INTRODUCTION

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1. What this is about?

This Section introduces the subject of this document and informs about its structure and purpose..

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Wennect (we”, “us” or “our”). is committed to protecting your privacy. Your trust is very important to us. We have prepared this document to ensure that we are transparent about how we use your personal data and cookies.

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By “personal  data” we mean any information relating to an identified or identifiable individual person. By “cookies” we mean small text files installed on your device. The topic of privacy may be complicated, so we encourage you to start reading by consulting the glossary in Section 3 below.

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This document (“Document”) applies to the personal data and cookies that we process in connection with the website operated by us at: www.wennect.com (“Website”), as well as products, functionalities and services referenced here (collectively the "Services"). The Document does not apply to the Wennect Platform, which is governed by its own Privacy Policy available at: https://use.wennect.com/privacy-policy

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This Document is layered and consists of three parts:

• Introduction – which describes what this document is about (“Introduction”);
• Privacy Policy – which describes how we collect and use your personal data, who do we share them with and what are your rights (“Privacy Policy”);
• Cookie Notice – which describes how we use cookies and similar technologies (“Cookie Notice”). 

2. Contact us

This Section contains our contact information.

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To exercise your rights under the GDPR, submit a question or complaint as regards use of your personal data in connection with the Services, contact us through the channel most convenient for you:

• Email – You can submit your privacy request by email at support@wennect.com.

3. Glossary

This Section contains definitions of the terms we use in the Document.

• GDPR – Regulation (EU) 2016/679 (General Data Protection Regulation)
• ICT Systems – without limitation are all computer, communications, electronic, data processing or cloud systems used by Wennect in relation to the use and/or provision of Wennect services, subject to relevant terms of such services.
• personal data - any information relating to an identified or identifiable individual person as defined in Article 4(1) of the GDPR
• Policy – this Privacy Policy
• processing, processor, controller and other terms relating to personal data not defined here have the meaning as defined in Article 4 of the GDPR
• Website – the website operated by Wennect at: www.wennect.com
• Wennect – Wennect OÜ asutamisel, a company in organization under process of establishment under laws of Estonia
• Wennect Platform – the Wennect’s ecosystem through which the Platform Services are being provided, available under the network address at https://www.use.wennect.com/

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PRIVACY POLICY

4. Who is responsible?

This Section describes which entities are responsible for processing of your personal data.

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Wennect – as the controller – is responsible for your personal data. We may engage other entities to assist us in processing your personal data as processors. In such case we remain responsible for use of your personal data. However, in certain cases such entities may be separate controllers of your personal data. As such they are responsible for use of your personal data. You can find more information about recipients of your personal data in Section 10 below.

5. What data do we use?

This Section describes what categories of your personal data we use.

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We collect and process the following personal data:

• Identity Data – including your name, surname, username.
• Contact Data – including your email, telephone number or other contact information provided voluntarily by you.
• Interaction Data – including information provided voluntarily by you, for example when you use contact forms or surveys, engage with our accounts on social media platforms or use our communication channels such as email or Discord.
• Technical Data – including data collected, generated or aggregated automatically in connection with usage of various services, for example usage of the Website, such as network traffic data, IP address, web headers, JavaScript-derived characteristics, hardware configuration, browser plugin details, browsing patters, statistics, individual identifiers or other identifiers, as well as information collected through cookies or other similar technologies.

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Our services, interactions, products and the Website are dedicated to adults, i.e. people who are at least 18 years of age and have legal capacity to form a binding contract. We do not knowingly collect personal data from children under 18 years of age.

6. What are the sources of the data?

This Section describes how we collect your data.

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We collect the personal data directly from you when you submit it to us (e.g. by contacting us). We also collect data indirectly, for example from the devices or software that you use. In some cases we may also collect information about you from third parties, for example from providers of analytical services or from software development platforms if you voluntarily provide us with a  link to your account. 

