Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.
Contact us if you have any questions or problems regarding the use of your Personal Data and we will gladly assist you.
Table of Contents
- Definitions used in this policy
- Principles we follow for processing Personal Data
- Legal bases for processing Personal Data
- Your rights regarding your Personal Data
- What information we ghater about you
- How and why we process Personal Data
- Sharing information
- How long we keep information
- Contact information
Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data Subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
We/Us (either capitalized or not) – Wisycom Srl
Our Websites – wisycom.com wisycom.fr wisycom.de wisycomusa.com
Principles We Follow for Processing Personal Data
We process your Personal Data according to the following data protection principles:
* Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
* Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
* Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
* Processing is limited with a time period. We will not store your Personal Data for longer than needed.
* We will do our best to ensure the accuracy of data.
* We will do our best to ensure the integrity and confidentiality of data.
Legal Bases for Processig Personal Data
We process your Personal Data on the grounds that:
* The use is necessary in order to fulfill our commitments to you under our Terms of Service or other agreements with you or is necessary to administer your account (for example, in order to enable access to our website);
* The use is necessary for compliance with a legal obligation;
* The use is necessary in order to protect your vital interests or those of another person;
* We have a legitimate interest in using your information, for example, to provide and update our Services, to improve our Services so that we can offer you an even better user experience, to safeguard our Services, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with our Services;
Data Subject’s Rights
If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (AKA the “GDPR”), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the following rights:
- Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
- Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
- Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
- Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
- Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
- Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data (for example in the case of direct marketing).
- Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
- Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
- Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
- Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
- Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.
You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to do that, or you would like to contact us about one of the other rights, scroll down to How to Reach Us to, well, find out how to reach us. EU individuals also have the right to make a complaint to a government supervisory authority.
Information We Collect
We only collect information about you if we have a reason to do so (for example, to provide our Services, to communicate with you, or to make our Services better). We collect information in three ways: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.
Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:
- Basic Account Information: We ask for basic information from you in order to set up your account on one of our websites. For example, we require individuals who sign up for an account to provide a username and email address–and that’s it. You may provide us with more information (like your name) but we don’t require that information to create an account.
- Public Profile Information: If you have an account with us, we collect the information that you provide for your public profile. For example, if you have an account, your username is part of that public profile, along with any other information you put into your public profile, such as a photo or an “About Me” description. Your public profile information is just that–public–so please keep that in mind when deciding what information you would like to include.
- Transaction and Billing Information: If you buy something from us (a subscription to a specific plan, or a physical or digital product. For example, you will provide additional personal and payment information that is required to process the transaction and your payment, such as your name, credit card information, and contact information.
- Content Information: Depending on the Services you use, you may also provide us with information about you in draft and published content (such as for your website or your Polldaddy survey). For example, if you write a blog post that includes biographic information about you, we will have that information, and so will anyone with access to the Internet if you choose to publish the post publicly. This might be obvious to you…but it’s not to everyone!
- Communications With Us (Hi There!): You may also provide us information when you respond to surveys or communicate with our Happiness Engineers about a support question.
Information We Collect Automatically
We also collect some information automatically:
- Log Information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services (for example, when you create or make changes to your account).
- Usage Information: We collect information about your usage of our Services (e.g. page views), along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, as well as get insights on how people use our Services, so we can make our Services better.
- Location Information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions.
Information We Collect from Other Sources
We may also get information about you from other sources. For example, if you create or log into your account through another service (like Google) or if you connect your account to a social media service (like Twitter or Facebook), we will receive information from that service (such as your username, basic profile information, and friends list) via the authorization procedures used by that service. The information we receive depends on which services you authorize and any options that are available. We may also get information, such as a mailing address, from third party services about individuals who are not yet our users (…but we hope will be!), which we may use, for example, for marketing and advertising purposes like postcards and other mailers advertising our services.
How And Why We Process Personal Data
Purposes for Process Personal Data
We use information about you as mentioned above and for the purposes listed below:
- To provide our Services (for example, to set up and maintain your account or charge you for any of our paid Services);
- To further develop and improve our Services;
- To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;
- To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition (for example, we may analyze how many individuals purchased a plan after receiving a marketing message or the features used by those who continue to use our Services after a certain length of time);
- To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of Wisycom Srl and others, which may result in us declining a transaction or the use of our Services;
- To communicate with you (for example through an email, about offers and promotions offered by Wisycom Srl and others we think will be of interest to you), solicit your feedback, or keep you up to date on Wisycom Srl and our products;
- To personalize your experience using our Services, target our marketing messages to groups of our users (for example, those who have a particular plan with us or have been our user for a certain length of time), and serve relevant advertisements.
How We Share Information
We do not sell our users’ private personal information. We only work with Processing partners who are able to ensure adequate level of protection to your Personal Data. We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:
- Legal Obligation: We may disclose information about you in response to a governmental request when we are legally obliged to do so, or if there are other legal grounds for it.
- To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Wisycom Srl, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury.
- With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorize us to do so, such as the social media services that you connect to your personal account through our social login feature.
- Aggregated or De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services and we may share a hashed version of your email address to facilitate customized ad campaigns on other platforms.
- Published Support Requests: And if you send us a request (for example, via a support email or one of our feedback mechanisms), we reserve the right to publish that request in order to help us clarify or respond to your request or to help us support other users.
Information Shared Publicly
Information that you choose to make public is–you guessed it–disclosed publicly. That means, of course, that information like your public profile, bio or other content that you make public on our websites, and your “Likes” and comments, are all available to others. For example, the photo that you upload to your public profile.
Public information may also be indexed by search engines or used by third parties. Please keep all of this in mind when deciding what you would like to share.
Information Shared Outside EEA
- In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield; or
- In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.
How Long We Keep Information
We generally discard information about you when we no longer need the information for the purposes for which we collect and use it (which are described in the section above on How and Why We Use Information) and we are not legally required to continue to keep it. For example, we keep the web server logs that record information about a visitor to one of our websites, such as the visitor’s IP address, browser type, and operating system, for approximately 30 days. We retain the logs for this period of time in order to, among other things, analyze traffic to Wisycom Srl’s websites and investigate issues if something goes wrong on one of our websites. As another example, when you delete a post, page, or comment from our sites, it stays in your Trash folder for thirty days just in case you change your mind and would like restore that content (because starting again from scratch is no fun, at all). After the thirty days are up, the deleted content may remain on our encrypted backups and caches until purged.
While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymising and pseudonymising where suitable. We monitor our Services for potential vulnerabilities and attacks. We implement a robust encrypted backup strategy.
You have several choices available when it comes to information about you:
- Limit the Information that You Provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services may not be accessible.
- Opt-Out of Electronic Communications: You may opt out of receiving promotional messages from us. Just follow the instructions in those messages. If you opt out of promotional messages, we may still send you other messages, like those about your account and legal notices.
- Set Your Browser to Reject Cookies.
- Export your Data or Delete your Account and Data: On our Privacy Tools Page you can download your data or, if you no longer want to use our Services, close your account and delete your data. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above (for example, when that information is reasonably needed to comply with or demonstrate our compliance with legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.
Government Supervisory Authority