Policy last updated: January 31, 2019
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.
1. Please read carefully!
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 , 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.
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.
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
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 . 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
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 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.
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 .
16. Updates and interpretation
17. Contacting us
You may also contact us by mail at: Juliana Van Stolberglaan St., The Hague 2595 CR, The Netherlands.