7. What if you fail to provide us with your data?

This Section describes if the provision of personal data is required and what happens if you do not provide us with your data.

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In some cases provision of your personal data is mandatory by law or necessary in order to carry out your request or to perform a contract we have with you. If you fail to provide us with your personal data in such situations, we may not be able to carry out your request, perform a contract with you (or enter into it) or comply with the law. In some cases this may mean that we will terminate the contract or stop our engagement with you.

8. How do we use your data?

This Section describes intended purposes of use of your personal data and legal basis for such use.

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We use your personal data only when it is lawful. The law requires that for each purpose of processing your data there must be a so-called “legal basis”. There are many types of legal basis set out in the GDPR. We mainly use the following:

• Contract Performance – when use of your data is necessary to perform the contract with you or take steps connected with the contract at your request;
• Legal Obligation – when use of your data is necessary to comply with legal obligation;
• Legitimate Interests – when use of your data is necessary for interest(s), our or those of a third party. and when the law does not prohibit it;
• Your Consent – when you have freely given us a specific, informed and unambiguous consent for use of your data.

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To learn more about legal basis in general, you can contact us (please consult Section 3).

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With regard to Legitimate Interests indicated in this Privacy Policy, we have assessed them against your interests and rights to ensure that we can rely on them in compliance with the GDPR. To learn more about these Legitimate Interests, you can contact us (please consult Section 3).

9. How long do we use your data?

This Section describes how long do we store your personal data.

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As a general rule, we store your personal data only as long as necessary for the purposes we collected it. This means that the duration of storage depends on the purpose of processing. For example, we generally store your personal data for the duration of the service provision. When we process your data on the basis of Your Consent, we store it until you withdraw it. Similarly, we store personal data processed on the basis of Legitimate Interests until you lodge an effective objection to such processing. The duration of storage may be extended in certain situations, for example when mandatory under the law or when use of your data is necessary to establish and assert possible claims or to defend against claims.

10. Do we share your data?

This Section describes intended purposes of use of your personal data and legal basis for such use.

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We share your personal data with:

• Service Providers – entities that we engage to help us with our business, including the Website or our other services;
• Wennect Group – entities from our group of companies, including our affiliates;
• Wennect Partners – entities we cooperate with in connection with the Wennect Platform, including Connectors;
• Public Authorities – entities that process your personal data in accordance with the law.

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You can find more detailed explanation on how we disclose your data to these entities below.

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SERVICE PROVIDERS

We share your personal data with our Service Providers. This includes external IT providers, professional service providers (e.g. accountants, lawyers, auditors), providers of solutions used for analytical purposes, as well as social media platforms.

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In general, the Service Providers process your personal data on our behalf as processors. In such case we require them contractually to keep your data secure and confidential. However, some Service Providers may also process your personal data on their own behalf as independent data controllers. For example, when they operate a social media platform. In such case their terms and conditions, privacy policies or end user license agreements apply to such use of your data. 

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You can find below summary on the key solutions and Service Providers that we use in connection with the Website and our online activities.

WENNECT PARTNERS

We share your personal data with our Wennect Partners. For example, some data provided by you in contact form on the Website can be shared with Connectors who use the Wennect Platform. We require Wennect Partners contractually to keep your data secure and confidential.

WENNECT GROUP

We share your personal data with members of Wennect group of companies. For example, we may share your personal data with Wennect sp. z o.o., a company established under the laws of Poland with its registered office in Warsaw. All members of Wennect group comply with Wennect privacy standards and GDPR. We require them contractually to keep your data secure and confidential.

PUBLIC AUTHORITIES

We share your personal data with public authorities where required by law and subject to statutory conditions and limitations. 

11. Do we transfer your data outside of the EEA?

This Section describes if we transfer your personal data outside of the European Economic Area (EEA) and, if so, how do we protect it in compliance with the law.

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We may transfer your personal data outside of the EEA. We do this only when it is necessary for the services that we provide to you or other important reasons (e.g. to establish and exercise claims or to defend against claims). 

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The level of protection of personal data varies globally. To ensure an adequate level of protection of your personal data, we will transfer your personal data only in compliance with the relevant GDPR requirements. This means that we will transfer your personal data only if the following apply:

• Adequacy Decision – if the European Commission issued a formal decision recognizing that certain countries, organisations or market sectors provide adequate level of protection;
• Appropriate Safeguards – if other means of safeguarding your personal data and rights are provided, for example we or our service provider use standard contractual clauses issued by the European Commission;
• Specific Derogations – if neither of the above apply and in some very specific situations set out in the GDPR (e.g. your explicit transfer consent).

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In general, we will be using mainly Adequacy Decision or one of the Appropriate Safeguards.

12. What are your rights?

This Section describes what are your rights related to personal data under the GDPR.

You have the following rights:

• Right to information – you can request from us information about the processing of your personal data.
• Right to access – you can request a copy of your personal data that we process, however data under certain conditions prescribed by law we may charge a fee for that.
• Right to withdraw consent – we have described this right in detail in Section 13 below.
• Right to object – we have described this right in detail in Section 14 below,
• Right to be forgotten – you can request that we erase your personal data under certain conditions prescribed by law.
• Right to correct – you can request that we rectify your personal data that we process (e.g. when it is inaccurate).
• Right to data portability – you can request that some of your personal data is provided to you, or to another data controller, in a commonly used and machine-readable format.
• Right to restrict – you can request that we stop processing your personal data with the exception of storage under certain conditions prescribed by law.
• Right to lodge a complaint – you can lodge a complaint with the supervisory authority dealing with the protection of personal data.

As a general rule, you can exercise your rights free of charge and we will inform you on how we carried out your request within one month of its receipt. In some cases, for example when your request is repetitive or excessive, we may charge a reasonable fee or extend this period or even refuse to carry out your request. We will notify you if such situation occurs.

To exercise your right(s) contact us (please consult Section 3 above).

13. Right to withdraw consent

This Section describes your right to withdraw your freely given consent.  purposes of use of your personal data and legal basis for such use.

You have the right to withdraw your consent to the processing of your personal data. You can do this at any time. If you withdraw consent, we will stop using your personal data where the basis for processing is consent. Withdrawal of consent does not affect the lawfulness of processing your data on the basis of consent before withdrawal. The right to withdraw consent applies only to the extent that your personal data is processed on the basis of consent.

To withdraw your consent contact us (please consult Section 3 above).

14. Right to object 

This Section describes your right to object to processing your personal data on the basis of legitimate interest(s), our or those of a third party.

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You have the right to object to the processing of your personal data on the basis of legitimate interest(s), our or those of a third party. You can do this at any time. If you raise an objection, we will stop using your personal data where the basis for processing is our legitimate interest. 

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In exceptional circumstances, we may continue to use your data despite your objection. We may do so if (i) we can demonstrate that there are valid legitimate grounds for the processing overriding your interests, rights and freedoms, or where (ii) your data will be necessary for us to possibly establish, exercise or defend claims. This exception does not apply to your objection to the processing of data for direct marketing purposes – if you object to it, we will stop processing your personal data. 

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To lodge an objection contact us (please consult Section 3 above).

15. Changes to the Privacy Policy 

This Section describes how we can amend this Privacy Policy.

We reserve the right to amend this Privacy Policy. We may amend it, for example, to reflect changes to processing of personal data, account for changes in applicable law or to make it more user friendly and transparent.

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We will inform you of the planned amendment to this Privacy Policy by publication on the Website or via email. The information will include at least the summary of the planned amendment and the effective date of the amendment.

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In addition, each amended Privacy Policy will have a version number at the top, so you will be able to easily check if there were any amendments to it. The current version of the Privacy Policy is Version 1.0 (effective from 21 December 2022). 

