Privacy Policy

Effective from: April 02, 2019
Version: 2.0
All versions available here

Non-legalese, Simple English Summary

1. You provide your personal information (email, phone number, etc.) to us while creating an account with us. We store that information reliably. We use that information to serve you.
2. When you install our services on your website /mobile app, we collect some personally identifiable data to serve you.
3. This policy specifies the data collected by us, the manner of collection, and your rights with respect to your personal data.
4. This policy is applicable only to you and not visitor’s of your website.
5. You (and/or your users) have an option to opt out from being tracked by our services. Please see our opt-out page for more information.

1. Privacy Statement

Wingify cares about your privacy.

1. Wingify is committed to conducting business in a compliant manner and protecting the privacy of individuals who visit VWO website and/or interact with VWO online (“User/’Users”), Users who register to use the Services as defined below (“Customers”), and Users who provide information to VWO to register for events (“Attendees”). This Privacy Statement describes Wingify’s privacy practices in relation to the use of VWO websites and the related products, applications, and services (including support) offered by VWO (the “Services”).
2. When Wingify receives personal information, Wingify maintains high ethical standards and takes steps to handle personal information in a responsible manner that is consistent with our core values and business objectives.
3. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
4. Wingify may modify or update this privacy statement at any time without prior notice. You can check the “Last Updated” date above to see when the statement was last changed. Your continued use of the website and/or the Services constitutes your consent to the contents of this Privacy Statement.

2. Overview

Wingify collects many kinds of information to operate effectively and provide you the best products, services, and experiences possible. Wingify collects information when you register, sign in, and use our sites and services. We collect this information in a variety of ways, including web forms, technologies like cookies, web logging, and/or others.

We respect each individual’s right to personal privacy. We will collect and use the information we receive directly from you through our website only in the ways disclosed in this Privacy Policy. This Privacy Policy applies solely to information we collect directly from you through the “Services”. The data/information collected by the customer will be subject to their own Privacy policy in force. Wingify’s Privacy Policy does not apply to any end user data that it may collect, obtain, or access in connection with operating the specific service on behalf of its customers. By visiting the Website, you acknowledge that you accept the practices and policies outlined in this Privacy Policy.

Wingify receives and processes information (in paper and electronic form) in accordance with its clients’ instructions for providing services to its customers. At Wingify, we recognize the importance of privacy to our customers and we strive to safeguard any personal information we receive and may need to use in support of our customers.

3. What Personal Information does Wingify collect or maintain?

Wingify collects two types of information: personal information and non-personally identifiable information to operate effectively and provide you the best products, services, and experiences possible. Wingify collects information when you register, sign in, and use our sites and services. We collect this information in a variety of ways, including web forms, technologies like cookies, web logging, and or other methods. We may use personal and non-personally identifiable information to create aggregate information (collectively referred to as “automated information”). We collect the following categories and elements of information:

1. In general, as a User you will not need to identify yourself or reveal any personal information. However, Wingify does collect domain information from your visit to customize and improve your experience on our websites. The type of information Wingify may collect includes:
   1. the date and time of your access
   2. the pages you have accessed
   3. the Internet Protocol (IP) address that you use to access the Internet
2. There are times when Wingify may collect personal information from you as aUser, Customer, or Attendee. This may include your name, email address, phone number, and other contact information (browser type and version, country, etc). In some cases, Wingify may request additional information in which case you may receive a separate privacy statement.  Some of the ways in which Wingify may collect information from you are:
   1. Registrations for webcasts, seminars, conferences, etc., sponsored by Wingify or a partner
   2. Subscription to newsletters or other Wingify content-related materials
   3. Service purchases or trials (either on your own or on behalf of your company)

Users of this Website are not requested to provide sensitive personal information (personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, or biometric data for uniquely identifying a natural person, information concerning health or information concerning a natural person’s sex life or sexual orientation). Please avoid providing such information through this Website.

