We at W&Sin (hereinafter “we”, “us” and “our” for the purposes of this Privacy Policy) know you care about your privacy, and so do we. We have developed this Privacy Policy to describe the types of Personal Information we may collect, how we may use and share that information, our lawful basis for processing it, what rights you have in relation to your Personal Information and how we protect it.
Our Services
In addition to, and included in, the W&Sin , W&Sin provides security and identity product offerings (which includes the Badge and Communicator applications), branded together as W&Sin (“W&Sin”) as part of a service that is hosted by W&Sin or a third-party service provider on behalf of W&Sin (a “Cloud Implementation”).
We may collect or receive Personal Information about you in various ways, depending on which of our applications and websites you use and how you interact with us, please see below for more information.
How We Collect Information
Information you provide to us
You may choose to submit Personal Information and other information to us by purchasing or interacting with the W&Sin . Examples of this include, when you create and manage a user account via our website, join or connect with a network, request technical support services, request information or support from us, communicate with us by email, telephone, or online chat, upload information through the W&Sin, subscribe to newsletters or other subscription services, register for training, educational programs, webinars or conferences, purchase products and services, submit job applications, request marketing to be sent to you, visit one of our sites, or participate in surveys.
For certain of the W&Sin or when you visit one of our sites, we may ask you to provide information including:
- Basic personal details (e.g., your name, title, and gender);
- Contact details (e.g., your corporate email address, postal address, including country and state, and phone number);
- Professional details (e.g., your job title, your company or organization name and any professional organization memberships);
- Usernames or URLs;
- Payment details (e.g., credit card information, bank account, etc.)
- Your photo (in connection with W&Sin , events where you are a speaker or where you upload your photo in connection with Badge)
Some of the information is necessary for us to provide particular W&Sin, or for security clearance, and our ability to deliver the W&Sin or allow access to our site(s) may be affected by your not providing certain information.
Information that we collect
When you access or use W&Sin , we may also collect certain information about your device and your use of the W&Sin . Such information may include:
- information, including version information, about the web browser or application you are using;
- products/services you purchased, with related pricing;
- if you are using a mobile device, the model of the device and its operating system;
crash data; - a unique identifier we assign to you;
- your IP address;
- information about your usage of the W&Sin s, including what functions or pages you use, the frequency of your use, links that you click on, and how often you log in;
cookies (please see our Cookies Policy here).
For certain of the W&Sin , including W&Sin web or mobile applications, we do not collect any Personal Information about you. Please refer to specific application privacy practices posted on the relevant application webstores for a list of personal information each application may collect.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.
Information We Collect From Other Sources
We may also collect these categories of information from sources other than directly from you. In particular, we collect this information from publicly available sources (such as your employer’s website or professional social networks such as LinkedIn), and may obtain Personal Information from third party data. Other users of the W&Sin may provide information about you when they submit content through the W&Sin . For example, you may be mentioned in a technical support case opened by someone else. Similarly, an administrator may provide your Personal Information such as when they designate you as the billing or technical contact on your company’s account. We may also receive information from analytics providers.
Please note that we may also have access to information about you that our customers may upload to our cloud services.
Location Information
To provide certain of the W&Sin, we may request your permission to access location information from your device. Some functions of the W&Sin may not work if you choose not to allow access to this location information. If you initially consent to sharing your location information through one of our applications or websites, you can subsequently stop the collection of this information by changing the settings of your device or by uninstalling the applications. Where you have not enabled location services for the applications or websites, we may derive general usage information (such as time zone) from your use of the applications or websites, including from your Bluetooth signal (where this is switched on when using Identity.
We will only process your Personal Information if we have a lawful basis for doing so. Lawful bases for processing include, depending on the applicable law, consent, contractual necessity, and our “legitimate interests” or the legitimate interest of others, as further described below.
Consent
Depending on your jurisdiction, some activities may require your consent, for example where we collect your personal data at events for our direct marketing communications so that we can provide further information and marketing to you. If applicable law requires your consent to process data in a certain way, then we will obtain it before carrying out that activity. When we process Personal Information based on your consent, it will be expressly indicated to you at the point and time of collection.
Where consent is not required, we will process your Personal Information because either it is necessary for our legitimate interests, is necessary to enable us to perform the contract or provide our services to you, or it is necessary for us to comply with our legal obligations.
Vital Interests/ tasks carried out in public interest
We may also need to process Personal Information if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
Legitimate Interests
In addition to the uses set out above, we may also process the Personal Information we collect for our legitimate business interests when that is an available legal basis under applicable law. “Legitimate Interests” means the interests of our company in conducting and managing our business to enable us to give you the best service and products and the most secure experience. For example, we have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing that is tailored to your interests. Our legitimate interests can also apply to processing that is in your interests as well. For example, we may process your information to ensure our websites and systems are secure. Specifically, we may also process the Personal Information we collect on the basis of the following legitimate business interests:
- where the processing enables us to enhance, modify, personalize or otherwise improve our services and communications for the benefit of our customers;
- to enhance the security of our network and information systems;
- to better understand how people interact with our websites;
- to review and update the information we hold on you, to ensure it is accurate and up to date;
- to assess your purchasing history and build a business profile on you (in your professional/business role);
- for analysis and research in connection with product offerings and development;
promoting our products and services; - for direct marketing purposes (where this is permitted) and to determine the effectiveness of promotional campaigns and advertising.
