitor’s or User’s device,
operating system, internet browser, screen resolution, language and keyboard
settings, internet service provider, referring/exit pages, date/time stamps,
etc.
2. Individually
identifiable information, namely information that identifies an individual or
may with reasonable efforts cause the identification of an individual, or may
be of private or sensitive nature (“Personal Information”). The Personal
Information collected by us mainly consists of contact details (e.g., e-mail
address or phone number), billing details (name, physical billing address,
payment method and transaction details), which are only collected from Users
with Paid Services, details regarding a browsing or usage session (IP address,
Geo-location and/or device unique identifier),
details regarding connected third party accounts (such as the e-mail
or username for a connected PayPal account), correspondences (including those made through or uploaded to our Services),
and any other Personal Information provided to us by Visitors and/or Users
through their access to and/or use of the Services. For the avoidance of doubt,
any Non-personal Information that is connected or linked to Personal
Information (for example, in order to improve the Services we offer) is deemed
and treated by us as Personal Information, as long as such connection or
linkage exists.
2.2. Users of Users Information
We may also collect similar information pertaining to visitors and users of
our User’s websites or services (“Users-of-Users”), solely for and on our
Users’ behalf (as further described in Section 6 below).
3. How do we collect such information?
There are two main methods we use:
1. We collect information
through your use of the Services. When you visit or use our Services,
including when you browse the Website or any User Website, register a Customer Account, edit your Customer
Platform and upload information and content, we are aware of it and will usually
gather, collect and record such uses, sessions and related information, either
independently or with the help of third-party services as detailed in Section 8 below,
including through the use of “cookies” and other tracking technologies, as
further detailed in Section 9 below.
2. We collect information
which you provide us voluntarily. For example, we collect the Personal
Information you provide us when you register to our Services; when you submit
or upload such Personal Information as you use any of our Services; and/or when
you contact us directly by any communication channel (e.g., WCM’s
emails).
3. We also collect
information from third party sources as described in Section 8 below.
4. Why do we collect such information?
We collect such Non-personal and Personal Information for the following
purposes:
1. To provide and operate
the Services;
2. To further develop, customize
and improve our Services, based on Visitors’ and Users’ common or personal
preferences, experiences and difficulties;
3. To provide our Users
with ongoing customer assistance and technical support;
4. To be able to contact
our Customers and Users with general
or personalized service-related notices and messages (as further
detailed in Section
10 below);
5. To create aggregated
statistical data and other aggregated and/or inferred Non-personal Information,
which we or our business partners may use to provide and improve our respective
services;
6. To enhance our data
security and fraud prevention capabilities;
7. To comply with any
applicable laws and regulations.
We will only use your Personal Information for the purposes set out in
Section 4 where we are satisfied that:
1. our use of your
Personal Information is necessary to perform a contract or take steps to enter
into a contract with you (e.g. to provide you with our customer assistance and
technical support), or
2. our use of your
Personal Information is necessary to comply with a relevant legal or regulatory
obligation that we have, or
3. our use of your
Personal Information is necessary to support legitimate interests that we have
as a business (for example, to maintain and improve our Services by identifying
user trends and the effectiveness of WCM campaigns and identifying technical
issues), provided it is conducted at all times in a way that is proportionate,
and that respects your privacy rights.
5. Where do we store your information?
Wcm Software is based in The Hague, The Netherlands. WCM Visitors’, WCM Users’ and
Users-of-Users’ Personal Information may be maintained, processed and
stored by WCM in Europe, in secured servers provided by our Third Party Services.
WCM service providers that store or process your Personal Information
on WCM’s behalf are each contractually committed to keep it protected and
secured, in accordance with industry standards and regardless of any lesser
legal requirements which may apply in their jurisdiction.
6. Users-of-users’ information
WCM may collect, store and process certain Non-personal and Personal
Information of Users-of-Users (“Users-of-Users Information”), solely on our
Users’ behalf and at their direction. For example, each of our Users is able
collect and manage contacts via their User Website. Such contacts are then
stored with WCM, on the User’s behalf.
For such purposes, WCM serves and shall be considered as a “Processor” and
not as the “Controller” (as both such capitalized terms are defined in the
European Union General Data Protection Regulation) of such Users-of-Users
Information. The Users controlling and operating such User Websites shall be
considered as the “Controllers” of such Users-of-Users Information, and are
responsible for complying with all laws and regulations that may apply to the
collection and control of such Users-of-Users Information, including all
privacy and data protection laws of all relevant jurisdictions.
You are responsible for the security, integrity and authorized usage of
your Users-of-Users’ Personal Information, and for obtaining consents,
permissions and providing any fair processing notices required for the
collection and usage of such information.
WCM cannot provide legal advice to Users or their Users-of-Users, however
we do recommend that all Users publish and maintain clear and comprehensive
privacy policies on their User Websites, in accordance with the applicable laws
and regulations, and that all Users-of-Users carefully read those policies and
make sure that they consent to them.
For more information on how Users-of-Users Information may be handled by
WCM (which may be relevant for the specific notice you provide to and/or
consent you obtain from your Users-of-Users), please see Sections 8,
13 and
15 below.