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We encourage you to review the Privacy Policy from time to time.

COOKIE NOTICE

16. What this is about? 

This Section describes how we can amend this Privacy Policy.

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Cookies are small text files installed on the your device that collect information which, as a general rule, facilitates use of a website. For example, cookies may remember your language preferences or other settings of your Internet browser. 

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We mainly use our own cookies. We also use third party cookies, which are cookies from a domain other than the domain of the website you are visiting, primarily for analytics activities. We may also use other technologies similar to cookies, for example HTML5 local storage, Local Shared Objects or tracking pixels. In general, where we refer to cookies in this Cookie Notice we also mean such technologies.

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You can find detailed information about the cookies that we use in our cookie management platform (click here). You can check what types of cookies are used, how long do we store them, and manage your preferences. For example, you may reject chosen type of cookies or accept their use. To learn more about cookies, please consult the Sections below.

17. What types of cookies do we use? 

This Section describes what types of cookies do we use.

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We use the following types of cookies:

• Essential Cookies – they are necessary for the proper functioning of the Website;
• Personalization Cookies – they are used to remember and adjust the Website to the your choices;
• Analytics Cookies – they are used to understand traffic on the Website so that we can improve its performance. 

We always use Essential Cookies as they necessary for the Website to work. This means that you do not have a possibility to disable them if you want to continue to use the Website.

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However, we use Personalization Cookies or Analytics Cookies only if you consent (opt-in). When you visit the Website you will see a banner at the bottom of the screen where you can decide if you want to consent to use of such cookies. If you choose to “Accept” cookies, we will use them. If you choose to “Deny” cookies, we will not use them. Personalization Cookies or Analytics Cookies are loaded on the Website only if you accept them. No such cookies will be used if you choose to deny them.

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We use Google Analytics cookies. They are used by Google to analyse the use of the Website, as well as to compile statistics and reports on the functioning of the Website. We use them to generate such aggregated data. However, because other websites also use Google Analytics, Google may combine cookie data from such websites. If you use Google account, Google may also use such cookie data together with your account. To learn more about how Google Analytics operate, please consult Google’s Privacy Policy (click here).

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You can change your mind about cookies at any time by using our cookie management platform (click here) to manage your preferences.

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You can also remove cookies from your device by clearing the browsing history of your Internet browser, as well as block cookies. This may cause the Website to not work properly or at all. To do this you have to change your browser settings. You can check how to do this on the browser provider website, for example: Internet Explorer, Microsoft Edge, Google Chrome, Safari, Mozilla Firefox, Opera.

18. How long do we use cookies? 

This Section describes how long we store various types of cookies.

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How long we use cookies depends on their type and purpose. There are two main types of cookies: 

• Session Cookies - which expire at the end of the browsing session, e.g. when you leave the Website;
• Persistent Cookies – which are stored for a longer period of time on your device.

Session Cookies are used mainly to make it easier and convenient for you to use a website. Persistent Cookies are used for example for security purposes or to remember your settings and choices.

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We store our Persistent Cookies for up to 12 months. You can check how long do we store particular cookies by using our cookie management platform (click here).

19. What about personal data? 

This Section describes the relation between cookies and personal data.

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Generally speaking, in most cases information used in connection with cookies is personal data. The Privacy Policy applies accordingly when your personal data is used in connection with cookies. For example, when we use Essential Cookies the legal basis of processing is Contract Performance, and when we use Analytics Cookies the Legitimate Interests are the legal basis of processing.

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You also have the rights described in the Privacy Policy and can exercise them as regards to use of cookies in connection with personal data. To exercise your right(s) contact us (please consult Section 3 of the Privacy Policy).

20. Changes to the Cookie Notice

This section describes how we can amend this Cookie Notice.

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We reserve the right to amend this Cookie Notice. We may amend it, for example, to reflect changes to use of cookies, account for changes in applicable law or to make it more user friendly and transparent.