Privacy Policy [Archive]

Effective from: December 19, 2019, for New Customer
Effective from: January 21, 2019, for Existing Customer
Version: 3.0
All previous Privacy Policy 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 Commitment

We keep Your personal information private and believe privacy is a fundamental human right. We are committed to provide You with products, information, controls, and transparency that allow You to choose how Your information is collected and used. This is especially important as technology progresses and privacy laws evolve.

We live in a time where digital technology profoundly impacts our lives, from the way we connect with each other to how we interpret our world. To thrive in this privacy-focused era, You need a trusted partner who can help You not only overcome these challenges but make the most of the opportunities that lie ahead. Our privacy commitment is uniquely positioned to help You meet Your compliance obligations. We know that one size doesn’t fit all when it comes to privacy, that’s why we have created robust privacy principles framework which provides You with Wingify’s approach to privacy and we shall continue to shape the way we build our products,  services, our processes, and our people keeping our Customer’s and User’s information private, safe and secure. Learn more about our privacy principles efforts.

We do not “sell” our customer’s personal information to anyone, meaning that we also do not rent, disclose, release, transfer, make available or otherwise communicate said personal information to a third party for monetary or other valuable consideration. We may share aggregated and /or anonymized information regarding Your usage of the Service(s) with third parties to help us develop and improve the Services and provide our customers with more relevant content and service offering as detailed in our Customer agreements. 

Disclaimer

1. Wingify Software Pvt. Ltd. (hereinafter “Wingify”; “We” or “Us” which expression, unless repugnant to the context hereof, shall mean and include its successors, subsidiaries and assigns) 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”; “You” or “Your”), and Users who provide information to VWO to register for events (“Attendees”). This Privacy Policy describes Wingify’s privacy practices in relation to the use of the VWO website (“Website”)  and the related products, applications, and services (including support) offered by VWO (the “VWO Services”).
2. When we receive personal information, we maintain high ethical standards and take steps to handle such information in a responsible manner that is consistent with data protection laws, our core values and business objectives.
3. By using VWO Services and agreeing to this policy, You consent to our use of cookies in accordance with the terms of this policy.
4. We may modify or update this privacy policy at any time without prior notice. You can check the “Last Updated” date above to see when the policy was last changed. Your continued use of the website and/or the VWO Services constitutes Your consent to the contents of this Privacy Policy.

2. Overview

We collect many kinds of data/information to operate effectively and provide You the best products, services, and experiences possible. We collect this information when You register, sign in, and/or use our Website and VWO Services. We collect this information in a variety of ways, including web forms, technologies like cookies, web logging, and/or other direct and indirect method.

We respect each individual’s right to personal privacy and collect and use the information we receive directly from the users/customers only in the ways disclosed in this ‘Privacy Policy’. This ‘Privacy Policy’ applies solely to information we collect directly from You through aforementioned VWO Services. The data/information collected by the Customer will be subject to their own privacy policy in force. 

This Privacy Policy does not apply to any end-user data that Customer may collect, obtain, or access in connection with using VWO Services. By visiting the Website and using VWO Services, You acknowledge that You accept the practices and policies outlined in this Privacy Policy.

We receive and process information (in verbal, written and electronic form) in accordance with our Customers instructions for providing services to end users.

3. What Information do we collect or maintain?

We collect two types of information: personally-identifiable and non-personally identifiable to operate effectively. We may use aforementioned types of information to create aggregate information (collectively referred to as “automated information”). The information can be categorised as below

3.1. Information provided deliberately

3.1.1. We do collect domain information from Your visit to customize and improve Your experience on our Website as a User, Customer, or Attendee. The type of information we may collect includes:

1. Your name, email address, phone number, and other contact information (browser type and version, country, etc). In some cases, we may request additional information where You may receive such request from Us. Some of the ways in which We may collect information from You are:
2. Registrations for/from webinars, webcasts, podcasts, seminars, conferences, etc., sponsored by Us or a partner.
3. Subscription to Our blog,  newsletters, whitepapers, eBooks or other VWO Services related content.
4. Information submitted through purchases, demo request, support request, contact request, sales or pricing query or free-trial signups of VWO Services (either on Your own or on behalf of Your company).

3.1.2. Information You submit through any other web forms and website pages

On the Website, You can pose inquiries or get in touch with Us through web forms, ordering pages, signing up for one of Our online or offline events or for one of Our content including ebooks, whitepapers, case studies or one of our free tools, subscribing to Our blogs and event alerts, or by registering for services.