We will collect personal information from Users to this Website, including automated information collected in server log files; personal information deliberately provided by the Website user through web forms, subscription pages, and other similar means; and personal information collected through cookies, web beacons, and similar technology.

4. Information automatically collected

When you use our Website, we automatically collect your IP address, traffic source, search keywords, page views, visits, location (aggregated), browser and operating systems (aggregated), device (aggregated), as well as other connection information like time and transferred information (collectively referred to as “automated information”).

We store and use this automated information in server log files for system integrity and security and in order to be able to investigate and prosecute infringements or abuse of our Website and to cooperate with authorities involved (security and prosecution purposes). We also use this information to enhance our services and to provide you with a positive user experience (product and analytics purposes).

For these purposes, we make accessible and share automated information with our security team (for security and prosecution purposes), supervisory authorities, and qualified personnel (product, marketing, analytics) having access to the tools that are used for collecting and analyzing automated information (Google Analytics and others, see below in sections “Google Analytics” and “Marketing automation and customer relationship management (CRM).”

We store the information required for security and prosecution purposes on a legitimate interest basis and the information required for product, marketing, and analytics purposes (legitimate interest or where required, by obtaining your prior consent), for the period necessary to pursue the purposes outlined in this section, or as permitted by statutory applicable laws.

Information you submit through web forms and website pages

On our Website, you can pose inquiries or get in touch with us through web forms, ordering pages, subscribing to our blogs and event alerts, or by registering for services.

We may collect, store, and use your name, company name, email address, IP address, the content of your request or query and other personal information you provide with your submission for contacting you, responding to your request, answering your questions, or providing information as requested.

We will also collect information about the content that Users access through this Website, such as newsletters or articles or the informational topics contained therein, or by sending information to a VWO email address provided on the VWO website. We will use this information to manage Usersubscriptions and to inform Users about VWO services and information that may be of interest, unless Users inform us that they no longer wish to receive any promotional material from VWO.

We collect and use this information on a legitimate interest purpose (or, where required, by obtaining your prior consent). We store this data for the period necessary to pursue the purposes outlined in this section, or as permitted by applicable statutory laws.

Double Opt-in procedure for EU users

The sign-up to receive our newsletters, invitations, and other information takes place in a so-called double opt-in procedure, i.e., after signing up, you will receive an email in which you will be asked to confirm your registration. The registrations are logged to be able to prove the registration process. This includes your name, email address, the time of registration and confirmation, and your IP address.

Your inquiries sent by email

We appreciate your queries about our product and services and welcome your email messages to mailboxes listed on our Website. We will share your messages with those within our organization that are most capable of addressing the issues contained in your message. We will keep a copy of your message until we have had an opportunity to address your concerns. We may archive your message for a certain period or discard it, as appropriate or as required by applicable data retention laws.

5. How does Wingify use your information?

1. Wingify uses the information collected to operate its websites to provide you with the Services requested and to contact you about your interest in the Services; to verify your information; and to plan and host corporate webinars, online forums, and social networks. Wingify may also aggregate your information with data that is separately provided by you on social media and third-party websites if visible to third parties. Wingify may also use data from Users, Customers, and Attendees for marketing purposes. For example, Wingify may use the information you provide to contact you to further discuss your interest in the Services and to send you information regarding Wingify, its affiliates, and its partners, such as information about promotions or events.
2. When Wingify collects information such as your name or other details about you, it is Wingify’s practice to provide you with information on how the data will be used at the time you are asked for it if that is not immediately apparent. When Wingify asks you to provide your information through a registration page or otherwise, you will have the option to not consent to the use of your personal information to contact you, in which case you may still be able to access other portions of this website, although you may not be able to access certain sections or services.
3. Refer to heading 8. “What rights do you have in connection with the personal data Wingify collects?” for information on your rights, including the right to “opt out” of certain uses of your information.

