Privacy Policy of www.thegreyicon.com

This Website collects some Personal Data from its Users.



This document can be printed for reference by using the print command in the settings of any browser.

Owner and Data Controller

Aviva Elias T/A The Grey Icon
3 Nicoll Place
London
NW4 3PD

Owner contact email: contact@thegreyicon.com

Types of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Trackers; Usage Data; first name; last name; phone number; email address; various types of Data; payment info; billing address; purchase history; number of Users; city; device information; session statistics; latitude (of city); longitude (of city); browser information.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through this Website.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Backup saving and management, Contacting the User, Data transfer outside of the UK, Displaying content from external platforms, Handling payments, Infrastructure monitoring, Managing contacts and sending messages, Traffic optimisation and distribution and Tag Management.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

  • Analytics

    The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

    Analytics collected directly (this Website)

    This Website uses an internal analytics system that does not involve third parties.

    Personal Data processed: Trackers; Usage Data.

    Google Analytics (Universal Analytics) (Google Ireland Limited)

    Google Analytics (Universal Analytics) is a web analysis service provided by Google Ireland Limited (“Google”). Google utilises the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualise and personalise the ads of its own advertising network.

    In order to understand Google's use of Data, consult Google's partner policy.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Ireland – Privacy Policy – Opt Out.

    Google Analytics 4 (Google Ireland Limited)

    Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
    In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.

    In order to understand Google's use of Data, consult Google's partner policy.

    Personal Data processed: browser information; city; device information; latitude (of city); longitude (of city); number of Users; session statistics; Trackers; Usage Data.

    Place of processing: Ireland – Privacy Policy – Opt Out.

    Google Analytics (Universal Analytics) with anonymised IP (Google Ireland Limited)

    Google Analytics (Universal Analytics) is a web analysis service provided by Google Ireland Limited (“Google”). Google utilises the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualise and personalise the ads of its own advertising network.
    This integration of Google Analytics anonymises your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.

    In order to understand Google's use of Data, consult Google's partner policy.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Ireland – Privacy Policy – Opt Out.

  • Backup saving and management

    This type of service allows the Owner to save and manage backups of this Website on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to this Website.

    Backup on Google Drive (Google Ireland Limited)

    Google Drive is a service to save and manage backups provided by Google Ireland Limited.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: Ireland – Privacy Policy.

    Backup on Wasabi

    This Privacy Policy (the “Policy”) describes how the Wasabi group of companies (for more details, see “Contact Information” below) (“Wasabi,” “we,” “our” or “us”) collect, use, and share information in connection with your use of our websites (the “Sites”), as well as any products, services, and/or applications available on or through the Sites (collectively, the “Services”). However, this Policy does not apply to information customers or users (“users”, “you,” or “your”) may process when using our Services.

    The information we collect includes “personal data,” which is any information about an identifiable individual, as further set forth in this Policy. Wasabi is the sole owner of the information collected on the Sites or through your use of the Services. We will not sell, share, or rent this information to others in ways different from what is disclosed in this Policy.

    Further, Wasabi respects your privacy and is committed to protecting your personal data in line with the General Data Protection Regulation – Regulation (EU) 2016/679 (“GDPR”). This Policy will inform you as to how we will look after your personal data when you interact with us, including visiting our Sites. It also tells you about your rights in relation to your personal data.
    We recommend that you read this Policy in full to ensure you are fully informed regarding our privacy practices. If you have any questions about this Policy or Wasabi’s data collection, use, and disclosure practices, please contact us at privacy@wasabi.com.

    A. Information We May Collect – We may collect and receive information about users of our Sites or Services from various sources, including: (i) information you provide through your user account on the Services (your “Account”) if you register for the Services; (ii) your use of the Sites or Services; and (iii) from third-party websites, services, and partners. You can use some of the features of the Sites or Services without registering, thereby limiting the type of information that we collect.