We will use this information to manage User subscriptions and to inform Users about VWO Services and information that may be of interest unless Users informed Us that they no longer wish to receive any promotional material from Us.

We collect and use this information for a legitimate interest purpose (or if different, wherever 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.

3.1.3. Your inquiries sent by email

 We appreciate Your queries about VWO Services and welcome Your email messages to mailboxes listed on the Website. We will share Your messages with concerned employees 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.

Users of the Website are neither asked and are simultaneously requested not 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), through our Website, or VWO Services, Company Official or otherwise.

We can also collect personal information from Users to the Website, including automated information collected in server log files or 3rd party tools (as outlined in section 3.2 below); along with 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 other similar technologies.

3.1.4. Double Opt-in procedure for EU users

 The sign-up to receive our content, 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 data is logged to be able to verify the registration. This includes Your name, email address, the time of registration and confirmation, and Your IP address.

3.2. Information collected automatically

When You use the 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”), automatically collected information from You is:

1.  the pages You have accessed on Our Website and the subsequent actions taken on them including clicks, time spent, form fills, sign-ins, purchases, and other browsing events
2.  the Internet Protocol (IP) address that You use to access the Internet
3. Your device and operating system
4. preceding page/source from where You reached Our Website
5.  the date and time of Your access

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.

4. How do we use your information?

1. We use the information collected to provide You with VWO Services requested and to contact You about Your interest in the VWO Services; to verify Your information; and to plan and host corporate webinars, and discussions on online forums, and social networks.
2. We 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. We may also use data from Users, Customers, and Attendees for marketing purposes. For example, we may use the information You provide to contact You to further discuss Your interest in the VWO Services and to send You information regarding Wingify, its affiliates, and its partners, such as information about promotions or events.
3. When We collect information such as Your name or other details about You, it is Our practice to provide You with information on how the information will be used if that is not immediately apparent. When We ask 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.
4. Refer to heading 7. “ How to exercise Your data protection rights” for information on Your rights, including the right to “opt-out” of certain uses of Your information.

5. Legal basis for processing

If You are a visitor from the European Economic Area (“EEA”), our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

  However, we will normally collect personal information from You only where we need the personal information to perform a contract with You (e.g. to provide You with VWO Services), where the processing is in our legitimate interests and not overridden by Your data protection interests or fundamental rights and freedoms, or where we have Your consent. In some cases, we may also have a legal obligation to collect personal information from You.

   If we collect and use Your personal information in reliance to our legitimate interests (or those of any third party), we will make clear to You at the relevant time why we need to use Your personal information. If we process personal information in reliance to Your consent, You may withdraw Your consent at any time.

  We are required to inform You of the legal basis of our processing of Your personal information, which are described in the table below. If You have questions or need further information concerning the legal basis on which we collect and use Your personal information, please contact us at [email protected].

Legal Basis and Purpose for Holding Your Personal Information
Processing  purpose	Legal basis for processing
To provide the Services If You have a VWO account, we use Your personal information: to operate, maintain, administer and improve the Service  to manage and communicate with You regarding Your Service account if You have one, including by sending You Service announcements, technical notices, updates, security alerts, and support and administrative messages  to better understand Your needs and interests, and personalize Your experience with the Service  to process payments, You use to make a purchase on the Service is collected and processed directly by our payment gateway. Payment processor complying with the PCI-DSS and using industry-standard security. to respond to Your Service-related requests, questions, and feedback.	You have entered a contract with us and we need to use Your personal information to provide Services You have requested or take steps that You request prior to providing services.
To create anonymous information We may create aggregated and other anonymous information from our users’ personal information. We make personal information into anonymous information by removing information that makes the information personally identifiable to You. We may use this anonymous information and share it with third parties for our lawful business purposes.	These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on You (both positive and negative) and Your rights before we process Your personal information for our legitimate interests. We do not use Your personal information for activities where our interests are overridden by the impact on You (unless we have Your consent or are otherwise required or permitted by law).
For compliance with the law We may use Your personal information as we believe appropriate to (a) comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) where permitted by law in connection with a legal investigation; and (c) to prosecute or defend legal claims.	Processing is necessary to comply with our legal obligations.
With Your consent In some cases, we may ask for Your consent to collect, use or share Your personal information, such as when You let us post Your testimonials or endorsements in the Service.	Processing is based on Your consent. Where we rely on Your consent You have the right to withdraw it anytime by sending a request to [email protected]  with the word “Opt-out” or “UNSUBSCRIBE”  in the subject field of the email. Note: Even after You opt-out from receiving promotional messages from us, if You have any account for VWO Services, we will still send You non-promotional communications, like service-related emails.
To send You marketing communications   If You request information from us, use the Service or participate in our surveys, promotions or events, we may send You VWO-related marketing communications as permitted by law but will provide You with the ability to opt-out.	These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on You (both positive and negative) and Your rights before we process Your personal information for our legitimate interests. We do not use Your personal information for activities where our interests are overridden by the impact on You (unless we have Your consent or are otherwise required or permitted by law).
To send You updates about VWO Services and blogs, or to otherwise contact You about our services we think may interest You, by email.	These processing activities constitute our legitimate interest – to develop and grow our business and Services and promote VWO.
To better understand how You and others use VWO Services so that we can improve VWO Services, and for other research and analytical purposes.	These processing activities constitute our legitimate interest – to ensure that we provide the best services and to develop and grow our business and services and promote VWO.
When we rely upon our legitimate interests for processing Your information, we will balance those interests against Your privacy rights and will not use Your personal information where the impact on You would override Your rights, unless we are otherwise permitted by law to process Your personal information, e.g., where You consent.

