LAST UPDATED: April 25, 2018
At WireWheel, Inc. (“WireWheel” or “we” or “us”) we are committed to the responsible collection and use of personal information.
This Privacy Notice (“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.
Content and information submitted by Users to the Services is referred to in this policy 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 Privacy 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.
WireWheel may also collect and process information other than Customer Information (“Other 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.
- 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.
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 other 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.
- 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 email@example.com.
- Fraud or criminal activity. We may use your information to assist in making the Services secure and to prevent abuse and fraud.
OTHER LEGITIMATE REASONS. WireWheel may also use information we collect for other legitimate purposes, including. (1) compliance with foreign law, law enforcement, court and regulatory requirements; (2) Industry watch-lists and industry self-regulatory schemes; (3) information system, network and cyber security (4) employment data processing; (5) general corporate operations and due diligence; and (6) product development and enhancement.
This policy 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.
You may review, correct, update or request deletion of your personal data by contacting firstname.lastname@example.org.
We will not share your contact information with third parties for purposes of their own marketing without your permission. 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.
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 Other 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 or 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 Other Information.
Other types of disclosure
WireWheel may share or disclose Customer Data and other 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.
We may disclose or use aggregate or de-identified information for any purpose.
5. COOKIES AND OTHER TECHNOLOGIES
WireWheel uses administrative, technical, and physical safeguards designed to safeguard the information that we collect. Please note that no information system can be 100% secure so we cannot guarantee the security of your information.
7. 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.
8. DATA TRANSFER
The WireWheel Services and website are operated by us from the United States, and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services or our website you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.
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. For more information, see our Privacy Shield Notice. We may process some personal data from individuals or companies via other compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses. To learn more about the Privacy Shield program, refer to https://www.privacyshield.gov/welcome.
9. CHANGES TO THIS PRIVACY NOTICE
WireWheel may change the provisions of this Privacy Notice at any time, and will always post the most up-to-date version on our website.
10. CONTACT INFORMATION
WireWheel welcomes your comments regarding this Privacy Notice. You can contact WireWheel at firstname.lastname@example.org.