If you are a visitor, user or customer of any of our Users, please read the
following: WCM has no direct relationship with the individual
Users-of-Users whose Personal Information it processes. If you are a visitor,
user or customer of any of our Users, and would like to make any requests or
queries regarding your Personal Information, please contact such User(s)
directly. For example, if you wish to access, correct, amend, or delete inaccurate
information processed by WCM on behalf of its Users, please direct your query
to the relevant User (who is the “Controller” of such data). If requested to
remove any Users-of-Users’ Personal Information, we will respond to such
request within thirty (30) days. Unless otherwise instructed by our User, we
will retain their Users-of-Users’ Personal Information for the period set forth
in Section
13 below.
7. WCM Free Account
WCM welcomes all startups to apply in order to receive a Demo Account ( “Free account”) published at https://wcm.software, by sending us their contact details and project requirements (“Free Account Information”) by email or through any other means provided by us.
We understand that privacy and discreetness are crucial to our customers, and are committed to keep Free Account
Information private and use it solely for WCM’s internal recruitment purposes.
8. Sharing personal information with
third parties
WCM may share your Personal Information with third parties (or otherwise
allow them access to it) only in the following manners and instances:
8.1. Third Party Services:
WCM has partnered with a number of selected service providers, whose
services and solutions complement, facilitate and enhance our own. These
include hosting and server co-location services, communications and content
delivery networks (CDNs), data and cyber security services, billing and payment
processing services, domain name registrars, fraud detection and prevention
services, web analytics, e-mail distribution and monitoring services, session
recording and remote access services, performance measurement, data
optimization and marketing services, content providers, and our legal and
financial advisors (collectively, “Third Party Service(s)”).
Such Third Party Services may receive or otherwise have access to our
Visitors’ and Users’ Personal Information and/or Users-of-Users’ Personal
Information, in its entirety or in part – depending on each of their particular
roles and purposes in facilitating and enhancing our Services and business, and
may only use it for such purposes.
8.2. Law Enforcement, Legal Requests and
Duties:
Where permitted by local data protection laws, WCM may disclose or
otherwise allow others access to your Personal Information pursuant to a legal
request, such as a subpoena, legal proceedings, search warrant or court order,
or in compliance with applicable laws, if we have good faith belief that
the law requires us to do so, with or without notice to you.
8.3. Protecting Rights and Safety:
WCM may share your Personal Information with others if we believe in good
faith that this will help protect the rights, property or personal safety of
WCM, any of our Users, any Users-of-Users, or any member of the general public,
with or without notice to you.
9. Use of cookies and other tracking
technologies
WCM, together with its marketing, analytics and technology partners, uses
certain monitoring and tracking technologies (such as cookies, tags and
scripts). These technologies are used in order to maintain, provide and improve
our Services on an ongoing basis, and in order to provide our Visitors, our
Users and their Users-of-Users with a better experience. For example, thanks to
these technologies, we are able to maintain and keep track of our Visitor’s and
Users’ preferences and authenticated sessions, to better secure our Services,
to identify technical issues, user trends and effectiveness of campaigns, and
to monitor and improve the overall performance of our Services.
Please note that Third Party Services placing cookies or utilizing other
tracking technologies through our Services may have their own policies
regarding how they collect and store information. Such practices are not
covered by our Privacy Policy and we do not have any control over them.
Cookies: In order for some of these technologies to work properly, a
small data file (“cookie”) must be downloaded and stored on your device. By
default, we use several persistent cookies for purposes of session and user
authentication, security, keeping the User’s preferences (e.g., regarding
default language and settings), connection stability, monitoring performance of
our services, and generally providing and improving our services.
If you want to delete or block any cookies, please refer to the help and
support area on your internet browser for instructions on how to locate the
file or directory that stores cookies. Please note that deleting our cookies or
disabling future cookies or tracking technologies may prevent you from
accessing certain areas or features of our Services, or may otherwise adversely
affect your user experience.
10. Communications from WCM
Service and Billing Messages:
WCM may contact you with important information regarding our Services, or
your use thereof.
For example, we may send you a notice (through any of the means available
to us) if a certain Service is temporarily suspended for maintenance; reply to
your e-mail; send you reminders or warnings regarding upcoming or late payments
for your current or upcoming subscriptions; forward abuse complaints regarding
your User Website; or notify you of material changes in our Services.
It is important that you are always able to receive such messages. For this
reason, you are not be able to opt-out of receiving such Service and
Billing
Messages unless you are no longer a WCM Visitor or User (which can be done
by deactivating your account).
11. Your rights in relation to your
personal information
It is imperative that you have control over your Personal Information.
That’s why WCM is taking steps to enable you to access, update,
amend, delete, or limit the use of your Personal Information.
Before disclosing the requested Personal Information, we may ask you
for additional information in order to confirm your identity and for security
purposes. We reserve the right to charge a fee where permitted by law
(e.g., if your request is unfounded or excessive).
You have the right to file a complaint with your local supervisory
authority for data protection (but we still recommend that you contact us
first).
