Last updated September 20, 2019
Welcome to the (“W-Systems”, “we”, “our” “us”) website (the “Site”). W-Systems is a provider of cloud-based collaboration solutions such as, CRM, marketing automation, telephony, business intelligence and cloud computing services (“Services”).
To make sure you stay informed of all changes, you should check these policies periodically. Updates will be referenced by the "Last Updated" date shown above.
Table of Contents
- Scope – Site Visitors and Customer Users
- Information We Collect About You
- How Do We Use Your Personal Data?
- Disclosure of Your Personal Data
- Do We Use "Cookies"?
- Third Party Links
- California Do Not Track Disclosure
- Individuals in the European Economic Area (EEA)
- Changes to our Policy
- Contact Us
1. Site Visitors and Customer Users
1.1 Site Visitors
We collect and process Personal Data about direct visitors to our Sites (each a "Site Visitor"), some of whom may also be Customers. We may refer to Site Visitors as "you" or "your."
1.2 Customer Users
2. Information We Collect About You
2.1 Personal Data That You Provide Through the Site
We collect Personal Data of Site Visitors that is voluntarily provided by you when you order products and services or register on our Site (including your name, email address, username, mailing address, phone number, payment and billing information or other details, as appropriate, that you elect to provide), or communicate with customer service. We also collect Personal Data that you enter on our Site or send to us electronically when you complete a web form to give Personal Data to us directly, such as on our “Contact Us” page.
2.2 Automatically Collected Data
When you visit the Site, we may automatically collect information about your use of our Site through cookies, pixel tags (also known as web beacons), ad conversion tracking and similar technologies. This information may include the browser or operating system that you use to access the Internet, your IP address, your location, the date and time you may have viewed certain pages on the Site, which advertisements (if any are displayed) that you clicked on and your subsequent actions, etc.
2.3 Phone Calls
In addition, if you call a phone number listed on any of our Sites, we may record the phone number the call was placed from, and may record the call.
3. How Do We Use Your Personal Data?
We may use the information we collect from Site Visitors when you fill out a form on our Site, make an inquiry, sign up for our newsletter, respond to a survey or marketing communication, surf the Site, create a login or make an entry through our customer support portal, or use certain other Site features.
We may process your Personal Data to perform the contract we are about to enter into or have entered into with you, to ensure compliance with local legal and regulatory requirements and for the purposes of our legitimate business interests, including the following:
3.1 To provide Services to customers and respond to requests
We use contact information or account-related data given to us by Site Visitors who are Customers in connection with the purchase, sign-up, use or support of a Customer account. Such information may include username, email address, phone number, and location data. We use this information to provide Site Visitors who are Customers with information about the Services and/or the Site, contact them regarding use of the Services and/or the Site or to provide notification of important changes to the Services and/or the Site.
When you ask for information about the Services (for example, when you ask us to send you offers or price information), we will use your contact information to respond to your requests, inquiries, comments, feedback or questions.
3.2 For marketing purposes
W-Systems, and its affiliates as described below, may use Site Visitors' contact details to tell you more about our Services and other services we believe may be of interest to you, upcoming events or other promotions. If we do so, each marketing communication we send you will contain instructions permitting you to "opt out" of receiving future marketing communications. Note, however, that if you are a Site Visitor who is a Customer of our Services you cannot opt out of some administrative communications that are reasonably necessary to the provision of the Services, such as billing or service notifications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated in the "Contact Us" section below.
- Marketing through our affiliates. W-Systems is part of the GateHouse Media family of companies, and has affiliates that provide online marketing services to small and medium sized businesses, and others that own and operate local newspapers, live events and related websites. We may provide your information to those affiliates for the purposes described above, subject always to your right to opt out of marketing communications at any time.
- Consent to marketing where required by law. Where required by applicable law (for example, if you are an individual in the EEA), we will only send you marketing information by email if you consent to us doing so at the time you provide us with your Personal Data. In this case, when you provide us with your consent to be contacted for marketing purposes, you have the right to withdraw your consent at any time by following the instructions to “opt-out” of receiving marketing communication in each marketing email we send you or by contacting us as provided under the “Contact Us” section below.
3.3 To analyze, administer, support, and improve use of the Site and the Services
We use data relating to your use of the Site and/or the Services to analyze, administer, support and improve your access to and use of the Site and the Services. For example, we use data about how and when you visit different parts of our Site in order to improve the structure of the Site. For EU individuals, this use of your Personal Data is necessary for our and our group of companies’ legitimate interests in understanding how Site Visitors and Customers use the Site and the Services in general and to improve your and other users' experience.
3.4 Aggregate and Anonymized Data
We may also compile, anonymize and/or aggregate your Personal Data together with other data and use such anonymized and/or aggregated data for our business purposes, including sharing such data with affiliates and business partners. This aggregate and anonymized information does not identify any person individually.
3.5 For other legitimate business purposes
We may also use Personal Data for other legitimate purposes, which include the following:
- If you ask us to delete your Personal Data and we are required to fulfill your request, we need to keep basic data to be able to identify you and prevent further unwanted processing. Under these circumstances, we will only retain the minimum Personal Data required to achieve this aim.
- To prevent fraud, criminal activity, or misuse of our Site, and to ensure the security of our IT systems, architecture and networks.
- To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties.
4. Disclosure of Your Personal Data
We disclose Personal Data to affiliates and certain third parties as described below.
