WebPros Privacy Policy

WebPros Privacy Policy

v.2 – Updated March 2nd, 2023

Particle Investments S.à r.l., Luxembourg (hereinafter “WebPros”), as the parent company of all affiliates and subsidiaries of the WebPros group of companies, is responsible for the operation of this group website.

This WebPros Privacy Policy is deemed to demonstrate that our visitors’, partners’ and customers’ (collectively “you” or “your”) privacy is one of WebPros’ cardinal objectives, especially when using any WebPros services or accessing this website. It sets forth the manner and legal commitments which WebPros agrees to maintain in collecting, processing and (where applicable) disclosing information about users of this website. 

By using the WebPros website, our products and/or services you agree to the practices described in this Privacy Policy.

Collection of Information

WebPros gathers information in most of its interactions with you, whether directly or indirectly. Although some of the information may be considered as “Personal Data”, most of the gathered information is not Personal Data. Personal Data is defined as information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context.

WebPros has taken extensive safety and operational precautions, including administrative, physical and technical safeguards to protect personal information. Furthermore, WebPros deploys commercially reasonable safeguards across the company databases to prevent unauthorized access, disclosure or loss of personal information.

Where information is provided to WebPros for the purpose of the establishment or maintenance of a contractual relationship, WebPros processes your data on the basis of Article 6 I b) GDPR. In all other cases, your data is processed on basis of and in accordance to your explicit consent as required by Article 6 I a) GDPR or a legitimate interest on basis of Article 6 I f) GDPR.

Information received from you directly

WebPros collects and stores information during the registration of products, the creation of online profiles, the application via our website and any contact for support or other matters (e.g. contact or comment forms, telephone contact). Examples of information transmitted by you:

  • Name, address, phone number, email address
  • IP addresses
  • Billing and other purchasing and shipping information;
  • Records of transactions, including purchases, inquiries and service requests;
  • Authentication data such as user name and password to verify access.
  • Application Data, CVs, profiles, pictures (additional Job Applicant Data Policy in place)

WebPros does not collect or process any credit card data during purchases. Any credit card purchase is made through a reliable and secure, external online payment processor (third-party controller), with the result that WebPros is never furnished with your sensitive credit card information.

In order to provide its services, its websites or fulfill its contractual obligations to you, WebPros may be required to forward data which may include some of your personal information to third parties. In order to follow the requirements of data minimization, the data so transferred is reduced to the necessary minimum. Those suppliers or subcontractors are required to adhere to a data processing agreement with WebPros under which they are committed to process data solely in accordance with the applicable laws (including the GDPR and other national privacy laws) and in accordance to WebPros instructions. This processing includes a required screening of your provided data against international export and economic sanctions lists by WebPros. A negative (no match) screening result is a mandatory requirement for WebPros to communicate with, deal with, do business with or provide any form of services to you. The WebPros “Export and Sanctions Compliance Policy” applies, accordingly.  

WebPros has an extensive data protection policy in place across its organization, which every WebPros employee or contractor must adhere to at all times. Such data protection policy sets forth the mandatory way, information is expected to be handled within WebPros and describes the necessary internal processes and the required level of confidentiality to be maintained in order to be compliant with national and international data protection laws (like e.g. GDPR).  

WebPros strives to comply with the concept of data minimization (“privacy by default”) by only collecting as much information as needed for the intended and approved purpose. Only information which is relevant to such purpose and which has been provided to WebPros in free and informed manner by you as the data subject will be processed by WebPros for as long as needed for the purpose. Thereafter, any Personal Data is subject to defined deletion routines as defined in WebPros’ record of processing activities, created and maintained in accordance to Article 30 of the GDPR.

Information Collected Automatically

WebPros may automatically collect and store information about how users utilize the WebPros website(s) and applications. This may include anonymized IP addresses of website visitors, browser type and other information such as search terms, which helps us to improve our services and our website to provide you with the best possible services and user experience. Any so collected data which may be considered as Personal Data is subject to immediate anonymization upon its collection with the result that the automatically-collected data will not allow WebPros or any other party to identify you.

Data Protection for Minors

The WebPros website as well as its contents, services and offers are not directed at children or minors. Accordingly, WebPros does not want and does not assume that any information collected on the WebPros website or any forum will be personal data pertaining to children or minors. Any data which is identified as belonging to a child or minor is subject to immediate deletion.

Is my data secure at WebPros?

WebPros has implemented appropriate technical and organizational measures related to the respective processing purpose in order to protect the Personal Data provided by you against abuse and loss. Personal Data and other information about you is stored in a secure operating environment that is not accessible to the public. 

Any data transmission performed by WebPros is encrypted during transmission via SSL. 

In addition, each of WebPros’ employees is contractually bound by comprehensive confidentiality and non-disclosure terms and is further required to abide by the WebPros data protection policy at all times.

What are my rights?

You have the following rights in respect to the Personal Data you provide to WebPros:

  • You may at any time request WebPros to delete the data you provided or withdraw any data processing consent you provided to WebPros by contacting [email protected]. 
  • You may further limit the scope of processing to certain processing activities or request a correction of your data.
  • You have the right to be informed about where, for which purpose and for how long which data is collected by WebPros. You may at all times request to receive such information in a structured, commonly-used and machine-readable format to transfer your data to another data controller.
  • In the unlikely case that WebPros may, in your reasonable discretion, not comply with the applicable data protection law, you have the right to file a complaint directed at the competent regulatory authority.

WebPros may ask you to provide a proper identification of yourself before performing any Personal Data-related action to avoid misuse. 

Is my data shared with third parties? 

In order for WebPros to execute its business processes in an optimal manner, it may be necessary for certain data to be processed by trusted 3rd parties and reliable partners. These 3rd parties may 

  • process payments
  • fulfill orders
  • send email 
  • manage communication (e.g. newsletters, security notifications, chat)
  • website hosting
  • store customer information (CRM)
  • conduct other related activities 

on behalf of WebPros. However, WebPros only shares such information needed to serve the specific purpose for which the 3rd parties were engaged. WebPros ensures that these 3rd parties are under similar obligations to maintain privacy and confidentiality as WebPros’ own employees are and that they will handle your information in the way and to the extend as WebPros itself is permitted to. WebPros does not allow any 3rd party to use your information for any purposes for which the information was not collected.

WebPros will only disclose your Personal Data abroad, if it is necessary for the intended purpose of processing. However, as a member of the worldwide WebPros group of companies, local WebPros entities may maintain or perform data processing operations in countries in- or outside the EEA or in countries without an adequate level of data protection, if it is required for the fulfillment of our obligations or the underlying agreement with you. Furthermore, subcontractors of WebPros which WebPros engages to act on its behalf in respect to the processing of your Personal Data may be domiciled in such areas. 

In order to secure such transfer and processing in accordance to chapter 5 of the GDPR, WebPros has implemented and requests the required technical and organizational measures as well as has entered into the appropriate contractual frameworks with group companies and subcontractors which make sure that the recipient of data has implemented an adequate level of data privacy in its organization as required by the GDPR. This includes signature of Data Processing Agreements as well as EU Standard Contractual Clauses (EUSCCs) issued by the EU commission. These precautions are appropriate safeguards as requested by Article 46 GDPR and local data protection laws in effect, which make sure that your information will be treated securely, confidentially and in accordance to the applicable data protection laws. 

Does WebPros sell my information? 

No – WebPros does not sell your information to third parties for any commercial or non-commercial interest (a traditional “sale”). However, the term “sale” may in some jurisdictions also comprise providing data to third parties to process payment for services, and, if chosen by you, the provision of your personal information to entities, whose products WebPros resells. If you opt out of the sale of your information by contacting [email protected] or clicking the link on the corresponding WebPros website, WebPros may be unable to provide services to you if your request not to sell information includes a prohibition on processing payments for the products you purchase in your jurisdiction.    

How long will my data be stored?

WebPros only maintains your Personal Data for as long as it is required for the intended and approved purpose. Data which is collected on basis of your explicit consent will be retained until such consent will be withdrawn or expires. Some data (e.g. billing related data) may be subject to statutory data retention obligations, which WebPros adheres to. Product trial licenses are tied to email addresses. For fraud protection purposes, such addresses are subject to an extended retention term after license expiration. As soon as your Personal Data is no longer needed to serve the purpose of its collection and no other retention policies apply, WebPros has implemented revolving routines to delete your data. WebPros employs data destruction techniques designed to completely destroy data and prevent any future recovery in all such routines.

Cookies 

A cookie is a piece of data stored on your computer, tied to information about you. WebPros may use all kinds of cookies. This may either include cookies which terminate and erase once you close your browser or log out, or cookies stored on your computer for an extended timeframe.

During your first visit on the WebPros website, you will be asked to confirm the cookie categories you agree to be set. At the same time you will be provided with detailed information about the respective cookies. 

WebPros has furthermore established a comprehensive “Cookie Statement”, describing the different kinds of cookies used on the WebPros website, the purpose of their use as well as ways to avoid cookies by way of editing your browser preferences or actively performing opt-out actions. The WebPros Cookie Statement can be found here.

Other Technologies (incl. Third-Party Providers)

When providing its services and websites to you, WebPros makes use of different other technologies including third party providers. Such third party providers may be located inside and outside the European Economic Area and are contractually bound to adhere to European privacy standards by Data Processing Agreements and, where necessary, EU Standard Contractual Clauses. The following technologies and third party providers are used by WebPros:

Zendesk

Zendesk provides software-as-a-service products related to customer support, sales, and other customer communications and is provided by Zendesk, Inc., 989 Market Street, San Francisco, California 94103 / USA. The services provided by Zendesk help us manage support inquiries and our knowledgebase. We use Zendesk services in accordance to Art. 6 Abs. 1 lit. b) and f) GDPR to either properly provide our contractually owed support services to customers (performance of a contract) or to efficiently provide our knowledgebase to visitors and customers (legitimate interest). If used for support management, Personal Data elements like names and email addresses are processed by Zendesk on our behalf to provide support services to you. Please note that US authorities may possibly gain access to personal data processed, based on US surveillance laws like the Cloud Act. The applicable Zendesk privacy notice can be found here. 

Google Tag Manager

Google Tag Manager is a tag management service provided by Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland as well as Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA that helps us to manage the tags or scripts needed on our website in a centralized fashion. In order to function properly, Google Tag Manager uses visitor IPs to provide its results, which means personal information about visitors may be processed by Google in the course of using our website. Further information with regards to Google Tag Manager can be found in the Google privacy policy, which can be found here. 

Please note that US authorities may possibly gain access to personal data processed, based on US surveillance laws like the Cloud Act. This might include IP addresses, processed by Google after consent is provided for Google Tag Manager. 

Google Analytics

Our websites use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland as well as Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics provides us with vital insights on how visitors find our websites, what they do when they are there, and other important information on the health of our websites and business. The services are provided on the basis of Google’s Privacy Policy, which can be found here.

Please note that US authorities may possibly gain access to personal data processed, based on US surveillance laws like the Cloud Act. This might include IP addresses, processed by Google after consent is provided for Google Tag Manager.

If you do not wish to be tracked by Google Analytics on our behalf, you always have the option to opt-out from being tracked via our consent management system (cookie solution).

HubSpot

HubSpot (HubSpot, Inc., 25 First Street, Cambridge, MA 02141 / USA) is a platform for marketing, sales and service management for websites. We use Hubspot (incl. certain CRM-features of it) for marketing automation and as a central tool to manage our customer-facing communication (e.g. contact forms, email campaigns etc.). To use these functionalities, To properly provide its services, HubSpot processes your name, email address and other personal data you provided to us and/or via our website on our behalf. We use HubSpot services in accordance to Art. 6 Abs. 1 lit. f) GDPR to properly and efficiently manage our marketing as well as in/outbound customer communication on basis of legitimate interest. The HubSpot privacy policy can be found here.

Please note that US authorities may possibly gain access to personal data processed, based on US surveillance laws like the Cloud Act.

CloudFlare

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc, 101 Townsend Street, San Francisco, California / USA. We use Cloudflare to provision our websites in a timely and professional fashion to visitors. When being in use, Cloudflare may place cookies on visitor devices for certain analytical and performance related functions. We use Cloudflare services in accordance to Art. 6 Abs. 1 lit. f) GDPR to provision and increase the performance of our websites on basis of legitimate interest.The Cloudflare privacy policy can be found here. Please note that US authorities may possibly gain access to personal data processed, based on US surveillance laws like the Cloud Act.

Links to 3rd Parties

This Privacy Policy applies only to WebPros websites and not to websites owned by 3rd parties. The WebPros websites may contain links to websites of certain 3rd Parties (suppliers, 3rd party ISVs, etc.). Although WebPros pays particular attention to the contents of linked websites and the quality of the links posted on its website, WebPros neither has any influence on the contents of these 3rd parties’ websites, nor on the way, these 3rd parties treat personal information collected on their own websites. 

Accordingly, WebPros disclaims any responsibility and liability for actions of any 3rd parties or the observance of data protection regulations by 3rd parties, linked to from WebPros websites. In the event you envisage any shortcomings or breaches of data protection regulations by one of the 3rd parties linked on WebPros websites, please immediately contact WebPros per the address below to allow WebPros to take the appropriate actions to stop this misbehavior.

 

Contact

If you have questions about this WebPros Privacy Policy and the procedures in effect, please contact our Data Privacy Officer at [email protected] .

Responsible party: Particle Investments S.à r.l., 14 Rue Robert Stümper, 2557 Luxembourg.

Version: v.2 (issued 27.02.2023)

This policy is subject to periodic revisions and may be amended by WebPros from time to time if necessary. Please come back periodically and check for updates.