6. How does Wingify address data transfers from the European Economic Area (EEA)?

All exports of data from within the European Economic Area (EEA) to non-EEA countries (referred to in the GDPR as “third countries”) are unlawful, unless there is an appropriate “level of protection for the fundamental rights of the data subjects”. The transfer of personal data outside of the EEA is prohibited unless one or more of the specified safeguards, or exceptions, apply:

Safeguards	Data Processor	Data Controller	Links
Binding Corporate Rules, or BCRs (controller)		x	Contact us at support@vwo.com for more details about our BCRs.
Data Protection Addendum (Customer/Wingify)	x		Refer Data Processing Agreement.
Standard Contractual Clauses (Customer/Wingify)	x		Refer Standard Contract Clauses.

Wingify is generally a data controller when you provide your data as a User or Attendee, or to register for a Service.

Wingify is generally a data processor when your company provides VWO with access to personal data originating from your company, e.g., a file for product support or other Services or data in a SaaS environment.

Binding Corporate Rules

Our BCRs are certain objectives, including those outlined below, with respect to the handling of personal data:

Focus Areas	Objectives
Limitation of purpose and Data Flow	Personal data is collected and processed for legitimate purposes and in accordance with Wingify Policies and Procedures.
Data quality and proportionality	Personal data is kept accurate, is not excessive, and is disseminated in a secure manner.
Right of access, rectification, erasure, and blocking of data	Data subjects may exercise rights to their data such as access, rectification, and erasure.
Security and confidentiality	Appropriate security controls are in place to protect data against unauthorized access, accidental alteration, and destruction.
Restriction on transfer and onward transfers	Data transferred to a third party is under appropriate agreement with adequate levels of protection.
Cooperation with data protection authorities	Wingify is committed to cooperating with data protection authorities and with individuals handling complaints.

7. What are Wingify’s security and confidentiality levels for your data?

Wingify’s intent is to strictly protect the security of your personal information; honor your choice for its intended use; and carefully protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction.
We restrict access to personal information collected about you at our Website to our employees, our affiliate’s employees, or others who need to know that information to provide services to you or while conducting our normal business operations.

At Wingify, we maintain appropriate physical, electronic, and procedural safeguards to protect personal information. We protect our databases with various physical, technical, and procedural measures, and we restrict access to your information by unauthorized persons. We also advise all Wingify employees about their responsibility to protect customer data, and we provide them with appropriate guidelines for adhering to our company’s business ethics standards and confidentiality policies.

We have taken appropriate steps to safeguard and secure the information we collect, including the use of encryption, pseudonymization, anonymization, apply secure sockets layer (SSL) for information in transit, when collecting or transferring personal information. Contact us at support@vwo.com for more details on how Wingify secures information.

Wingify follows the ISO 27001 standard framework. Wingify is ISO 27001:2013 (ISMS) and BS 10012:2017 (PIMS) certified.

8. What Rights do you have in connection with the personal information that Wingify collects?

We have taken all necessary and adequate steps to protect your personal information and ensure your rights.

You have certain rights described below. Please note that limitations may apply to your ability to exercise these rights, for example, when your right to obtain the information is found to be overwritten by essential considerations of overriding interests.

1. Right of access
   You have the right to request access to the personal information we process about you.

   We will provide you with a copy of the personal information undergoing processing as a starting point, free of charge or by electronic means, if the request has been submitted in a commonly used electronic form or through support@vwo.com.

