LAST UPDATED: October 10, 2022
At WireWheel, our mission is to help companies around the world protect the digital footprints that we all leave at work and at home. This Privacy Notice (“Notice”) is our effort to give you a sense about what information we collect about you when you visit our website, or use our product either as a customer or as a more limited user. We’ve tried to write this in the best way for people to understand, but we are always trying to do better. If you have questions about anything in here, please contact us at email@example.com.
At WireWheel, Inc. (“WireWheel” or “we” or “us”) we are committed to the responsible collection and use of personal information. This Notice governs the collection, use, and sharing of any personal information that is provided to us by Customers or users (“You”) as part of the WireWheel Services or when you visit our website.
When we refer to the “Services,” we mean any use of our privacy and data protection platform.
- CHOICES ABOUT THE USE OF PERSONAL INFORMATION
- YOUR RIGHTS REGARDING PERSONAL INFORMATION
- COOKIES AND OTHER TECHNOLOGIES
- INFORMATION ABOUT CHILDREN
- INTERNATIONAL DATA TRANSFER
- DATA RETENTION
- CHANGES TO THIS PRIVACY NOTICE
- APPLICABILITY OF THIS PRIVACY NOTICE
- CONTACT INFORMATION
Content and information submitted by users to the Services is referred to in this Notice as “Customer Data.” As further explained below, Customer Data is controlled by the organization or other third party that created the project or workspace (the “Customer”). Where WireWheel collects or processes Customer Data, it generally does so on behalf of the Customer, except as provided below.
If you join a workspace or project initiated by a Customer, and you create a user account, you are a “User,” as further described in this Notice and the User Terms of Service.
If you are using the Services by invitation of a Customer (for example, your employer, or a partner, or a co-founder) that Customer determines its own policies regarding storage, access, modification, deletion, sharing, and retention of User and Customer Data that may apply to your use of the Services. Please check with the Customer about the policies and settings it has in place.
Subject to any restriction outside these agreements, a User retains the right to use the specific information supplied by that User for its own purposes.
At a certain point, a User may also convert to being a Customer (“User-Converted-Customer”) of WireWheel. In that instance, information previously provided into the WireWheel Services only by that User may become “Customer Data” for that User-Converted-Customer, and will be treated as Customer Data for that User-Converted-Customer’s account as set forth herein. For example, if User is asked by a Customer for the User’s name and address, the answer submitted into the Customer’s WireWheel project becomes the property of the Customer. However, if the User becomes a WireWheel User-Converted-Customer, that User-Converted-Customer data may now become Customer Data.
Personal Information We Collect
WireWheel may also collect and process information included in Customer Data that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”), including as follows:
- Information collected through our website. This may include information such as name, address, email address or physical address that is provided by you by filling out a form requesting information about our Services. We ask that you not send us any sensitive personal information (e.g. social security numbers) through our website.
- Information about any User necessary to create an account. This may include information such as an email address, phone number, and password to create an account.
- Workspace and Project setup information. When a Customer creates a workspace or project using the WireWheel Services, WireWheel may collect an email address, a workspace name, workspace photo, domain details, user name for the individual setting up the workspace, password and other similar information. WireWheel may also collect team contact info, such as a mailing address.
- Billing and other information. When our Customers purchase the Services, our affiliates, consultants, vendors and our third party payment processors may collect and store billing address and credit card information on our behalf, or WireWheel may do this ourselves.
- Information about the use of WireWheel Services. WireWheel collects extensive information about the use and access of our Services, which may include administrative and support communications with us and information about the projects and workspaces, messages, people, features, content, and links you interact with, and what third party integrations you use (if any).
- Address and other contact information. We may, with your authorization, collect contact or address book information, from your device or other services or resources, to improve your interactions with WireWheel.
- Customer Data. We may collect your personal information as part of processing privacy impact assessments (PIAs) `data subject access requests (DSARs), and consent and preference signals on behalf of our Customers.
- Logging data. Our servers or partners may automatically log certain information, including your Internet Protocol address, the address of the web page you visited before using the Services, your browser type and settings, the date and time of your use of the Services, information about your browser configuration and plug-ins, language preferences, and cookie data. For more information about the collection of this information, please see our Cookies Notice.