6. International Transfers of Personal Information

We do not share Your personal information with third parties, unless it is necessary to carry out Your request, for our legitimate business needs, or as required or permitted by applicable law. Where we do transfer Your personal information to third parties or service providers, appropriate arrangements will be made in order to ensure correct and secure data processing in compliance with applicable data protection law.

We store personal information about  Website visitors and Attendees within the United States and in other countries and territories to facilitate our global operations. Our Content Delivery Network (CDN) runs on IBM Softlayer and Google Cloud Platform; and the servers are spread across 10 locations — Japan, Australia, Singapore, Netherlands, London, Paris, France, Germany and 3 cities in the US to help serve a dynamic request for tests. However, all the Customer data is stored centrally in Washington DC and  Dallas, United States. We may update our data center geography and server locations based on customer requirements or to meet security, compliance and legal requirements. Your personal information may be transferred to and processed in countries other than the country in which You are a resident. Therefore, Your personal information may be processed outside of the EEA and in countries that are not subject to an adequacy decision by the European Commission and which may not provide for the same level of data protection as the EEA.

In this event, we will ensure that the recipient of Your personal information offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask You for Your prior consent to such international data transfers. We have implemented safeguards to ensure an adequate level of data protection where Your personal information is transferred to countries outside the EEA, such as:

1. the recipient country has an adequacy decision from the European Commission.
2. the European Commission’s Standard Contractual Clauses for the transfer of personal information.

Refer below table as our adequacy safeguards details.

Safeguards	Data Processor/ Service Provider	Data Controller/ Business	Further Information
Binding Corporate Rules, or BCRs (controller)	NA	NA	Contact us at [email protected] for more details about our BCRs.
Data Protection Addendum (Customer/Wingify)	Yes	NA	Refer Data Protection Addendum

Wingify is generally a data controller /business when You provide Your data as a User or Attendee, or to register for a Service.

Wingify is generally a data processor/service provider 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 information:

Focus Areas	Objectives
Limitation of purpose and Data Flow	Personal Information is collected and processed for legitimate purposes and in accordance with Wingify Policies and Procedures.
Data quality and proportionality	Personal Information is kept accurate, is not excessive, and is disseminated in a secure manner.
Right of access, rectification, erasure, and blocking of data	Users 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	Information 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. How to Exercise Your Data Protection Rights

We have taken all necessary and appropriate steps to protect Your personal information and ensure Your rights.

Applicable data protection laws give You certain rights regarding Your personal information. You may ask us to take the following actions in relation to Your personal information that we hold. Below is a summary of those choices, how to exercise them and any limitations.

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.