    1. Information You Provide

    (i) Account Registration or Contact Information. When you register for an Account, the information we may collect from you includes your name, mailing address, email address, phone number, and past purchases (collectively, “Contact Information”). Wasabi also allows you to voluntarily provide us with Contact Information through our Sites when requesting further information, or when signing up for newsletters or other contact from us.

    (ii) Payment Information. When you add your payment information (including any credit card information) to your Account, that information is directed to our third-party payment processor. We do not store any of your payment or credit card information on our systems; however, we have access to, and may retain, subscriber information through our third-party payment processor.

    (iii) Communications. If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. We may also receive a confirmation when you open an email from us.

    Further, if you have requested information or if you have purchased Services from us in the past, or you have downloaded or accessed any demonstrations or training with respect to the Wasabi and/or the Services, we may use this information to provide you with news, offers for upgrades, discounts and other marketing information. If you do not wish to receive such marketing communications from us, you can opt-out or “unsubscribe”) in the manner designated in the marketing communication or by contacting us at privacy@wasabi.com. However, please note that even if you opt-out or unsubscribe, we may still contact you for informational, transactional, account-related, or similar purposes.

    (iv) Forum Use. If you use a blog, bulletin board or similar means of communication on or through our Sites, you should be aware that any data you submit there can be read, collected, or used by other users of these forums. We use industry standard measures, including administrative, technical, and physical safeguards, to help protect personal data from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. However, no data transmission over the Internet can be guaranteed to be entirely secure. As a result, while we always use all reasonable efforts to protect your personal data, we cannot guarantee the security of your information and the submission of data is at your own risk.

    (v) Surveys and Responsive Requests. From time to time, we may use your Contact Information to request information from you via surveys or similar responsive requests. Participation in these surveys or responsive requests is completely voluntary and you have a choice whether or not to disclose any information requested. Information requested may include contact information (such as name, email and address), and demographic information (such as zip code, age level, education, etc.). If you give us personal information about somebody else, such as a spouse or work colleague, we will assume that you have their permission to do so. Survey information may be used to monitor or improve the use and satisfaction of the Sites or the Services.

    2. Information Collected Through Use of the Sites or Services

    (i) Cookies and Other Tracking Technologies. We use different kinds of cookies on our website in order to provide you the best online experience, which are stored by your browser for record-keeping purposes. In order to collect this information, a cookie may be set on your computer or device when you visit our Sites or use the Services. Further, third-party vendors (such as AdRoll and Google) may use the cookie information about your prior visits to the Sites in order to place targeted Wasabi advertisements on other sites you visit.

    You may choose to set your web browser to refuse cookies. A user who does not accept cookies from our Sites may not be able to access certain areas of the Sites. Many browsers have an option for disabling cookies, which may prevent your browser from accepting new cookies or enable selective use of cookies. Please note that, if you choose not to accept cookies, some features and the personalization of our Sites or Services may no longer work for you. You will continue to receive advertising material but it will not be tailored to your interests.

    Cookies contain a small amount of information that allows our web servers to recognize you. Through the use of cookie technology or otherwise, we may track and collect information about your computer and software when you visit the Sites or use Services. This information may include, but is not limited to, internet protocol (IP) addresses, browser type and language, internet service provider (ISP), referring/exit pages, type of computer, operating system, date/time stamp (as well as pages viewed and how long you spend on a page), clickstream data, landing page, and referring URLs, (ix) other information about your use of and actions on our Sites, including use of features of the Sites or the Services, about the functionality of our the Sites or the Services, and frequency of visits (all of the foregoing collectively referred to as “Traffic Data”). Traffic Data is anonymized and does not personally identify you. We also use Traffic Data assists us to design, arrange and improve our Sites.

    We may also use web beacons (small pieces of data that are embedded in images on the pages of websites) and auditing software to track page views and entry and exit points to and from our Sites. In addition, we may use web beacons, cookies, customized links and/or similar technologies to determine whether electronic newsletters sent by us to those who have requested them from us have been opened and which links are clicked. Any data collected will only be used in an aggregate and anonymized form.