- Information about your device. WireWheel may collect and use information about the device on which you are using WireWheel Services, including what type of device it is, what operating system you are using, device settings, application IDs, unique device identifiers, and crash data.
- Geo-location information. We may, with your permission, collect precise GPS location from mobile devices. We do also use WiFi and IP addresses received from your browser or device to approximate location.
- Services integrations. If, when using the Services, you integrate with a third party service, we will connect that service to WireWheel. The third party provider of the integration may share certain information about your account with WireWheel. However, we do not receive or store your passwords for any of these third party services.
- Third party data. WireWheel may also receive information from affiliates in our corporate group, our partners, or others that we use to make our own information better or more useful. This might be aggregate level information, such as which IP addresses go with which zip codes, or it might be more specific information, such as about how well an online marketing or email campaign performed.
|Category of Personal Information||Categories of Sources From Which Personal Information Has Been Collected in the Preceding 12||Categories of Third Parties With Whom the Service Shares or Sells Personal Information|
|Identifiers such as a name, Internet Protocol address, email address or other similar identifiers||Directly from you
Automatically or indirectly from you
|Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||Directly from you
|Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement||Directly from you
Automatically or indirectly from you
Third parties or affiliates
|Precise geolocation data||Directly from you||Service providers
|Professional, education or employment-related information||Our Customers||Service providers|
We will not collect additional categories of personal information other than those categories listed above. If we intend to collect additional categories of personal information, we will provide you with a new notice at or before the time of collection.
We use your information to provide and improve the Services, as follows:
WireWheel may access and use Customer Data as reasonably necessary and in accordance with Customer’s instructions to (a) provide, maintain and improve WireWheel’s Services; (b) to prevent or address service, security, technical issues or at a Customer’s request in connection with customer support matters; (c) as required by law or as permitted by a lawful data request (e.g., subpoena) and (d) as set forth in our agreement with the Customer or as expressly permitted in writing by the Customer.
In addition, WireWheel may analyze and share with Customers, Users, and others, derivative insights from the Customer Data or User Data shared when using the Services, provided that we do not share or disclose any of the underlying Customer Data.
We use personal information in a variety of ways in connection with our Services:
- Research and development. We carry out research and analyze trends to better understand how users are using the Services and improve them.
- Communications with you about the Services.
- Responses for information. If you contact us with a problem or question, we will use your information to respond.
- Email and other messages. We often need to contact you for invoicing, account management and similar reasons. WireWheel may send you email and other messages using any number of communication methods that you share with us. We may also contact you to inform you about changes in our Services, our Service offerings, and important Service related notices, such as security and fraud notices. These emails and messages are considered part of the Services and you may not opt-out of them.
- Billing and account management. We use account data to administer accounts and keep track of billing and payments.
- Fraud or criminal activity. We may use your information to assist in making the Services secure and to prevent abuse and fraud.
- Marketing. We may contact you via email or through other methods of communication about new product features or to provide you with other news about WireWheel. We may also use your contact information for other marketing or advertising purposes or contact you to participate in surveys. We will not share your contact information with third parties for purposes of their own marketing without your permission. You can opt out of these at any time by using the “unsubscribe” link in any marketing email or by contacting firstname.lastname@example.org.
- Other legitimate reasons: We may use information we collect for other legitimate purposes, including:
- Compliance with foreign law, law enforcement, court and regulatory requirements;
- Industry watch-lists and industry self-regulatory schemes;
- Information system, network and cyber security;
- Employment data processing;
- General corporate operations and due diligence; and
- Product development and enhancement.
This Notice is not intended to place any limits on what we do with data that is aggregated and/or de-identified so it is no longer associated with an identifiable user or Customer of the Services.
3. CHOICES ABOUT THE USE OF PERSONAL INFORMATION
As a general matter, the WireWheel Customer provides WireWheel with instructions on what to do with Customer Data, and has several choices. For example, the Customer may add and deny access to projects and workspaces and the Services, enable or disable third party integrations, manage permissions, retention and export settings, transfer or assign workspaces, or share projects. These choices and instructions may result in the access, use, disclosure, modification or deletion of certain or all Customer Data.
If you want to limit or prevent our ability to receive location information from you, you can deny or remove the permission for certain Services to access location information or deactivate location services on your device. Please refer to your device manufacturer or operating system instructions for instructions on how to do this.
Your Choices and Opt-Outs
You can also contact us at any time to update your marketing preferences. You can opt out of marketing communications from us at any time by using the “unsubscribe” link in any marketing email or by contacting email@example.com. Please be advised that you may not be able to opt-out of receiving certain service or transactional messages from us, including legal notices.
As a general matter, Customers determine their own policies for the sharing and disclosure of Customer Data. WireWheel does not control how Customers or their third parties choose to share or disclose Customer Data. However, WireWheel may share information with limited third parties as follows:
WireWheel may share Customer Data in accordance with our agreement with the Customer and the Customer’s instructions, including:
- With third party service providers and agents. We may engage third party companies or individuals to process Customer Data.
- With affiliates. We may engage affiliates in our corporate group or other consultants or vendors to process Customer Data.
- With third party integrations. WireWheel may, acting on our Customer’s behalf, share Customer Data with the provider of an integration added by Customer. WireWheel is not responsible for how the provider of an integration may collect, use, and share Customer Data.
As a general matter, WireWheel does not sell, rent, or lease its customer lists to third parties. We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your personal information is not transferred to the third party without your express consent.
WireWheel May Also Share Personal Information As Follows
- About a user with the Customer. In a number of circumstances, we may share information with a Customer about any user asked to contribute to a project, workspaces or otherwise about use of the Services.
- With third party service providers and agents. We may engage with trusted third party companies or individuals, such as third party payment processors, to process information on our behalf. All such third parties are prohibited from using your personal information except to provide these services and they are obligated to maintain the same level of protection of that information as WireWheel.
- With affiliates. We may engage affiliates in our corporate group to process personal information.
Other Types Of Disclosure
WireWheel may share or disclose Customer Data and personal information consistent with other uses described above, including:
- During changes to our business structure. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of WireWheel’s assets, financing, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence).
- To comply with laws. To comply with legal or regulatory requirements and to respond to lawful requests, court orders and legal process.
- To enforce our rights, prevent fraud and for safety. To protect and defend the rights, property, or safety of us or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud.
- Sharing information with our third-party service providers working on our behalf for the purposes described in this Notice to help us provide and support our Service or to assist in protecting and securing our systems and services and other business-related functions. This includes: analyzing data, hosting data, engaging technical support for our Services, processing payments, and delivering content and marketing messages.
- Sharing personal information of Customers, and visitors with third-party advertising networks, exchanges, and social media platforms to serve our advertising on other sites.
- We may disclose or use aggregate or de-identified information for any purpose.
For more information, including information on how to opt-out of certain advertising, please see our Cookies Notice.
5. YOUR RIGHTS REGARDING PERSONAL INFORMATION
You have certain rights regarding the collection and processing of personal information. You may exercise these rights, to the extent they apply to you, by contacting us at the information provided at the end of this Notice or by visiting Make a Request About Your Data.
Accessing, Modifying, Rectifying, and Correcting Collected Personal Information
Depending on the laws that apply to you, you may obtain from us certain personal information our records. If you wish to access, review, or make any changes or corrections to personal information you have provided to us through the Services, please contact us at the information provided at the end of this Notice. We reserve the right to deny access as permitted or required by applicable law.
Your California Privacy Rights
California’s “Shine the Light” law permits our users who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the previous calendar year and the names and addresses of those third parties. Requests may be made only once per year per person, must be sent to the email address below, and are free of charge. However, we do not disclose personal information protected under the “Shine the Light” law to third parties for their own direct marketing purposes.
The California Consumer Privacy Act of 2018 (“CCPA”) and other state laws enacted from time to time provide residents of those jurisdictions with specific rights regarding their personal information. Depending on the nature of your request, WireWheel may refer you to a particular Customer where processing of personal information has taken place pursuant to our contract with a Customer in order to exercise your rights, consistent with applicable law. For individuals whose state of residence does not afford these rights, we may offer them voluntarily and at our discretion, and we reserve the right to limit or revoke any such rights at any time, as may be permitted by applicable laws. This section describes your CCPA rights and explains how to exercise those rights:
- Right to Know: You have the right to request what personal information about you we collect, use, disclose, and/or sell, as applicable, over the past 12 months as follows:
- The categories of personal information we collected about you;
- The categories of sources from which the personal information is collected;
- Our business or commercial purpose for collecting or selling that personal information;
- The categories of third parties with whom we share that personal information;
- The specific pieces of personal information we collected about you.