Rights of Data Subject	Description		VWO Procedure to handle User Request (DSR)
Right of access	User has the right to request access to the personal information we store and process about them.		We will provide information about our processing of Your personal information and give You access to Your personal information. You can submit these requests by email to [email protected].  We may request specific information from You to help us confirm Your identity and process Your request.
Right to rectification	User have the right to rectification of inaccurate personal information concerning them, including completion of incomplete personal information.		We will provide information about our processing of Your personal    information and give You access to   Your personal information. You can   submit these requests by email to   [email protected].  We may request specific information from You to help us confirm Your identity and process Your request.
Right to erasure (Right to be forgotten)	User has the right to the erasure of personal information.		We will provide information about   our processing of Your personal   information and give You access to   Your personal information. You can   submit these requests by email to   [email protected].  We may request specific information from You to help us confirm Your identity and process Your request.
Right to restrict processing	Users have the right to restrict our processing of personal information.		We will provide information about   our processing of Your personal   information and give You access to   Your personal information. You can   submit these requests by email to   [email protected].  We may request specific information from You to help us confirm Your identity and process Your request.
Right to data portability	Users have the right to receive the personal information in structured, commonly used, and readable format. Users have the right to transmit this personal information to a third party without hindrance from us, if technically possible.		We will provide information about   our processing of Your personal   information and give You access to   Your personal information. You can   submit these requests by email to   [email protected].  We may request specific information from You to help us confirm Your identity and process Your request.
Right to object	Users have the right to object at any time to our processing of personal information. For example, if Users have requested to receive information from us, e.g.newsletters, but do not wish to receive further information, data subjects can easily opt-out of receiving further information from us.		We will provide information about   our processing of Your personal   information and give You access to   Your personal information. You can   submit these requests by email to   [email protected].  We may request specific information from You to help us confirm Your identity and process Your request.
Automated individual decision-making, including profiling	As a rule, Users have the right not to be subject to a decision based solely on automated processing, including Your, which produces legal effects or affects them significantly. This does not apply if among other things automated decision-making and profiling are necessary for entering into, or performance of a contract between You and us.		We will provide information about   our processing of Your personal   information and give You access to   Your personal information. You can   submit these requests by email to   [email protected].  We may request specific information from You to help us confirm Your identity and process Your request.
Right to withdraw consent	As a rule, If the processing of Your personal information is based on 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 information prior to the withdrawal of Your consent.		If the 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 to   [email protected].   Please note that this does not affect   the processing of Your personal    information prior to the withdrawal   of Your consent.
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 [email protected].
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 information collects?
What choices do You 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.
Cookies	You can set or amend Your web browser controls to accept or reject cookies.   If You reject cookies, You may still use the  Website and VWO Services;   however, Your access to some functionalities and areas of the Website or   VWO Services may be severely restricted. Learn more by reading our Cookies Notice.
Opt-out of Marketing Communications	We offer those who provide (Users, Customers, and Attendees) personal contact information a means to choose how we use the information provided. You may manage Your receipt of marketing or promotional and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails or You may send a request to [email protected] with the word “UNSUBSCRIBE” in the subject field of the email. You may opt-out of receiving promotional communications from us by using this unsubscribe link within each email. Even after You opt-out from receiving promotional messages from us, if You have any account for VWO Services, we will still send You non-promotional communications, like service-related emails.  Stop sending You marketing communications. You may continue to receive Service-related and other non-marketing communications.
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 [email protected], and we will try to resolve Your concerns.

8. What are our security and confidentiality levels for your Information?

We follow security by design baked into our services to protect Your information

 We back ourselves up with robust data security and privacy practices that form an integral part of our product engineering and service delivery principles. Security is at the heart of how we build our products and process Your data to provide high resiliency. We have top-down governance and security in our DNA that lets us constantly wade through our threat vectors and calibrate to strengthen our security posture. That way, we align with the changing business and technology landscape.

 We have implemented appropriate organizational, technical, administrative and physical safeguards to protect the security, confidentiality, integrity, and privacy of Personal Information and Customer Data within our organization.

 We invest heavily in security to ensure we meet or exceed industry standards, applicable regulations, and our customer’s expectations. Refer to Annexure 2 of Data Protection Addendum and VWO Data Security for detail security measures. These safeguards will include, but will not be limited to, measures to safeguard and secure Your information, and we make use of privacy-enhancing technologies such as encryption, pseudonymization, anonymization, least access privileges principle. If You have any questions about the security of Your information, You can contact us at [email protected].

We regularly engage third-party assessors to examine our security policies, procedures, technologies, and controls to validate that our Information Security and Cybersecurity Program is designed and operating effectively. Wingify has comprehensive security and privacy assessments and certifications performed to ensure the security by design of the processing, details of which can be found at https://vwo.com/compliance/

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 a longer duration.

10. What are our 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 User’s/Customer’s browser to identify the User/Customer. If You do not wish to provide any information through cookies to us You may choose not to use the VWO 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 Website.

The detailed Cookies categories and practices are described in our Cookies Notice.