    (ii) Use of the Services. When you use our Services, we may collect information about your engagement with and utilization of our Services, such as processor and memory usage, storage capacity, navigation of our Services, and system-level metrics. We use this data to operate the Services, maintain and improve the performance and utilization of the Services, develop new features, protect the security and safety of our Services and our customers, and provide customer support. We also use this data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business.

    (iii) Use of Contractors. We may use contractors outside the United States to provide technical support for the Service, to complement the resources provided by our U.S. based technical support staff. All technical support staff, whether U.S. or non-U.S. based, may need to access customer-specific information (excluding the content of your files) for problem troubleshooting.

    3. Information We Receive from Third Parties

    (i) Third-Party Accounts. If you choose to link our Services to a third-party account, we will receive information about that account, such as your authentication token from the third-party account, to authorize linking. If you wish to limit the information available to us, you should visit the privacy settings of your third-party accounts to learn about your options.

    (ii) Other Resources. We, for marketing or research purposes, may also receive contact details or other information about you from publicly and commercially available sources, which we may combine with other information we receive from or about you. We will use the information we collect from third party sources in accordance with this Policy.

    B. Retention of Data – We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

    In some circumstances you can ask us to delete your data, see this section below for further information: https://wasabi.com/legal/customer-agreement/#yourrights. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

    C. Data Integrity and Security – We use industry standard security measures to protect against the loss, misuse and/or alteration of data located on our systems. We implement appropriate measures and processes, such as using encryption when transmitting certain sensitive information, to help us to keep your information secure and to maintain its quality. We regularly review our security and related policies to adapt the technology as new threats evolve, and in order to monitor our systems to help ensure the highest level of availability of our Sites and Services. If you have any questions about the security of our Sites or Services, you can contact Wasabi at privacy@wasabi.com.

    D. Access – If you are a registered user of the Services, or you otherwise have an Account, you may access certain information associated with your Account by logging into our Services or emailing privacy@wasabi.com. If you terminate your Account, any public activity on your Account prior to deletion may remain stored on our servers and may remain accessible to the public.

    To protect your privacy and security, we may take reasonable steps to verify your identity before updating or removing your information. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business for disaster recovery purposes. Your ability to access and correct your information may be temporarily limited where access and correction could: inhibit Wasabi’s ability to comply with a legal obligation; inhibit Wasabi’s ability to investigate, make or defend legal claims; result in disclosure of personal information about a third party; or result in breach of a contract or disclosure of trade secrets or other proprietary business information belonging to Wasabi or a third party.

    E. Lawful Grounds For Using and Processing Your Personal Data – We will normally collect personal data from you only (i) where we need the personal data to perform our obligations; (ii) where the processing is in our legitimate interests and not overridden by your rights; or (iii) where we have your consent to do so. We use the information we collect in various ways, including to:

    Provide, operate, and maintain our Services;
    Improve, personalize, and expand our Services;
    Understand and analyze how you use our Services;
    Develop new products, services, features, and functionality;
    To inform our marketing strategy, including to define customers for our products and services
    Keep our records up to date;
    Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the Service, and for marketing and promotional purposes;
    Process your transactions;
    Send you text messages and push notifications;
    Find and prevent fraud; and
    For compliance purposes, including enforcing our Terms of Service, or other legal rights, or as may be required in (a) the event of an emergency, (b) by applicable laws and regulations, (c) for the protection and safety of our employees and agents, our customers, or any other person or (d) requested by any judicial process or governmental agency.
    F. How We Share Information – We may share the information we collect in various ways, including the following:

    Third Party Service Providers. We may share information with third-party service providers that provide services on our behalf, such as helping to provide our Sites and/or Services (such as website analytics, email delivery, marketing/advertising and legal and other professional advice), and to provide you with information relevant to you such as product announcements, software updates, special offers, or other information. We also share information with third-party partners in order to receive additional publicly available information about you. However, we do not permit third party service providers to use your personal data for any other purposes, and only permit them to access and process your personal data for specified purposes and in accordance with our instructions.
    Analytics. We also analyze the data through the use of third-party analytics providers, such as Google Analytics. Analytics providers use cookies to collect non-identifying information of users and visitors to our Sites. For more information on Google privacy options regarding its Analytics cookies, see http://www.google.com/policies/privacy/partners/. For a current list of the entities that may process data for or on behalf of Wasabi, see http://www.wasabi.com/legal/sub-processors.
    Business Transfers. Information may be disclosed and otherwise transferred to any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
    Advertising. We work with third-party advertising partners to show you ads that we think may interest you. These advertising partners may set and access their own cookies, pixel tags, and similar technologies on our Sites and/or Services, and they may otherwise collect or have access to information about you which they may collect over time and across different online services. Some of our advertising partners are members of the Network Advertising Initiative or the Digital Advertising Alliance. To learn more about these programs, or opt-out of personalized ads, visit the Digital Advertising Alliance’s Self-Regulatory program for Online Behavioral Advertising at www.aboutads.info, or the Network Advertising Initiative at www.networkadvertising.org.
    Information Received Through a Referral. If you sign up for our Services through a referral, we may share information with the referrer to let them know that you used the referral to sign up for our Services.
    Aggregate information. Where legally permissible, we may use and share information about users with our partners in aggregated or de-identified form that cannot reasonably be used to identify you.
    Under Law. We may also share information to (i) satisfy any applicable law, regulation, legal process, or governmental request; (ii) enforce this Policy and our Terms of Service, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
    G. Third Party Links – You may access other third-party services through the Sites or Services, for example by clicking on links to those third-party services from within the Sites Services. We are not responsible for the privacy policies and/or practices of these third-party services, and we encourage you to carefully review their privacy policies.

    H. International Transfers – Wasabi has offices and provides Services both within and without the United States. This means that your personal data could be transferred out of the European Economic Area (the “EEA”), Switzerland or the United Kingdom “UK”. Whenever we transfer your personal data out of your jurisdiction, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

    We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
    Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
    Where we use providers based in the US, 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 the European Economic Area, the UK, Switzerland and the US.
    Please contact us https://wasabi.com/legal/privacy-policy/#contact if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

    I. Your Rights under the General Data Protection Regulation (“GDPR”) – Under certain circumstances, you have rights under data protection laws in relation to your personal data. We have explained your rights below; if you wish to exercise any of your rights, please contact us at privacy@wasabi.com. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. You have the right to:

    access, correct, update, or request deletion of your personal information (note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request).
    object to the processing of your personal information. You may ask us to restrict the processing of your personal information, or request portability of your personal information (however, in some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms).
    request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
    request the transfer of your personal data to you or to a third party. 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.
    opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you.
    withdraw your consent at any time for any personal data we have collected and processed with your consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
    complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, the UK, Switzerland and certain non-European countries (including the US and Canada) are available here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. If your complaint involves a GDPR issue, please do not refer it to BBB EU Privacy Shield (see below).
    No Fee Usually Required
    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    What We May Need From You
    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.

    J. Children’s Privacy – The Children’s Online Privacy Protection Act restricts the collection and use of personal data pertaining to children under the age of 13. We do not allow such children to register as users and will not knowingly collect or solicit personal data from anyone under the age of 13. No one under the age of 13 should provide any personal data on or through the Sites or otherwise. In the event we learn that we have collected personal data from a child under age 13, we will terminate the any Account and all communications, and delete such information. If you believe that we might have any information from or about a child under 13, please contact us at privacy@wasabi.com. Minors aged 13 and over should not use this site or post any information or other content without adult supervision.

    K. Acceptance of and Changes to This Privacy Policy – By using the Sites and Services, you consent to the collection, use and storage of your information by us in the manner described in this Policy. This Policy may be modified from time to time, so please review it frequently. Changes to this Policy will be posted on our websites. If we materially change the ways in which we use or share personal information previously collected from you through the Sites or Services, we will notify you through the Sites, Services, by email, or other communication.