- Right to Delete: You have the right to request the deletion of your personal information that is collected or maintained by us. If we receive and confirm your verifiable consumer request, we shall delete (and direct our service providers to delete) your personal information from our records, unless an exception applies or as otherwise required by law.
- Right to Correct: You have the right to correct inaccurate personal information that we have collected and maintain about you.
- Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.
- Right to opt-out of the sale of personal information: You have the right to request to be opted out from the sale of your personal information, if applicable.
Sale of Personal Information
We never monetize your personal information; however, the CCPA has a broad definition of “sale” that includes transactions other than what would be traditionally considered sales. In the past twelve (12) months, we have “sold” (as defined under the CCPA) the following categories of personal information set forth in the table above: Internet, or other electronic network activity information. We have “sold” your personal information to third parties who provide cross-platform advertising and related tracking for our Services.
We do not and will not knowingly sell the personal information of minors under the age of 16 without affirmative authorization.
Exercising Your Privacy Rights
To exercise any rights described above under the CCPA or other applicable laws, please submit a verifiable consumer request to us by either:
- Visiting Make a Request About Your Data
- Emailing us at firstname.lastname@example.org
- Sending postal mail to: WireWheel, Attention: Privacy 1310 N Courthouse Rd STE 200 Arlington, VA 22201
The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
The above rights are also subject to various exclusions and exceptions under the law. Under certain circumstances, we may be unable to implement your request, pursuant to applicable law. We will advise you of any reason for denying or restricting a request to the extent permitted by law.
Your Nevada Privacy Rights
Nevada law permits our users who are Nevada consumers to request that their personal information not be sold (as defined under applicable Nevada law), even if their personal information is not currently being sold. Requests may be sent to email@example.com and are free of charge.
Your EU, UK and Switzerland Privacy Rights
European Union, UK and Switzerland privacy laws provide individuals with enhanced rights in respect of their personal information. These rights may include, depending on the circumstances surrounding the processing of personal information:
- The right to object to decisions based on profiling or automated decision making that produce legal or similarly significant effects on you (we do not however process personal information in a manner, which would make this right applicable);
- The right to request restriction of processing of personal information or object to processing of personal information carried out pursuant to (i) a legitimate interest (including, but not limited to, processing for direct marketing purposes) or (ii) performance of a task in the public interest;
- The right to withdraw your consent to process your personal information for a purpose you previously consented to. Withdrawing consent does not affect the lawfulness of processing, which was done before consent was revoked;
- In certain circumstances, the right to data portability, which means that you can request that we provide certain personal information we hold about you in a machine-readable format; and
- In certain circumstances, the right to erasure and/or the right to be forgotten, which means that you can request deletion or removal of certain personal information we process about you.
Note that we may need to request additional information from you to validate your request. To exercise any of the rights above, please firstname.lastname@example.org or by visiting Make a Request About Your Data.
If you are located in the European Union, European Economic Area, the UK, or Switzerland, and you wish to raise a concern regarding our use of your personal information, you have the right to complain to a supervisory authority.
Legal Basis for Processing Personal Information (EEA and UK Only)
If you are located in the EEA or UK, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect and use personal information to perform our contractual obligations to you, or to take steps in response to information or inquiries you may submit prior to entering into a contract with us, or where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Our legitimate interests are described in more detail in this Notice in the sections above titled “Use”, but they typically include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of our platform Service and our WireWheel sites; and supporting our marketing activities.
In some limited cases, we may collect and process personal information to comply with laws, regulators, court orders, or other legal obligations, or pursuant to legal process.
Where required by law, we will obtain consent to collect personal information.
If you have questions or need further information concerning the legal basis on which we collect and use your personal information, please contact us at email@example.com.