If you are a WCM Visitor or User, and you wish to receive a copy, access
and/or request us to make corrections to the Personal Information that you have
stored with us (either yours or your Users-of-Users’), you are welcome to
contact us at info@wcm.software. You can also, mail your request to WcmSoftware, The Hague 2595 CR, The Netherlands.
We will make all reasonable efforts to honor your request promptly
(unless we require further information from you in order to fulfil your
request), subject to legal and other permissible considerations.
Please note that permanently deleting your WCM account erases all of your
information from WCM's databases. After completing this process, you can no
longer use any of your WCM services, your account and all its data will be
removed permanently, and WCM will not be able to restore your account or
retrieve your data in the future. If you contact WCM Support in the future, the
system will not recognize your account and WCM Support will not be able to locate the deleted account.
12. Questions and Complaints
If you have any questions or concerns about our collection, use or
disclosure of Personal Information, or if you believe we have not complied with
this Privacy Policy or applicable data protection laws, please contact us – our
details are set out at the end of this Privacy Policy.
We will investigate the
complaint and determine whether a breach has occurred and what action, if any,
to take.
We take every privacy complaint seriously and will make all reasonable
efforts to resolve your complaint promptly. Our target response time is
30 days.
We expect our procedures will deal fairly and promptly with your complaint.
However, if you remain dissatisfied, you can also make a complaint with your
local supervisory authority for data protection.
You can file a complaint with your local supervisory authority for data
protection at any time, however we recommend that you contact us first so we
can try to resolve it.
13. Data Retention
We may retain your Personal Information (as well as your Users-of-Users’
Information) for as long as your User Account is active, as indicated in this
Privacy Policy or as otherwise needed to provide you with our Services.
We may continue to retain such Personal Information even after you
deactivate your User Account and/or cease to use any particular Services, as
reasonably necessary to comply with our legal obligations, to resolve disputes
regarding our Users or their Users-of-Users, prevent fraud and abuse, enforce
our agreements and/or protect our legitimate interests.
We maintain a data retention policy which we apply to information in our
care. Where your Personal Information is no longer required we will ensure it
is securely deleted.
14. Public user content
If you upload any User Content to your User Account
or post it on your User Website and provide it in any other way as part of the
use of any Service, you do so at your own risk.
We have put adequate security measures in place to protect your Personal
Information. However, we cannot control the actions of other Users or
members of the public who may access your User Content, and are not responsible
for the circumvention of any privacy settings or security measures you or we
may have placed on your User Website (including, for instance, password-protected
areas on your User Website). You understand and acknowledge that, even after
its removal by you or us, copies of User Content may remain viewable in cached
and archived pages or if any third parties (including any of your
Users-of-Users) have copied or stored such User Content. To clarify, we
advise against uploading or posting any information you do not wish
to be public.
15. Security
WCM has implemented security measures designed to protect the Personal
Information you share with us, including physical, electronic and procedural
measures. Among other things, we offer HTTPS secure access to most areas on our
Services; the transmission of sensitive payment information through our
designated purchase forms is protected by an industry standard SSL/TLS encrypted
connection. We also regularly monitor our systems for possible
vulnerabilities and attacks, and regularly seek new ways and Third Party
Services for further enhancing the security of our Services and protection of
our Visitors’ and Users’ privacy.
Regardless of the measures and efforts taken by WCM, we cannot and do not
guarantee the absolute protection and security of your Personal Information,
your Users-of-Users’ Information or any other User Content you upload, publish
or otherwise share with WCM or anyone else.
We therefore encourage you to set strong passwords for your User Account
and User Website, and avoid providing us or anyone with any sensitive
information of which you believe its disclosure could cause you substantial or
irreparable harm. Furthermore, because certain areas on our Services are less
secure than others (for example if you browse to a non-SSL page), and since
e-mail and instant messaging are not recognized as secure forms of
communications, we request and encourage you not to share any Personal
Information on any of these areas or via any of these methods.
If you have any questions regarding the security of our Services, you are
welcome to contact us at info@wcm.software.
16. Updates and interpretation
We may update this Privacy Policy as required by applicable law, and to
reflect changes to our information collection, usage and storage practices. If
we make any changes that we deem as “material” (in our sole good faith
discretion), we will notify you (using one of the notification methods set
forth in Section
12.3 of the Terms of Use) prior to the change becoming effective. We
encourage you to periodically review this page for the latest information on
our privacy practices.
Unless stated otherwise, our most current Privacy Policy applies to
all information that we have about you and your Users-of-Users, with respect to
our Website, WCM Platform, WCM Control Panel and other Services.
This Privacy Policy was written in English, and may be translated into
other languages for your convenience.
17. Contacting us
If you have any questions about this Privacy Policy or wish to exercise any
of your rights as described in Section 11, please contact us at info@wcm.software. We will attempt to resolve any
complaints regarding the use of your Personal Information in accordance with
this Privacy Policy.
You may also contact us by mail at: Juliana Van Stolberglaan St., The Hague 2595 CR, The Netherlands.