DEFINITIONS AND INTERPRETATIONS
Collectively all information that you submit to Witsy Limited via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws
Data Protection Laws
Any applicable law relating to the processing of personal data, including but not limited to the Data Protection Act 2018 or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK
The General Data Protection Regulation (EU) 2016/679
Witsy Limited, we, us, or our
Witsy Limited, a company incorporated in England and Wales with registered number 11748985 whose registered office is at Coronation Parade 42 Cannon Lane, Pinner, Middlesex, United Kingdom, HA5 1HW
UK and EU Cookie Law
The Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011
User or you
Any third party that accesses the Website and is not either (i) employed by Witsy Limited and acting during their employment or (ii) engaged as a consultant or otherwise providing services to Witsy Limited and accessing the Website in connection with the provision of such services
The website that you are currently using, www.witsy.ai, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
- 3. This website and the Witsy services are not intended for children and we do not knowingly collect data relating to children.
- 4. For purposes of the applicable Data Protection Laws, Witsy Limited is the "data controller". This means that Witsy Limited determines the purposes for which and the manner in which your Data is processed.
INFORMATION WE MAY COLLECT ABOUT YOU
- 6. We may collect the following Data, which includes personal Data:
- (a) Identity Data, such as name, job title, profession
- (b) User Data, when you sign up to our services, such as username (or a similar identifier), passwords, preferences and responses to communications from us
- (c) Contact Information when you sign up to our services, such as email addresses, telephone numbers, postal address and marketing preferences.
- (d) Publically Available Data, for instance via social media, that has been made publically available by you, including usernames, names, contact information, professional history, rolls and responsibilities, and post content.
- (e) Billing Information, when you sign up to our services, such as credit card information, bank account information, billing address, payment history
- (f) Technical Data such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
HOW WE COLLECT DATA
- 7. We collect Data in the following ways:
- (a) data is given to us by you
- (b) data is collected from publicly available sources
- (c) data is collected automatically
DATA THAT IS GIVEN TO US BY YOU
- 8. Witsy Limited will collect your Data in a number of ways, for example:
- (a) when you contact us through the Website, by telephone, post, e-mail or through any other means
- (b) when you register with us and set up an account to subscribe to our services
- (c) when you elect to receive marketing communications from us
- (a) necessary for our legitimate interests, as set out in “Our use of data” below
- (b) required for the performance of a contract between you and us
DATA THAT IS COLLECTED FROM PUBLICLY AVAILABLE SOURCES
- 10. We may receive personal data about you from various public sources as set out below, including Technical Data (as described above), and identity/contact data (registered contact address, email address, telephone number, first name, maiden name, last name, username or similar identifier):
How Witsy uses Unstructured Public Information:
- Receive updates whenever personnel are added or removed from leadership webpages
- Detect public announcements of executive promotions, company news, upcoming product launches in the news
- Monitor public filings for up-to-date information on revenue, employee headcount, IPO announcements, and more
- Identify company website source codes to learn what technologies an organization uses
- 11. We process the personal data referred to in this section on the lawful basis that it is necessary for our legitimate interests as set out in “Our use of data” below.
- 12. We do not intend to process Special Category Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). If we do process this data, it will only be in situations where you have made the Special Category Data public and available via one of the sources set above.
DATA THAT IS COLLECTED AUTOMATICALLY
- 13. To the extent that you access the Website, we will collect your Technical Data (As described above) automatically, for example information which helps us to make improvements to Website content and navigation including your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
- 15. We process the personal data referred to in this section on the lawful basis that it is necessary for our legitimate interests, as set out in “Our use of data” below.
OUR USE OF DATA
- 16. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
- (a) internal record keeping
- (b) providing our services to our users
- (c) improvement of our products/services including presentation and customisation to your needs and interests
- (d) transmission by email of marketing materials that may be of interest to you
- (e) contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website
- (f) to respond to any query you may submit to us
- (g) to comply with the law
- (h) as we feel is necessary to prevent illegal activity or to protect our interests
- 17. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).
- 18. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- 19. For the delivery of direct marketing to you via email, we'll need your consent, whether via an opt-in or soft-opt-in
- (a) soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out
- (b) for other types of e-marketing, we are required to obtain your explicit consent, meaning that you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide
- (c) if you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below.
- 20. When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter such a contract.
- 21. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
WHO WE SHARE DATA WITH
- 23. We may share your Data with the following groups of people for the following reasons:
- (a) any of our group companies or affiliates, for marketing and promotions and to offer services that we believe you could be interested in
- (b) our employees, agents and/or professional advisors, including lawyers, bankers, auditors and insurers, to enable us to provide you with our services
- (c) third parties, for example, if you specifically request this, have given us consent for marketing purposes, in the event we sell or buy any business or assets, if the Website is acquired by a third party and in order to comply with a legal obligation
- (d) any potential investor in or acquirer of Witsy, or as may otherwise be required in connection with a corporate restructuring
25. Where your personal data is transferred outside of the European Economic Area (EEA), it is always done so in compliance with EU law
- (a) Amazon Web services in the US
- (b) Digital Ocean in EU
We require all third parties to respect the security of your Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
KEEPING DATA SECURE
- 26. We will use technical and organisational measures to safeguard your Data, for example:
27. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this: e-mail address (email@example.com).
- (a) access to your account is controlled by a password and a username that is unique to you
- (b) we store your Data on secure servers.
- (c) When you enter sensitive information (such as a credit card number) on our registration forms, we encrypt that information using secure socket layer technology (SSL).
- (d) We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. However, no method of Internet transmission or electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.
- 29. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of a legal claim in respect of our relationship with you.
- 30. You have the following rights in relation to your Data:
- (a) Right to access - the right to request:
- (i) copies of the information we hold about you at any time
- (ii) that we modify, update or delete such information.
If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
- (b) Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
- (c) Right to erase - the right to request that we delete or remove your Data from our systems where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- (d) Right to restrict – the right to restrict our use of your Data the right to "block" us from using your Data or limit the way in which we can use it. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- (i) If you want us to establish the data's accuracy.
- (ii) Where our use of the data is unlawful but you do not want us to erase it.
- (iii) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- (iv) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- (e) Right to data portability - the right to request that we move, copy or transfer your Data. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- (f) Right to object - the right to object to our use of your Data where we use it for our legitimate interests and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which overrides your rights and freedoms.
- 31. To make inquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via e-mail address (firstname.lastname@example.org).
- 32. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
- 33. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
- 34. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
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