Welcome to Wippit’s Privacy Policy.
What does this
Privacy Policy Cover?
Wippit respects your privacy and is committed to
protecting your Personal Data.
We
want to be transparent with you about how we collect and use your Personal Data
in making available our
website www.wippit.xyz(“Site”)
and tell you about your privacy rights and how the law
protects you.
With that in mind, this Privacy Policy is designed to describe:
·
Who
we are and how to contact us.
·
Your
rights relating to your Personal Data.
·
Marketing
communications preferences.
·
What
Personal Data we collect.
·
How
we use your Personal Data and why.
·
What
happens when you do not provide necessary Personal Data?
·
Personal
Data from Third Party Sources.
·
How
we use cookies and other tracking or profiling technologies.
·
Who
we share your Personal Data with.
·
How
we keep your Personal Data secure.
·
How
long we store your Personal Data.
·
Our
policy on children.
·
Third
party links.
This Privacy Policy aims to give you information on
how Wippit collects and processes your Personal Data through your use of this
Site, including any data you may provide through this Site.
The Privacy Policy is intended to meet our duties of
Transparency under the “
General Data
Protection Regulation
” or “GDPR”.
We will post any modifications or changes to this
Privacy Policy on this page.
Who we are and how to
contact us.
Who
we are.
Wippit
Limited
is the
Controller (for the purposes of the GDPR) of your Personal
Data
(referred to as either “Wippit”,
“we”, “us” or “our” in this
Privacy Policy).
How
to contact us.
You can contact us by emailing www.support@xyz
Your rights relating to your Personal Data.
Your
rights in connection with your Personal Data
Under certain circumstances, by law you have the right
to:
·
Request access to your Personal Data
. This enables you to receive a copy of the Personal
Data we hold about you and to check that we are lawfully processing it.
·
Request correction of the Personal Data that we hold
about you
. This enables you to
have any incomplete or inaccurate information we hold about you corrected.
·
Request erasure of your Personal Data
. This enables you to ask us to delete or remove Personal
Data where there is no good reason for us continuing to process it. You also
have the right to ask us to delete or remove your Personal Data where you have
exercised your right to object to processing (see below).
·
Object to processing of your Personal Data
.
This right
exists
where we are relying on a Legitimate Interest as the legal basis
for our processing and there is something about your particular situation,
which makes you want to object to processing on this ground. You also have the
right to object where we are processing your Personal Data for direct marketing
purposes.
·
Request the restriction of processing of your Personal
Data
. This enables you to
ask us to suspend the processing of Personal Data about you, for example if you
want us to establish its accuracy or the reason for processing it.
·
Request the transfer of your Personal 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.
·
Withdraw
consent
. This right only exists
where
we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be
able to provide you with access to the certain specific functionalities of our Site.
We will advise you if this is the case at the time you withdraw your consent.
How
to exercise your rights
Ifyou
want to exercise any of the rights
described above, please contact us by emailing
support@wippit.xyz
.
Typically, you will not have to pay a fee to access
your Personal Data (or to exercise any of the other rights). However, except in
relation to Consent Withdrawal, we may charge a reasonable fee if your request
is clearly unfounded, repetitive or excessive, or, we may refuse to comply with
your request in these circumstances.
We may need to request specific information from you
to help us confirm your identity and ensure your right to access your Personal
Data (or to exercise any of your other rights). This is a security measure to
ensure that Personal Data is not disclosed to any person who has no right to
receive it. We may also contact you to ask you for further information in
relation to your request to speed up our response.
We try to respond to all legitimate requests within
one month. Occasionally it may take us longer than a month if your request is
particularly complex or you have made a number of requests. In this case, we
will notify you and keep you updated.
Complaints
If you would like to make a complaint regarding this
Privacy Policy or our practices in relation to your Personal Data, please
contact us
by emailing
support@wippit.xyz
.
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been
adequately resolved, please note that the GDPR gives you the right to contact
your local data protection supervisory authority, which for the UK, is the
Information
Commissioner’s Office
.
Marketing communications preferences.
Where you opt out of receiving
these marketing messages, please note that we may still need to send you
service emails in connection with your use of our Site, including any software
you have downloaded from our Site and/or 3D printable files you have purchased.
What Personal Data we
collect.
