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”).

This Privacy Policy explains what Personal Data (as defined below) we collect and process, including why we collect it and how we use it. "Personal Data" is information that, alone or in combination with other information, could be used to identify an individual or track that individual's behavior or location online or through mobile devices (“Personal Data”). 

By using the Site and/or the Services, and providing us with Personal Data, you consent to the processing of your Personal Data and to the practices described in this Privacy Policy and the Cookie Policy referenced below and to the updates to these policies posted here from time to time. If you are based in the European Economic Area (“EEA”), this Privacy Policy serves as notice of how we process your Personal Data for which we are a controller. If we require consent from individuals in the EEA in connection with the processing of their Personal Data, this will be sought in line with applicable data protection laws.

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

  1. Scope – Site Visitors and Customer Users
  2. Information We Collect About You
  3. How Do We Use Your Personal Data?
  4. Disclosure of Your Personal Data
  5. Security
  6. Do We Use "Cookies"?
  7. Third Party Links
  8. California Do Not Track Disclosure
  9. Children
  10. Individuals in the European Economic Area (EEA)
  11. Changes to our Policy
  12. 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." 

Cookie Settings

1.2 Customer Users

We also process Personal Data about our Customers' end users, which may include the clients, prospects, employees, consultants, independent contractors, suppliers and other individuals or third parties ("Customer Users") whose Personal Data our Customers provide to us for processing in connection with our Services for those Customers. Please note that in these circumstances, our Customers will be in control over how their end users' Personal Data is processed, and we will be processing such Personal Data in accordance with our Customer service agreements. This Privacy Policy does not address the processing of this Personal Data. 

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.

Please see the “Do We Use “Cookies”? section below to find out more about how we use cookies (see section 6 below).

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. 

  1. 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.
  2. 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.

4.1 Affiliates

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. Security

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.

In general, W-Systems and its affiliates, and our third party providers and partners, use cookies and other technologies to optimize the functionality of the Site, to help us understand how the Site is used and to provide Site Visitors with interest-based content or advertising based upon their browsing activities and interests. 

For more information about the cookies and other technologies that we, our affiliates and third party providers and partners use on our Site, please read our Cookie Policy.

7. Third Party Links

The Site may contain links to other websites not operated or controlled by us (“Third Party Sites”). The privacy practices described in this Privacy Policy do not apply to Third Party Sites or any related third party services. You are on a Third Party Site whenever the website [root] domain address is different from our primary Site domain address (w-systems.com). By providing these links we do not imply that we endorse or have reviewed these sites, and we are in no way responsible for the practices or policies of these sites. Please refer to those sites directly for links to their privacy practices and policies.

8. California Do Not Track Disclosures

W-Systems does not currently respond to “Do Not Track” signals sent by a Site Visitor's browser or mobile application and operate as described in this Privacy Policy whether or not a “Do Not Track” signal is received. If we change our practices in the future and begin to respond to “Do Not Track” signals, we will update this Privacy Policy accordingly.

9. Children

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. 

10.1 Controller

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.

You may exercise your rights by contacting us as indicated under the “Contact Us” section below. To change your consent settings for our use of cookies and other technologies, please see our Cookie Policy.

10.3 Legitimate Interests

“Legitimate interests” means the interests of our company in conducting and managing our organization. For example, we have a legitimate interest in processing your Personal Data to analyze how the Site and our products and services are being used by you, to prevent fraud or criminal activity, misuse of our products or services, to ensure the security of our IT systems, architecture and networks, and to meet our corporate and social responsibility objectives, as described in this Privacy Policy. When we process your Personal Data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your Personal Data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests. For more information on your rights, please see “Your Rights” section above.

10.4 Data Transfers

W-Systems is based in the United States, and we use service providers (described above) based in the United States to operate our business and our relationship with you. When you use our Site and the Services, you acknowledge that your Personal Data will be transmitted to our and our service providers’ servers in the United States to provide you with the services that you requested, administer our contract with you or to respond to your requests as described in this Privacy Policy. The United States may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located. Where we transfer your Personal Data out of the EEA we will take steps to ensure that your rights continue to be protected.

10.5 Data Retention

We will keep your Personal Data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy based on the context in which you provided it, or for the duration required by law, whichever is the longer.

11. Changes to our Policy

The Site and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice unless otherwise required by applicable law. Please review this policy periodically, and especially before you provide any Personal Data. If permitted by applicable laws, your continued use of the Site after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy, without prejudice to your rights under applicable laws.

12. Contact Us

If there are any questions regarding our Privacy Policy or our Cookie Policy, or to manage your cookie choices, you may contact us using the information below.

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:

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