We share Personal Data with our affiliates in order to inform you about services we believe may be of interest to you that are provided by those affiliates. If we send you marketing communications, each one will contain instructions permitting you to "opt out" of receiving future marketing communications. Where required by applicable law (for example, if you are an individual in the EEA), we will only send you marketing information from our affiliates by email if you have consented to us doing so at the time you provide us with your Personal Data.
4.2 Third Parties
We share Personal Data with our, and our affiliates', third party service providers as needed to assist us in operating, analyzing and advertising on our Site and providing the Services to Customers, and conducting our business more generally. These service providers include website hosting partners, data centers, sign-on authentication software providers, website analytics companies, advertising technology companies, providers of CRM, marketing and sales software solutions, call tracking and online chat providers, customer support providers, and providers of billing, order management and payment processing functions. Where these parties have access to and process Personal Data on our behalf in the course of performing their duties to us, they are required to keep your Personal Data confidential and secure.
4.3 Business Partners and Advertisers
Please note that if you click on a third party advertisement on our Site, it will take you to the advertiser's website. We may also share Personal Data that you provide to us with our business partners in order to inform you about services we believe may be of interest to you that are provided by those business partners and advertisers. If we send you marketing communications, each one will contain instructions permitting you to "opt out" of receiving future marketing communications. Where required by applicable law (for example, if you are an individual in the EEA), we will only send you marketing information from our business partners and advertisers by email if you have consented to us doing so at the time you provide us with your Personal Data.
4.4 Business Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your Personal Data and other information may be transferred to a successor or affiliate as part of that transaction along with other assets.
4.5 Legal Requirements
We also may provide your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or lawful requests by public authorities, including meeting national security or law enforcement requirements and applicable law, rule, order, or regulation, (ii) protect and defend our or our affiliates' rights or property, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.
5.1 Our Site
We take reasonable and appropriate steps to protect the Personal Data provided via the Site from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet, email or other electronic transmission is ever fully secure or error free, so you should take special care in deciding what Personal Data you send to us in this way.
Our Site is scanned on a regular basis for security holes and known vulnerabilities. We use regular Malware Scanning. Your Personal Data is contained behind networks with security protocols and access is authorized for only a limited number of persons who have special access rights to such systems, and are required to keep the information confidential.
5.2 Our Services
We take reasonable steps to protect the Personal Data that is in our control provided to us via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.
6. Do We Use "Cookies"?
Yes. Cookies and similar technologies are small files that a website or its service provider transfers to a computer's hard drive through a Web browser (if the user allows) that enables the website's or service provider's systems to recognize the user's browser and capture and remember certain information.
7. Third Party Links
8. California Do Not Track Disclosures
W-Systems does not knowingly collect Personal Data from children under the age of 13 (or 16 where required by applicable law) without parental consent. If you have reason to believe that a child under the age of 13 (or 16 where applicable under law) has provided Personal Data to W-Systems through this Site please contact us as provided in the "Contact Us" section below with sufficient detail to enable us to delete that information from our databases.
10. Individuals in the European Economic Area (EEA)
This Section 10 applies only if we collect through the Site any Personal Data of individuals based in the EEA or if we track individuals in the EEA who access our Site, and it applies only to those individuals who are based in the EEA.
W-Systems is the controller (as defined under the General Data Protection Regulation (GDPR)) for processing and using the Personal Data of EEA individuals that is collected through our Site. Please see the “Contact Us” section below to find out how to contact us.
10.2 Rights of Individuals Based in the EEA
Subject to applicable law, you may be able to exercise any of the following rights in relation to your Personal Data:
- Right to know what information we have about you: This is known as the "right of access" and gives you the right to find out what, if any, Personal Data we have about you, how we process it, and to request a copy of the Personal Data.
- Right to correct your information: This is known as the "right of rectification" and gives you the right to ask that we correct or complete any Personal Data we have about you.
- Right to delete your information: This is known as the "right to erasure" or "right to be forgotten" and gives you the right to ask us to delete your Personal Data.
- Right to change how we use your information: This is known as the "right to restrict processing" and gives you the right to ask us to change how we use your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us using it in a certain way.
- Right to move your information: This is known as the "right to data portability" and gives you the right to ask to receive your Personal Data from us in a structured, commonly used and machine-readable format or to have it transmitted to another controller.
- Right to stop us from using your information: This is known as the "right to object" and gives you the right to ask us at any time to stop using your Personal Data.
- Rights relating to how we use your information to categorize you or make decisions about you: This is known as the "right in relation to automated decision-making and profiling.": You have the right to be free from decisions we may make that are based solely on automated processing of your Personal Data, including profiling, if they produce a significant legal effect on you, unless such decision-making or profiling is necessary for entering into or performing a contract between you and us, or is made with your explicit consent.
- Right to withdraw consent: If we rely on your consent to use your Personal Data, you have the right to withdraw that consent at any time. This will not affect our use of your data before we received notice that you wished to withdraw your consent.
- Right to file a complaint with the supervisory authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the supervisory authority that is authorized to hear those concerns in your jurisdiction.
10.3 Legitimate Interests
10.4 Data Transfers
10.5 Data Retention
11. Changes to our Policy
12. Contact Us
- By email: firstname.lastname@example.org
- By phone: + 1 (833) 205-6120
- By web to manage your cookie choices: www.w-systems.com/dsar
General Data Protection Regulation (GDPR) - European Representative
Pursuant to Article 27 of the GDPR, W-Systems has appointed a company called European Data Protection Office (EDPO) as its GDPR representative in the EEA. If you are an individual based in the EEA, in addition to or alternatively to contacting us, you can also contact EDPO regarding matters pertaining to the processing of your Personal Data under GDPR as follows: