Privacy Policy
We at WPO and our Affiliates are committed to protecting your privacy and complying with the EU General Data Protection Regulation (GDPR) and subsequently the UK GDPR.
This Privacy Policy applies to the information and data collected by WPO when you interact with us on our websites or through other channels (for example, by communicating with us or attending one of our events), and when you use our products and services. This Privacy Policy describes how we collect, receive, use, store, share, transfer, and process your Personal Data. It also describes your choices and rights with respect to your Personal Data, including your rights of access and correction of your Personal Data.
For the purpose of this Privacy Policy, “Personal Data” shall mean any information relating to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with other information in the Data Controllers possession or likely to come into such possession. The processing of Personal Data is governed by the General Data Protection Regulation (EU) 2016/679 (the ‘GDPR’).
Roles and Responsibilities
WPO is the Data Controller of the information collected for the products and services we provide to you.
If you have any questions about this Privacy Policy or our treatment of your Personal Data, please let us know immediately. You may contact for general data protection queries by email to privacy@wpo.eu or in writing at WPO SAS, 22 rue de Palestro 75002 Paris, France, Attn: Privacy and Data Protection Officer.
We update this Privacy Policy from time to time and we encourage you to review this Privacy Policy periodically. We will post any Privacy Policy changes on this page and, if the changes are material and we wish to use your Personal Data for a new purpose, not covered by this Privacy Policy then we will provide you with a notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
How do we collect your Personal Data
- Information you provide to WPO
When you interact with us directly or via our websites, we may collect Personal Data and other information from you, as further described below.
When you interact directly with WPO
We collect Personal Data from you when you submit web forms or interact with us, for example signing up for a webinar, requesting customer support, applying for a vacancy or through meetings with WPO’s representatives. We may ask for your email address, first and last name, job title, and other similar business information.
When you visit our websites
You are informed that during your visits to the website a cookie may be automatically installed in your browsing software. This is a set of data that is not used for identification purposes but serves to record information regarding your browsing on the website. It makes it possible to analyse the number of visits and measure the audience etc. in order to improve the quality of the website.
Webinars and other event Information
When you register for a webinar or other WPO event, we collect information such as name, address, phone number, and email address. We use this information to communicate with you and facilitate your registration.
Customer Testimonials
We post customer testimonials and comments on our websites and social medias, which may contain Personal Data. We obtain each customer’s consent via email or through other agreements between customers and WPO prior to posting the customer’s name and testimonial.
Application for a Vacancy
When you apply for a vacancy, either on our website or other platforms, we collect information such as CV and cover letter. We use this information to communicate with you and facilitate hiring process.
- Information we collect and process when you use the Dashboard by WPO SaaS
Log Files
When you visit our websites or when you or use the Dashboard by WPO SaaS, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, access times and others similar technical information.
Usage Data
We collect usage data when you or your users interact with the Dashboard by WPO service. Usage data includes metrics and information regarding your use and interaction with the service such as what product features you use the most, or when an object (like a ticket) is opened and closed.
Mobile
When you access or use the Dashboard by WPO service via our mobile web-application, we automatically collect information such as your device model and version, operating system, or device identifier.
Third Party Integrations
You may connect third party integrations to your Dashboard by WPO account, which may ask for certain permissions to access data or send information to your account. It is your responsibility to review any third party integrations you authorize.
Any permission(s) granted by you, grants these third parties access to your data, which may include (but is not limited to) granting third-party applications access to view and store your Dashboard by WPO account data. We are not responsible for the practices of third party integrations, so please carefully review the permissions you grant to third-party applications.
What type of Personal Data do we collect ?
We may collect the following types of Personal Data;
- - Personal information (such as first and last name, address, email, telephone number, company you work for, job title) and other similar business information;
- - Information about your use of our websites (such as IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, access times and referring website addresses);
- - Usage data which includes metrics and information regarding your use and interaction with the service such as what product features you use the most, or when an object (like a ticket) is opened and closed.
- - Personal information related to your application for a vacancy:
- * Details of qualifications, skills, experience and employment history, including start and end dates, with previous employers and with WPO;
- * Details of your family status, next of kin, dependants and emergency contacts; Information about your nationality (including proof thereof) and entitlement to work in the territory in which you are employed;
- * Right to work documentation (i.e. passport);
- * Details of your family status, next of kin, dependants and emergency contacts; Information about your nationality (including proof thereof) and entitlement to work in the territory in which you are employed;
- * Details of qualifications, skills, experience and employment history, including start and end dates, with previous employers and with WPO;
Why does WPO process your Personal Data ? Legal Basis for processing
WPO complies with its obligations under the GDPR by keeping Personal Data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting Personal Data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate safeguarding measures are in place to protect Personal Data.
Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. However, we will collect Personal Data from you only where we have your consent to do so, where we need the Personal Data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you.
How WPO uses your Personal Data ?
We use your Personal Data for the following purposes:
- Communicate with you and process as well as respond to your requests (re-contractual or contractual).
For example, we need to process your data to provide you with a commercial contract, or various deliverables.
- Market and promote our services (consent or legitimate interest).