When we process your personal information for our legitimate interests, we consider 3 questions: is there a legitimate interest behind the use of your Personal Information? Is our use necessary for that purpose and do your rights override our legitimate interest? We always keep your rights in high regard and we take steps to ensure your Personal Information is not used in ways other than those you would expect. We will not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by applicable data protection law).
Where legitimate interest, or one of the other legal basis referred to above, isn’t available under applicable data protection law for the processing described under that subheading , then we will apply another alternative legal basis to enable us to carry out that data processing, or adjust the processing undertaken accordingly.
If you have any concerns about us using your Personal Information as outlined above, you have the right to object using the contact details contained in this Privacy Policy.
How We Use the Information We Collect
We may use the information we collect from you to:
- provide products/services to you;
- bill/invoice you;
- complete corporate transactions
- manage any accounts that you may have with us;
- validate your identity;
- send personalized marketing messages via email, post and telephone to you. Where required by applicable law, we will send these messages with your consent, and you have the right to opt out of receiving marketing by contacting us;
- serve relevant advertising on our site and third-party sites related to our products and services which are personalized to your interests;
- provide you with notice of product releases, special events, trainings, promotions or other matters relevant to you;
- respond to your inquiries;
- improve the services you receive from us.
We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
With Whom We May Share Information
We disclose information about you:
- to our third-party service providers, such as IT systems, network and back-up and storage;
- to other W&Sin group companies;
- resellers;
- system integrators;
- co-sellers;
- referral partners;
- technology partners;
- professional advisors, such as lawyers, accountants, auditors and/or consultants.
We also reserve the right to transfer any information we have about you in connection with any sale or transfer of all or a portion of our business or assets, including in the event of a reorganization, dissolution or liquidation.
Transfers of Personal Information Abroad
We take appropriate steps to protect your Personal Information regardless of where it is stored, taking into consideration the requirements of the data protection laws which we consider are applicable to how we process your Personal Information. These include entering into contracts with third parties. An example of this could arise if our processing of your Personal Information is protected under United Kingdom or European Union data protection laws. If that Personal Information will be transferred by us or on our instructions to a country outside the United Kingdom or European Economic Area and doing so would otherwise be restricted under prevailing data protection law applicable to us, because your Personal Information would not be protected to an equivalent data protection law standard, we will put in place an approved mechanism for providing appropriate safeguards to protect it. This includes approved mechanisms such as standard contractual clauses.
There may also be some instances in which we rely upon one or more permitted exceptions under the relevant data protection law from taking this step for particular situations. For example, where we have asked for your explicit consent to do, or to perform a contract with you, or take steps prior to doing so, to conclude or perform a contract with another party concluded in your interest, for important reasons of public interest, or where it is done in the context of legal claims.
How We Protect Personal Information
We maintain appropriate administrative, technical and physical safeguards designed to protect the Personal Information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We have put in place procedures to deal with any suspected breach of Personal Information and will notify you and any applicable regulator of a breach where we are legally required to do so.
How Long We Keep Personal Information
We also ensure that, in compliance with applicable law, we do not retain Personal Information longer than necessary. We will keep Personal Information about you for as long as we have a relationship with you, for example as long as you wish to keep receiving marketing messages from us, or as long as you are a customer (and for a reasonable period thereafter). When determining how long to retain Personal Information after we no longer have a relationship with you, we take into account how long our customers usually want to continue hearing from us, our legal obligations and the expectations of regulators, as well as the length of time information is needed for internal audit purposes and to exercise or defend our legal rights.
We also consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Your Rights
Depending on your jurisdiction, you may be entitled to certain rights, which can include:
- Where our use of your Personal Information requires consent, you may withdraw this consent at any time;
- You may request access to your Personal Information we hold about you and obtain information about how we process it. Depending on the applicable privacy laws (e.g. California law), you may be entitled to request the categories and specific pieces of Personal Information that we have collected about you, the categories of sources from which the Personal Information was collected, the purposes of collecting the Personal Information, the categories of third parties we have shared the Personal Information with, and the categories of Personal Information that have been shared with third parties for a business purpose;
- You may update, correct or amend the Personal Information we hold about you if it is wrong;
- You may ask us to change, restrict or stop the way in which we communicate with you or process Personal Information about you;
-You may ask us to delete your Personal Information;
- You have rights in relation to automated decision making, including profiling which has a legal effect, or which causes a significant effect;
- You may ask us to move, copy or transfer your Personal Information;
- You may object to our processing of your Personal Information;
- You may opt out of the sale of Personal Information—however, for purposes of California law, we do not sell your Personal Information to third parties, nor do we intend to, as those terms are defined by California privacy law. We also have not done so for the last 12 months. In addition, we have contracts with our service providers to prohibit any sale of the personal information we provide them; but if you have any concerns that our third parties might be selling your information, please contact us.
How to Contact Us
If you have any comments or inquiries about this Privacy Policy, if you would like to update information we have about you or to exercise your rights, you may contact us by submitting a Data Privacy Inquiry, sending an email to w&[email protected]
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority in the country in which you live via their website.
Changes to this Policy
We may change this Policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We will update the date at the top of the Privacy Policy accordingly. We encourage you to check this Policy for changes when you revisit the W&Sin website.