    If you do not agree with this Policy, please do not use the Sites or Services. Your continued use of the Sites and/or Services following posting of changes to these terms will mean you accept those changes.

    L. California Notices – Users who reside in California and have provided personal data to us have the right to receive: (a) information identifying any third party to whom we may have disclosed, within the past year, personal data pertaining to you and your family for that party’s direct marketing purposes; and (b) a description of the categories of personal data disclosed. To obtain such information, please email your request to privacy@wasabi.com. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.

    M. Privacy Shield For EEA, UK & Swiss Individuals Whose Data Is Transferred Into The United States – Wasabi Technologies, Inc. complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries, the UK and Switzerland transferred to the United States pursuant to Privacy Shield. Wasabi Technologies, Inc. has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

    The Federal Trade Commission has jurisdiction with enforcement authority over Wasabi Technologies Inc.’s compliance with the Privacy Shield.

    In compliance with the Privacy Shield Frameworks, Wasabi Technologies, Inc. attests to the following Principles while personal data is in the United States:

    EEA, UK and Swiss individuals have the right to access their personal data and to correct, amend or erase information that is inaccurate or has been processed in violation of the Principles. Individuals wishing to exercise this right may do so by logging into our services or emailing privacy@wasabi.com
    You may opt-out of marketing communications and you can exercise this right by clicking on the “unsubscribe” or “opt-out” link on the emails we send you. We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than that which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@wasabi.com.
    We remain liable for the onward transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.
    We may be required to release personal data in response to lawful requests from public authorities including to meet national security and law enforcement requirements.
    In compliance with the Privacy Shield Principles, Wasabi Technologies, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact Wasabi at:
    privacy@wasabi.com
    Wasabi Technologies, Inc.
    111 Huntington Avenue
    Suite 2900
    Boston, MA 02199

    Wasabi Technologies has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/bbb-eu-privacy-shield-consumers/ProcessForConsumers. This service is provided free of charge to you.

    If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

    N. Important Information For California Residents –

    (a) Scope. This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents when we act as a “business” as defined under the California Consumer Privacy Act of 2018 (“CCPA”), and their rights with respect to their Personal Information. For purposes of this section, “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA or information we collect from you in the course of providing services to you or receiving services from you where you are an employee, controlling owner, director, officer or contractor of a company, partnership, sole proprietorship, non-profit or government agency. In some cases, we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.

    Your California Privacy Rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
    Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
    The categories of Personal Information that we have collected.
    The categories of sources from which we collected Personal Information.
    The business or commercial purpose for collecting and/or selling Personal Information.
    The categories of third parties with whom we share Personal Information.
    Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information disclosed to each category of third party recipient.
    Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
    Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
    Deletion. You can ask us to delete the Personal Information that we have collected from you.
    Opt-out of Sales. If we sell your Personal Information, you can opt-out. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
    Opt-in. If we know that you are younger than 16 years old, we will ask for your permission (or if you are younger than 13 years old, your parent’s or guardian’s permission) to sell your Personal Information before we do so.
    Nondiscrimination. You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Service.
    (b) How To Exercise Your Rights. You may exercise your California privacy rights described above as follows:

    Right to Information, Access and Deletion. You may exercise your right to information, access or deletion by contacting us at privacy@wasabi.com
    Right to Opt-out of the “sale” of Your Personal Information. Like many companies, we use services that help deliver interest-based ads to you. Our use of some of these services may be classified under California law as a “sale” of your Personal Information to the companies that provide the services because they collect information from our users (e.g., device data and online activity data) to help them serve ads more likely to interest you. You can request to opt-out out of this “sale” of your personal information here: http://www.wasabi.com/privacy-policy/#changeConsent.
    We reserve the right to confirm your California residency to process your requests and will need to confirm your identity to process your requests to exercise these rights. Government identification may be required. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

    (c) Personal Information That We Collect, Use and Disclose. – The categories and sources of Personal Information we collect, the business/commercial purposes for which we use these categories of Personal Information, and the categories of third parties to which we disclose these categories of Personal Information for business purposes are set forth above.