We use the information you provide to WPO to market and promote the products, services, and other offerings. For example, we use the information, like your email or physical address, to send information or WPO content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business. We use this information to promote the use of our services to you and share promotional and information content with you in accordance with your communication preferences.
We may also reach out to you via telephone to ask about other WPO products or services you may be interested in.
- Registration, authentication, and administration of user accounts (contractual).
We use the data you provide to WPO to contact you via email or in-app notification about account management, and other administrative matters. We send updates to you regarding our Terms of Service or other legal agreements. We may also communicate with you about security incidents via email or in-app notification.
We use your information to provide customer support, such as resolving technical issues you encounter and analyzing product outages or bugs.
- Provide and improve our products and services (legitimate interest).
We use your account information and correspondence to improve our services. For example, we process the customer satisfaction survey results for continuous improvement.
We collect data about how our products and services are used by monitoring our product users. We use this data to develop and improve our products and services. For example, we use usage data to assess trends and usage across the product to help us determine what new features or integrations our users may be interested in.
We may use Personal Data in an anonymized manner for machine learning that supports certain product features and functionality with the Dashboard by WPO SaaS. For example, machine learning helps power the invoice scanner tool if you use our CMS module and allows for easier imports of data. You may opt-out of having your Personal Data used for machine learning purposes by emailing privacy@wpo.eu.
- - Comply with legal and regulatory requirements and requests (legal obligation);
- - Establish, exercise, and defend legal claims (legitimate interest).
- - Secure and prevent cyber-attacks (legitimate interest)
We use your account information to investigate and help prevent security incidents
- Detect and prevent product abuse (legitimate interest)
Other important Privacy Information
WPO will never sell your Personal Data to any third party.
Who has access to Data ?
We may share your Personal Data with;
- - Our employees, agents and/or professional advisors (i.e. solicitors);
- - Other companies within the current and future WPO Group;
- - Other third-party contractors who provide services to us (i.e. IT service providers, external accounting firm);
- - Where we are under a legal obligation to do so, for example, where we are required to share information under statute, to prevent fraud and other criminal offences or because of a Court Order, for example, tax office or the police.
International Transfers to Third Party
The organisation will generally not transfer your data to countries outside the European Economic Area.
Some of the third parties, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. In such case, WPO makes sure to safeguard the transfer through a variety of legal mechanisms.
Notably, WPO uses Hubspot as Helpdesk/CRM software. Hubspot and its affiliates participates and complies with the EU-U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework (collectively, “Privacy Shield Frameworks”) regarding the collection, use, and retention of Personal Data of individuals in the European Union, Switzerland and UK. To learn more about the Privacy Shield Principles, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov.
How does the Organisation Protects Data
The organisation takes the security of your data seriously. WPO has controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties. We use a variety of security technologies and procedures to help protect your Personal Data from unauthorized access, use or disclosure. Additionally certain documents containing personal information are password protected for added security.
Where WPO engages third parties to process Personal Data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
How long we keep your Personal Data ?
The information we collect about you depends on the type of information and how we collect and store it. After a reasonable period of time, we will either delete or anonymize your information.
We retain Personal Data that you provide to us no longer than reasonably necessary and specifically where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing legitimate business need to process your Personal Data, we securely delete the information or anonymize it. We will delete this information at an earlier date if you so request, as described in the section “Your rights and your Personal Data” below.
Your Rights and your Personal Data
Unless subject to an exemption (under the GDPR), you have the following rights with respect to your Personal Data-
- - The right to request that the data controller provide the data subject with his/her Personal Data and where there is a dispute in relation to the accuracy or processing of your Personal Data, to request a restriction is placed on further processing;
- - The right to request that WPO corrects any Personal Data if it is found to be inaccurate or out of date;
- - The right to request your Personal Data is erased where it is no longer necessary for WPO to retain such data;
- - The right to lodge a claim with the Information Commissioners Office.
If you wish to exercise any of these rights, please contact our Data Protection Officer on email at privacy@wpo.eu via phone, 0033 (0) 760 998 615 or by mail at:
To the attn of Data Protection Officer (Chafeira AZOUAOU)
WPO SAS – 22 rue de Palestro, 75002 Paris, France
Further Processing
If we wish to use your Personal Data for a new purpose, not covered by this data protection notice then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Contact Details
To exercise all relevant rights, queries or complaints, please in the first instance contact the Data Protection Officer.
In the UK, you can contact the Information Commissioners Office on 0303 123 1113 or at The Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
In France, you can contact the Commission Nationale de l’Informatique at des Libertes on 01.53.73.22.22 or at CNIL, 3 Place de Fontenoy, TSA 80715, 75334 Paris CEDEX 07, FRANCE.
In Ireland, you can contact the Data Protection Commissioner on 057 8684800 or at DPC, Canal House, Station Road, Portarlington, R32 AP23, Co Laois.
In Sweden, you can contact the Datainspektionen on 08 657 61 00 or at DPA, Box 8114, SE-104 20 Stockholm.
In Spain, you can contact the Agencia Espanola de Proteccion de Datos (AEPD) on +34 901 100 099/ +34 91 266 35 17
In Germany, you can contact the Federal Commissioner for Data Protection and Freedom of Information (BfDI) +49 (0) 228-997799-0 or email poststelle@bfdi.bund.de