All the Personal Data we collect,
both from you and from third parties about you, is outlined in the table below.
Before you read that table, it might be useful to
explain what “Personal Data” is. The
GDPR definition of Personal Data can be found
here
. Essentially, it boils down to: information about an
individual, from which that individual is either directly identified or can be
identified.
It does not
include ‘anonymous data’ (i.e., information where the identity of individual has
been permanently removed).
However, it does
include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which
alone doesn’t identify an individual but, when combined with certain additional
and reasonably accessible information, could be attributed to a particular
person).
|
Category
of Personal Data collected |
What
this means |
|
Identity Data |
First name, surname,
username or similar identifier, title, date of birth and gender. |
|
Contact Data |
Your home
address, billing address, email address and telephone numbers. |
|
Transaction
Data |
Any details
about payments to and from you and other details of services you have
purchased from us. |
|
Marketing and
Communications Data
|
Your
preferences in receiving marketing from us and your communication
preferences. |
|
Behavioural
Data
|
Inferred or
assumed information relating to your behaviour and interests, based on your
online activity. This is most often collated and grouped into “segments”
(e.g., there may be a segment for men, living in London and aged under 25,
who like sports).
|
|
Technical Data |
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 or use our services. |
Aggregated Data
We also collect, use and share “Aggregated Data” such as
statistical or demographic data for any purpose. Aggregated Data may be derived
from your Personal Data, but once in aggregated form it will not constitute Personal
Data for the purposes of the GDPR as this data does not directly or indirectly
reveal your identity. For example, we may aggregate your Behavioural Data to
calculate the percentage of users accessing a specific Site feature. However,
if we combine or connect Aggregated Data with your Personal Data so that it can
directly or indirectly identify you, we treat the combined data as Personal Data
which will be used in accordance with this Privacy Policy.
No Special
Categories of Personal Data
We do not collect any “Special Categories
of
Personal Data
” about you (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). Nor do we collect any information about criminal
convictions and offences.
How we use your
Personal Data and why.
We will only use your Personal Data for the purposes
for which we collected it as listed below, unless we reasonably consider that
we need to use it for another reason and that reason is compatible with the
original purpose.
If we need to use your Personal Data for an unrelated
purpose, we will update this Privacy Policy and we will explain the legal basis
which allows us to do so.
What is our “legal basis” for processing your Personal
Data?
In respect of each of the purposes for which we use your Personal Data,
the GDPR requires us to ensure that we
have a “legal
basis” for that use. Most commonly, we will rely on one of the following legal
bases:
·
Where we
need to perform a contract we are about to enter into or have entered into with
you (“Contractual Necessity”).
·
Where it
is necessary for our legitimate interests and your interests and fundamental
rights do not override those interests (“Legitimate Interests”). More
detail about the specific legitimate interests pursued in respect of each Purpose
we use your Personal Data for is set out in the table below.
·
Where we
need to comply with a legal or regulatory obligation (“Compliance with Law”).
·
Where we have your specific consent to carry out the processing for the Purpose
in question (“Consent”).
Generally we do not rely on your Consent as a legal
basis for using your Personal Data other than in the context of direct
marketing communications.
We have set out below, in a table format, the legal
bases we rely on in respect of the relevant Purposes for which we use your
Personal Data.
|
Purpose |
Category(ies)
of Personal Data involved |
Why
do we do this |
Our
legal basis for this use of data |
|
Account Creation |
·
Identity Data
·
Contact Data |
To register you as a new customer when your download our Wippit Print
software. |
Contractual Necessity. |
|
To process your order for 3D printable files you purchase from us (and
their associated services) |
·
Identity Data
·
Contact Data
·
Transaction Data |
To process and deliver your order. |
Contractual Necessity.
|
|
Fraud Prevention |
·
Identity Data
·
Contact Data |
To keep our
website, our services and associated systems operational and secure. |
Legitimate Interests.
We have a legitimate interest in ensuring the
ongoing security and proper operation of our services, website and associated
IT services and networks. |
|
Troubleshooting |
Technical Data |
To track issues that might be occurring on our systems. |
Legitimate Interests.