2. Right to rectification
   You have the right to rectification of inaccurate personal data concerning you, including completion of incomplete personal data. Contact Wingify at support@vwo.com for any questions or to update your information.
3. Right to erasure (right to be forgotten)
   Under certain circumstances, you have the right to the erasure of the personal information concerning you. Contact Wingify at support@vwo.com for any questions or to update your information.
4. Right to restriction
   Under certain circumstances, you have the right to restrict our processing of personal information concerning you. Contact Wingify at support@vwo.com for any questions or to update your information.
5. Right to data portability
   Where processing is based on consent or a contract and the processing is carried out by automated means, you have the right to receive the personal information concerning you in a structured, commonly used, and machine-readable format. You have the right to transmit this personal information to a third party without hindrance from us, if technically possible. Contact Wingify at support@vwo.com for any questions or to update your information.
6. Rights to object
   Under certain circumstances, you have the right to object at any time to our processing of personal information concerning you. For example, if you have requested to receive information from us, e.g., newsletters, but do not wish to receive further information, you can easily opt out of receiving further information from us. Contact Wingify at support@vwo.com for any questions or to update your information.
7. Automated individual decision-making, including profiling
   As a rule, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or affects you significantly. This does not apply if among other things automated decision-making and profiling is necessary for entering into, or performance of, a contract between you and us. Contact Wingify at support@vwo.com for any questions or to update your information.
8. Right to withdraw consent
   If processing of your personal information is based on your consent, you may withdraw your consent at any time by unsubscribing from an email or sending us an email. Please note that this does not affect the processing of your personal data prior to the withdrawal of your consent.
9. Exercising your rights
   If you want to exercise any of your rights as described above or have any questions, please contact our Data Protection Officer by sending an email to privacy@wingify.com.
10. Filing of a complaint
    If you wish to file a complaint regarding our processing of your personal data, you can choose to file a complaint to a supervisory Data Protection Authority.

What other rights do you have in connection with the personal data Wingify collects?

1. What choices do I have?
   You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.
2.  Cookies
   You can set or amend your web browser controls to accept or reject cookies. If you reject cookies, you may still use our Websites and Services; however, your access to some functionalities and areas of our Websites or Services may be severely restricted.
3. Marketing Communications
   You can opt out of receiving certain promotional or marketing communications from us at any time by clicking the Unsubscribe link in the email communications we send or by contacting us at support@vwo.com with the word “UNSUBSCRIBE” in the subject field of the email. If you have any account for our Services, we will still send you non-promotional communications, like service-related emails.

   Wingify offers Users, Customers, and Attendees the means to choose how Wingify uses the personal data they provide. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located at the bottom of Wingify marketing emails. Additionally, you may send a request to support@vwo.com.

4.  What if I have questions about this policy?
   If you have any questions or concerns regarding our privacy policy, please send us a detailed message to support@vwo.com, and we will try to resolve your concerns.

9. Information Retention

How long we keep the personal information we collect depends on the type of information, the purpose for which it is used and similar factors. In general, we will retain your personal information for the length of time reasonably needed to fulfill the purpose outlined in this privacy policy (including for a long as needed to provide you or our customers with products and services), unless a longer retention period is required or permitted by law.

We will also retain and use your information for long as necessary to resolve disputes and/or enforce our rights and agreements. Non-personally identifiable and aggregated information may be stored for longer duration.

10. What if you post on Wingify social media pages?

1. Social Media: Our website includes Social Media features, such as Facebook-like buttons and widgets, such as the “Share this” button or interactive mini-programs that run on our site. These features may collect your IP address, the page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social Media features and widgets are either hosted by a third-party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.
2. Testimonial: With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at support@vwo.com.

11. How does Wingify share your information?

1. Wingify may share your personal data with third-parties like Suppliers and Business Partners, to use their services and may also jointly host events or webinars or collaborate on any other front; and we require that such third-parties comply with our Privacy Policy and any other appropriate confidentiality and security measures.
2. Suppliers:
   Wingify may use third-party vendors to offer its services and may also jointly host events and webinars with partners.
3. Business Partners:
   Wingify may use partners to offer its services and may also jointly host events and webinars with partners.
4. Third-Party Advertising: 
   Wingify may use third party advertising services to offer its services and may also reach out to you through these platforms.