6. COOKIES AND OTHER TECHNOLOGIES
We use the information about activities on the WireWheel sites and other sites in order to provide interest-based and targeted advertising based on browsing activities and interests, and to provide analytics information, to enhance the effectiveness of our Service, and for other purposes identified herein.
The information we collect automatically includes:
- Device information such as: IP address, browser, unique device identifiers, mobile network information, request information (speed, frequency, the site from which the visitor linked to us (“referring page”), the name of the website the visitor chose to visit immediately after ours (called “exit page”), information about other websites the visitor has recently visited and the web browser used (software used to browse the internet) including its type and language)
- Usage data such as: information about how visitors interact with our emails, WireWheel sites, and other websites (such as the pages and files viewed, searches, operating system and system configuration information and date/time stamps associated with visitors’ usage).
We also use your browsing history and personal information to display interest-based advertising that is relevant to you. We place interest-based advertisements on our website as well as other third-party sites. The browsing history we use is collected by us and by third parties on our website, as well as other sites. We may also share your anonymous browsing history from our website and personal information with third parties to provide relevant ads. They may combine this information with assumptions based on the other websites you have visited in order to tailor ads to you. You can opt out of interest-based advertising from third party providers who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising at www.aboutads.info/choices.
WireWheel uses administrative, technical, and physical safeguards designed to safeguard the information that we collect. Those safeguards include: (i) the pseudonymization and encryption of personal information where we deem appropriate; (ii) taking steps to ensure personal information is backed up and remains available in the event of a security incident; and (iii) periodic testing, assessment, and evaluation of the effectiveness of our safeguards. Please note that no information system can be 100% secure so we cannot guarantee the security of your information.
8. INFORMATION ABOUT CHILDREN
WireWheel Services and websites are not directed at children under 13. If you are aware that children under 13 are providing us with personal information without our consent, please contact us.
9. INTERNATIONAL DATA TRANSFER
WireWheel has self-certified to the EU-U.S. and Swiss-U.S. Privacy Shield frameworks set forth by the U.S Department of Commerce with respect to collection, use and retention of Customer Data and personal information; however, the EU-U.S. Privacy Shield framework is no longer a valid data transfer mechanism. Accordingly, when we transfer personal information from the EEA or UK to the United States, we rely on Standard Contractual Clauses issued by the European Commission or the International Data Transfer Addendum issued by the UK ICO, respectively.
WireWheel has further committed to refer unresolved Privacy Shield complaints to JAMS Privacy Shield Program, an alternative dispute resolution provider located in the United States.
If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, WireWheel has further committed to refer unresolved Privacy Shield complaints to JAMS Privacy Shield Program, an alternative dispute resolution provider located in the United States. The services of JAMS Privacy Shield Program are provided at no cost to you.
10. DATA RETENTION
We retain personal information for the extent we deem necessary to carry out the processing activities described above, including but not limited to compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, and to the extent we reasonably deem necessary to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our users and other third parties.
11. CHANGES TO THIS PRIVACY NOTICE
This Notice replaces all previous disclosures we may have provided to you about our information practices with respect to the Services. We reserve the right, at any time, to modify, alter, and/or update this Notice, and any such modifications, alterations, or updates will be effective upon our posting of the revised Notice. WireWheel may change the provisions of this Notice at any time, and will always post the most up-to-date version on our website. Your continued use of the Services following our posting of any revised Notice will constitute your acknowledgement of the amended Notice.
12. APPLICABILITY OF THIS PRIVACY NOTICE
This Notice is subject to the Terms of Service that govern your use of the Services. This Notice applies regardless of the means used to access or provide information through the Services.
This Notice does not apply to information from or about you collected by any third-party services, applications, or advertisements associated with, or websites linked from, the Services. The collection or receipt of your information by such third parties is subject to their own privacy policies, statements, and practices, and under no circumstances are we responsible or liable for any third party’s compliance therewith.
13. CONTACT INFORMATION
WireWheel welcomes your comments regarding this Notice. You can contact WireWheel at firstname.lastname@example.org.
For more information about how users with disabilities can access this Notice in an alternative format, please contact us at:
1310 N. Courthouse Road, Suite 200 Arlington, VA 22201