It is in our legitimate interests that we are able to monitor and
ensure the proper operation of our Sites and associated systems and
services. |
|
Marketing |
·
Identity Data
·
Contact Data
·
Marketing and
Communications Data |
To form a view
on what we think you may want or need, or what may be of interest to you and
to send your associated marketing communications.
|
We will send
you marketing communications where you have provided us with your consent to
do so.
|
What happens when you
do not provide necessary Personal Data?
Where we
need
to process your Personal
Data either to comply with law, or to perform 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 the functionalities of the Site).
In this case, we may have to stop you using our Site but
we will notify you if this is the case at the time.
Personal Data from Third Party Sources
In addition to the Personal Data that we collect
directly from you (as described in the section immediately above this one), we
also collect certain of your Personal Data from third party sources. These
sources are broken down in the table below, together with a description of
whether they are publicly available or not.
|
Third party data source |
Publicly available? |
Category(ies) or other
types of personal data received. |
|
Social Media sites |
Yes |
·
Identity Data |
|
Analytics Providers |
No |
·
Behavioural Data
·
Technical Data |
How we use cookies & other
tracking or profiling technologies.
Cookies.
What are cookies?
We may collect information using “cookies”. Cookies
are small data files stored on the hard drive of your computer or mobile device
by a website. We may use both session cookies (which expire once you close your
web browser) and persistent cookies (which stay on your computer or mobile
device until you delete them) to provide you with a more personal and interactive
experience on our Site.
We use two broad categories of cookies:
·
first party cookies,
served directly by us to your computer or mobile device; and
·
third party cookies,
which are served by our partners or service providers on our Site.
Cookies
we use
Our Site uses the following types of cookies for the
purposes set out below:
|
Type of cookie |
Purpose |
|
Essential Cookies
|
These cookies
are essential to provide you with services available through our Site and to
enable yo
u to use some of its features.
For example,
they allow you to log in to secure areas of our Site and help the content of
the pages you request
to
load
quickly. Without these cookies, the services that you have asked for cannot
be provided, and we only use these cookies to provide you with those services.
|
|
Functional Cookies
|
These cookies
allow our Site to remember choices y
ou make when
you use our Site,
such as remembering your language
preferences, remembering your login details and remembering the changes you
make to other parts of our Site which you can customise. The purpose of these
cookies is to provide you with a more personal experience and to avo
id you having to re-enter your preferences every time you
visit our Site.
|
|
Analytics and
Performance Cookies
|
These cookies
are used to collect information about traffic to our Site and how users use
our Site. The information gathered
via these
cookies
doe
s not
“
directly
”
i
dentify
any individual visitor. However, it may render such visitors “
indirectly identifiable”
. This
is because the information collected is typically linked to a pseudonymous
identifier associated with the device you use to access our Site.
The
information collected
is aggregated
and anonymous.
It includes the number of visitors to our
Site, the
websites that referred them to our Site,
the pages they visited on our Site, what time of day they visited our Site,
whether they have visited our Site before, an
d other
similar information.
We use this information to help operate our
Site more efficiently
, to gather broad demographic
information and to monitor the level of activity on our Site.
We use Google
Analytics for this purpose. Google Analytics uses its own cookies.
It
is only used to improve how our Site works. You can find out more information
about Google Analytics cookies here:
https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
You can find
out more about how Google protects your data here:
www.google.com/analytics/learn/privacy.html
.
|
|
Targeted and
advertising cookies
|
These cookies
track your browsing habits to
enable us to show
advertising which is more likely to be of interest to you. These cookies use
information about your browsing history to group you with other users who
have similar interests. Based on that information, and with our permission,
third party
advertisers can place cookies to enable
them to show adverts which we think will be relevant to your interests while
you are on third party websites
.
|
|
Social Media
Cookies
|
These cookies
are used when you share information using a social media sharing
button or “like” button on our Site or you link your
account or engage with our content on or through a social networking website
such as Facebook, Twitter or Google+. The social network will record that you
have done this.
|
Disabling
cookies
You can typically remove or reject cookies via your
browser settings. In order to do this, follow the instructions provided by your
browser (usually located within the “settings”, “help” “tools” or “edit”
facility). Many browsers are set to
accept cookies until you change your settings.
If you do not accept our cookies, you may experience
some inconvenience in your use of our Site. For example, we may not be able to
recognise your computer or mobile device and you may need to log in every time
you visit our Site.