12. What are Wingify’s practices regarding cookies?

1. Cookies are small files stored on your computer and are useful for enabling the browser to remember information specific to a user. We place cookies in a customer’s browser to identify the customer. If you do not wish to provide any information through cookies to Wingify, you may choose not to use the services. We may also collect and store information locally on your device using mechanisms such as browser web storage.
2. Cookies Consent Manager: We provide all information regarding third-party cookies through our cookie consent manager on the VWO website.
3. How to reset cookie preferences: Users can reset their cookie preferences by clearing their browser cookies. Reference link: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en

Tools	Type of Cookie	Privacy Policy	Purpose
Facebook Custom Audience	Advertising	https://www.facebook.com/privacy/explanation, https://www.facebook.com/policies/cookies/	Used to target the audience on Facebook through ads.
Google AdWords Conversions	Advertising	https://www.google.co.in/intl/en/policies/privacy/, https://www.google.co.in/intl/en/policies/technologies/cookies/	Used to target the audience on Google Search and displayed through ads.
LinkedIn Ads	Advertising	https://www.linkedin.com/legal/privacy-policy https://www.linkedin.com/legal/cookie_policy	Used to target the audience on LinkedIn through ads.
Twitter	Advertising	https://business.twitter.com/en/help/ads-policies.html	Used to target the audience on Twitter through ads.
Quora	Advertising	https://www.quora.com/about/privacy https://www.quora.com/about/cookies	Used to target the audience on Quora through ads.
Yahoo JP	Advertising	https://about.yahoo.co.jp/csr/en/stakeholder/06.html	Used to target the audience on Yahoo Japan through ads.
Bing	Advertising	https://advertise.bingads.microsoft.com/en-in/resources/policies/user-safety-and-privacy-policies	Used to target the audience on Bing through ads.
Yandex	Advertising	https://yandex.com/legal/privacy/	Used to target the audience on Yandex through ads.
Marketo	Automation	https://documents.marketo.com/legal/privacy/	Used as a marketing automation suite and to track a customer’s journey on our website.
Google Analytics	Site Analytics	https://www.google.co.in/intl/en/policies/privacy/ https://www.google.co.in/intl/en/policies/technologies/cookies/	Used to track user analytics and behavior on the VWO website.
VWO	Site Analytics	https://vwo.com/privacy-policy/	Used to track user analytics and behavior on the VWO website and to improve conversion rates.
PushCrew	Customer Interaction	https://pushcrew.com/privacy-policy/	Used for customer engagement through push notification on the web.
Privy	Customer Interaction	https://privy.com/privacy-policy/	Used to capture customer information on the VWO website, per certain triggers/behaviors.

We entered into data processing agreements as required with third-party recipients to protect your personal information and interests. In these data processing agreements, the service providers undertake measures to protect the data of our users, to process it on our behalf in accordance with the applicable data protection regulations and, in particular, not to pass the data on to third parties. Wingify thus ensures that your data are processed at a level of data protection that corresponds to the level of data protection in the EU/European Economic Area.

13. Children

We are committed to preserving online privacy for all the Users, Customers, and Attendees to our Website, including children. Our Website is a general audience Website, and we do not knowingly collect personal information about children or provide services to children. Consistent with applicable laws, we will not knowingly collect any information from children under the age of 16 years. The Website is not designed to attract anyone under the age of 16, please do not attempt to register for the services or send any information about yourself to us.

If you believe that a child under 16 years may have provided us with Personal Information, please contact us at privacy@wingify.com.

14. Data Protection Officer

The Wingify has appointed a data protection officer for you to contact if you have any questions or concerns about Wingify’s personal data policies or practices. Wingify’s Data Protection Officers and contact information: privacy@wingify.com.

15. EU Representative

Wingify has nominated a local representative in the European Union to comply with Article 27 EU GDPR. If you want to exercise your data privacy rights, please visit the privacy dashboard.
Contact info for our EU GDPR representative:
GDPR-Rep.eu provided by Dr. Andreas Mätzler
Attorney at Law
c/o Wingify Software Pvt Ltd
Schellinggasse 3/10
1010 Vienna
Austria

Email: office@gdpr-rep.eu
Website: www.gdpr-rep.eu

Please add the following subject to all correspondence:
DPI-REP ID: 19843629