1.1 We are committed to safeguarding the privacy of our website visitors and customers; in this policy we explain how we will handle your personal data.
2. How we use your personal data
2.1 In this Section 2 we have set out:
- the general categories of personal data that we may process;
- the purposes for which we may process personal data; and
- the legal bases of the processing.
2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The sources of the usage data are defined in section 2.10. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data ("account data"). The account data may include your name, email address, company name and telephone number. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.4 We may process information and files that you post for publication on our website or upload through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and delivering our services. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. We do not scan or process the files you upload in our service for any marketing purposes.
2.5 We may process information contained in any enquiry you submit to us regarding our services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is our legitimate interest, namely our responsibility to respond to your enquiry.
2.6 We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your company name, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships. More specifically, we may reach out to you when you have registered for our services by email or phone. In addition to this, when you sign up for our services you will receive operational emails about the progress of your trial and you will receive information about how you can get the most out of your trial.
2.7 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
2.8 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
2.9 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.10 We use third-party tools to process the personal data as stated in the articles above (articles 2.3 to 2.9). On our website or services the following tools might process your personal data:
2.11 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.12 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.13 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3. Automated decision-making
3.1 We will use your personal data for the purposes of automated decision-making in relation to your usage of our services.
3.2 This automated decision-making will involve specific emails, notifications, tutorials and other kind of in-app content based on your actions within our service. For example, we might send you a email which explains how you can upload a file when you haven’t uploaded content before.
3.3 The significance and possible consequences of this automated decision-making have a low significance and no crucial consequences. It will influence the content and frequency of our communication and influence your experience within our services, but it has no major implications.
4. Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Information about our group of companies can be found at https://www.woodwing.com/en/contact-us
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 We may disclose your contact information to our business partners identified at https://www.woodwing.com/en/partners insofar as reasonably necessary for the follow up of your interest in our goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it.
4.4 Financial transactions relating to our services may be handled by our payment services provider Fastspring. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services provider privacy policies and practices at https://fastspring.com/privacy.
4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 We have offices in The Netherlands, The United States of America, and Malaysia. Transfers to and from The United States of America will be protected by appropriate safeguards, namely the Privacy Shield, a copy of which can be obtained from https://www.privacyshield.gov/EU-US-Framework. Transfers to and from Malaysia are based on article 49 of the GDPR (limited transfers for compelling legitimate interests).
5.3 We use the Amazon Web Services infrastructure for the hosting of our website and services. This infrastructure is currently situated in the EU, the United States of America, Singapore and Australia. Your data is stored in one of these regions. The choice for a specific region is automatically made when you register for our services based on the location of your IP address during this registration or manual selected by you in the onboarding process. We may decide in the future to move your data within a region in order to optimize our hosting facilities and infrastructure, while respecting regional legalisation.
5.4 Your personal data might be processed by the third-party tools as described in article 2.10. We refer to their privacy policies for more information about the location of their services.
5.5 While most of your data is not publicly available, you acknowledge that some personal data that you submit through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others. This data can be for example available through a public Sharelink or a public Portal which you have setup or generated.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
- your files and data from our services (this may include your files, metadata and any other data from our service) will be retained as long as needed to provide our services. After cancellation of our services, or the ending of a trial we will keep your data for a minimum of 3 months and a maximum period of 12 months.
- your data regarding tracking, analytics and usage of our website and service will be retained for a maximum period of 26 months.
- enquiry data will be retained for a minimum and maximum period of five years following the last enquiry submission.
- customer relationship data will be retained for a minimum period of five years following the start of the relationship, and for a maximum period of five years following the last interaction.
- transaction data will be retained for a minimum period of seven years following the transaction, and for a maximum period of ten years following the transaction.
- notification data will be retained for a minimum period of the length of the subscription to these notifications following the moment of subscription, and for a maximum period of 26 months following the end of the subscription.
- correspondence data will be retained for a minimum period of five years following the first correspondence, and for a maximum period of five years following the last correspondence.
6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
- the period of retention will be determined based on usefulness of the data.
6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of significant changes to this policy by email.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 To the extent that the legal basis for our processing of your personal data is:
- consent; or
- that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us via email at email@example.com
9. Third party websites
9.1 Our website includes hyperlinks to, and details of, third party websites.
9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
10. Updating information
10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
11. About cookies
11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
12. Cookies that we use
13. Cookies used by our service providers
14. Managing cookies
14.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- https://support.google.com/chrome/answer/95647?hl=en (Chrome);
- https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
- http://www.opera.com/help/tutorials/security/cookies/ (Opera);
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- https://support.apple.com/kb/PH21411 (Safari); and
- https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
14.2 Blocking all cookies will have a negative impact upon the usability of many websites.
14.3 If you block cookies, you will not be able to use all the features on our website.
15. Our details
15.1 This website is owned and operated by WoodWing Software.
15.2 We are registered in The Netherlands under Chamber of Commerce number NL808758597B01, and our registered office is at Ronde Tocht 1D, 1507CC Zaandam, The Netherlands.
15.3 Our principal place of business is at Ronde Tocht 1D, 1507CC Zaandam, The Netherlands.
15.4 You can contact us:
- by email, using the email address published on our website.
- by telephone, on +31 75 61 43 400
Version April 17, 2020
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