Further information about cookies, including how to
see what cookies have been set on your computer or mobile device and how to
manage and delete them, visit
www.allaboutcookies.org
and
www.youronlinechoices.com.uk
.
In particular, you can disable cookies which remember
your browsing habits and target advertising at you by visiting
http://www.youronlinechoices.com/uk/your-ad-choices
. If you choose to remove targeted or advertising
cookies, you will still see adverts but they may not be relevant to you. Even
if you do choose to remove cookies by the companies listed at the above link,
not all companies that serve online behavioral advertising are included in this
list, and so you may still receive some cookies and tailored adverts from
companies that are not listed.
Y
ou can
also
prevent the use of Google
Analytics relating to your use of our Site by
downloading
and installing
the browser plugin available via this link:
http://tools.google.com/dlpage/gaoptout?hl=en-GB
Who we share your Personal Data with.
The table below describes who we share your Personal
Data with, what we share and why we share it.
|
Recipients |
Category(ies) of
Personal Data we share. |
Why we share it |
|
Service Providers |
·
Identity Data
·
Contact Data
·
Technical Data |
Our service providers provide us with IT and system administration
services. |
|
Professional advisers |
·
Identity Data
·
Contact Data |
Our lawyers, bankers, auditors and insurers provide
consultancy, banking, legal, insurance and accounting services.
|
|
HM Revenue & Customs, regulators and other
authorities |
·
Identity Data
·
Contact Data |
Authorities may require reporting of processing
activities in certain circumstances |
Please note that when you
purchase 3D printable files through our Site, your payment will be processed by
PayPal. PayPal’s processing of your personal data will be subject to PayPal’s
own privacy policy. We are not responsible for PayPal’s privacy policy.
Data transfers
As you can see from the above, we
share your Personal Data with certain service providers and professional
advisers who may be based outside the United Kingdom and European Economic Area
(“UK and EEA”). Any processing of
your Personal Data by these parties will involve an export of your Personal Data
outside of the UK and EEA.
We endeavour to ensure that
people to whom we provide Personal Data hold it subject to appropriate
safeguards and controls. Whenever we transfer your Personal Data out of the UK
and EEA, we ensure a similar degree of protection is afforded to it by ensuring
at least one of the following safeguards is implemented:
·
We
may transfer your Personal Data to countries that have been deemed to provide
an adequate level of protection for Personal Data by the European Commission.
For further details, see
European Commission: Adequacy of the protection of
Personal Data in non-EU countries
.
·
Where
we use service providers outside the UK and EEA, we may use specific contracts
approved by the European Commission, which give Personal Data the same
protection it has in the UK and EEA. For further details, see
European Commission: Model contracts for the transfer
of Personal Data to third countries
.
·
Where
we use service providers based in the U.S., we may transfer data to them if
they are part of the Privacy Shield which requires them to provide similar
protection to Personal Data shared between Europe and the U.S. For further
details, see
European Commission: EU-U.S. Privacy Shield
.
How we keep your Personal Data secure.
We have put in place appropriate security measures to
prevent your Personal Data from being accidentally lost, used or accessed in an
unauthorized way, altered or disclosed.
We limit access to your Personal Data to those
employees and other staff who have a business need to have such access. All
such people are subject to a contractual duty of confidentiality.
We have put in place procedures
to deal with any actual or suspected Personal Data breach. In the event of any
such breach, we have systems in place to work with applicable regulators. In
addition, in certain circumstances (e.g., where we are legally required to do
so) we may notify you of breaches affecting your Personal Data.
How long we store
your Personal Data.
We
will only retain your Personal Data for so long as we reasonably need to use it
for the purposes set out above
“How we
use your Personal Data and why.”
, unless a longer retention period is
required by law (for example for tax or other regulatory purposes) or to
support a claim or defence in court.
Our policy on children.
This Site is not intended for
children below 16 and we do not knowingly collect data relating to such children.
Third party links.
This Site may include links to
third-party websites, plug-ins and applications. Clicking on those links or
enabling those connections may allow third parties to collect or share your
Personal Data. We do not control these third-party websites and are not responsible
for their privacy statements. When you leave our Site, we encourage you to read
the privacy policy of every site you visit.
WIPPIT LIMITED, 2019