    O. Contact Information – If you have any questions or concerns about this Privacy Policy, please feel free to email us at privacy@wasabi.com, or at the following addresses:

    Wasabi Technologies, Inc.
    111 Huntington Avenue
    Suite 2900
    Boston, MA 02199 Wasabi Technologies B.V. (Registration number 73934011)
    Kingsfordweg 151
    1043 GR Amsterdam
    The Netherlands

  • Contacting the User

    Contact form (this Website)

    By filling in the contact form with their Data, the User authorises this Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

    Personal Data processed: email address; first name; last name; phone number.

  • Displaying content from external platforms

    This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
    This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

    Font Awesome (Fonticons, Inc. )

    Font Awesome is a typeface visualisation service provided by Fonticons, Inc. that allows this Website to incorporate content of this kind on its pages.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: United States – Privacy Policy.

    Google Fonts (Google Ireland Limited)

    Google Fonts is a typeface visualisation service provided by Google Ireland Limited that allows this Website to incorporate content of this kind on its pages.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Ireland – Privacy Policy.

  • Handling payments

    Unless otherwise specified, this Website processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Website isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

    Stripe (Stripe Payments Ltd)

    Stripe is a payment service provided by Stripe Payments Ltd.

    Personal Data processed: billing address; email address; first name; last name; payment info; purchase history; Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.

    Place of processing: United Kingdom – Privacy Policy.

  • Infrastructure monitoring

    This type of service allows this Website to monitor the use and behaviour of its components so its performance, operation, maintenance and troubleshooting can be improved.
    Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Website.

    Uptime Robot (Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.)

    Uptime Robot is a monitoring service provided by Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: Turkey – Privacy Policy.

  • Managing contacts and sending messages

    This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
    These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

    MailerLite (UAB "Mailerlite")

    MailerLite is an email address management and message sending service provided by UAB "Mailerlite".

    Personal Data processed: email address; first name; last name.

    Place of processing: Lithuania – Privacy Policy.

  • Tag Management

    This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralised fashion.
    This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

    Google Tag Manager (Google Ireland Limited)

    Google Tag Manager is a tag management service provided by Google Ireland Limited.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Ireland – Privacy Policy.

  • Traffic optimisation and distribution

    This type of service allows this Website to distribute their content using servers located across different countries and to optimise their performance.
    Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Website and the User's browser.
    Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

    Cloudflare (Cloudflare Inc.)

    Cloudflare is a traffic optimisation and distribution service provided by Cloudflare Inc.
    The way Cloudflare is integrated means that it filters all the traffic through this Website, i.e., communication between this Website and the User's browser, while also allowing analytical data from this Website to be collected.

    Personal Data processed: Trackers; various types of Data as specified in the privacy policy of the service.

    Place of processing: United States – Privacy Policy.

Cookie Policy

This Website uses Trackers. To learn more, Users may consult the Cookie Policy.

Further Information for Users

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes.
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Further information about retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The rights of Users based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following, to the extent permitted by law:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or enquire with the Owner using the information provided in the contact section.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

Transfer of Personal Data outside of the United Kingdom

Data transfer abroad based on consent (UK)

If this is the legal basis, Personal Data of Users shall be transferred from the UK to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.

In such cases, the Owner shall inform Users appropriately and collect their explicit consent via this Website.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilised by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using this Website who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.

This Website (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Website as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.


Legal information

This privacy policy relates solely to this Website, if not stated otherwise within this document.

Latest update: 27 October 2022

This document has been created with the iubenda Privacy and Cookie Policy Generator. See also the Terms and Conditions Generator. iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided.

Show the simplified Privacy Policy