We have 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 information on to third parties. We thus ensure that Your information is processed at a level of applicable data protection that corresponds to the level of data protection in the EU/European Economic Area and other areas.

11. How we collect and share your personal information?

We do not share or “sell” the personal information that You provide us with other organizations without Your express consent, except as described in this Privacy Policy. We may disclose personal information to third parties under the following circumstances:

How we collected information from Other Sources
Social Media Widgets	The Websites include social media features, such as the “Facebook Like” button, and widgets, such as the “Share This” button or interactive mini-programs that run on our Websites. These features may collect Your Internet protocol address, which page You are visiting on the Websites, 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 the Websites. Your interactions with these features are governed by the privacy policy of the companies that provide them.
Referrals	If You choose to use our referral service to tell a friend about our products and services, we will ask You for Your friend’s name and email address. You must only provide Your friend’s name and email address if You have a reasonable belief, they will not object to us contacting them. If You do, We will automatically send Your friend an email inviting him or her to visit the Websites and will store this information for the purpose of sending this initial email, tracking the success of our referral program and other marketing activities. Your referral may contact us at [email protected] to request that we remove his/her information from our database.

 

How we share Your personal information
Business Partners	We may disclose Your personal information to our subsidiaries and business partners to offer its services and may also jointly host event and webinars with partners.
Service Providers	We may employ third party companies and individuals to administer and provide the Service on our behalf (such as hosting events & webinars, email delivery and database management services). These third parties are permitted to use Your personal information only to perform these tasks in a manner consistent with this Privacy Policy and are obligated not to disclose or use it for any other purpose.
Payment gateway	We may share Your payment information to process Your payments.
Professional advisors	We may disclose Your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services they render to us.
Law Enforcement Agencies; Protection and Safety	We may disclose Your personal information as we believe appropriate to government or law enforcement officials or private parties (a) for the security, compliance, fraud prevention and safety purposes described above; (b) as required by law, lawful requests or legal process, such as to respond to subpoenas or requests from government authorities; (c) where permitted by law in connection with any legal investigation; and (d) to prosecute or defend legal claims.
Court/Government Agencies/Regulatory Authorities	We may disclose information if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency, or in the good faith belief that such action is necessary (a) to comply with a legal obligation, (b) to protect or defend our rights, interests or property or that of third parties, (c) to prevent or investigate possible wrongdoing in connection with the services, (d) to act in urgent circumstances to protect the personal safety of customers, their users or the public; or (e) to protect against legal liability.
Website Users	From time to time, we may post testimonials on the Websites that may contain personal information. We obtain Your consent to post Your name along with Your testimonial. If You wish to update or delete Your testimonial, You can contact us at [email protected].
Third Parties	We may also share personal information with third parties when we have Your consent to do so.
In addition, we may be required to disclose any personal information that we process in response to lawful requests by public authorities, including to meet applicable national security or law enforcement requirements.

12. Notice to Users of our Customers and End Users of Websites

i. Users of our Customers Websites and VWO Services: When our customers use the VWO  Services as part of their own websites, apps, and services, they may collect information from You using our services, but they remain responsible for their own privacy and security practices. We are not responsible for our customers privacy and security practices, which may differ from ours. If You have used one of our customers websites or services, and You would like to access, correct or delete the personal information collected through that services, You should direct Your request to the applicable customer.

 Please see “ Opt-out of VWO Services Tracking” and “Opt-out from Tracking in VWO Engage” page. Or “Opt-out of VWO”

 ii. Users of VWO Services: The VWO Services are primarily intended for use by organizations. Where the VWO Services are made available to You through an organization (such as Your employer), that organization is responsible for administering the accounts over which it has control. If this is the case, please direct Your information privacy and security questions and requests to Your administrator. We are not responsible for the privacy and security practices of Your administrator’s organization, which may be different than this policy.

13. Children’s Information

We don’t knowingly collect any personal information from children under the age of 13. If You are under the age of 13, please do not submit any personal information through our Websites or Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Website or VWO Services without their permission. If You have reason to believe that a child under the age of 13 has provided personal information to us through the Website or VWO Services, please contact us at [email protected], and we will delete that information.

14. Data Protection Officer

We have appointed a data protection officer for You to contact if You have any questions or concerns about our personal data policies or practices. Our Data Protection Officer can be contacted at [email protected].

15. EU  Representative

We have 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: [email protected]
Website: gdpr-rep.eu

Please add the following subject to all correspondence:
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