This policy applies to Global Performance Commerce Limited Inc. (“WowSuite” or the "Company"), including all related websites, products, and services. For European Union residents, this policy also follows the requirements of the European General Data Protection Regulation (GDPR). For California residents, this policy likewise follows the requirements of the California Consumer Privacy Act (CCPA).
I. Your Agreement
A. When you use our site, you agree to let us handle your personal data as described in this policy.
B. This policy applies to WowSuite, our websites, products, and services.
C. If you live in the European Union, this policy also explains how we meet GDPR requirements.
D. If you live in California, this policy also explains how we meet CCPA requirements in Section XXII. CCPA Data Processing.
II. How We Use Your Information
A. We collect your personal data in different ways and for various reasons, such as:
- When you buy something from us, we collect your name, address, phone number, and/or email address.
- When you visit our site, we automatically receive your computer's IP address to help us learn about your browser and operating system.
B. Email marketing (when legally allowed):
If you give us permission and it's allowed in your location, we may send you emails about our site, new products and services, and other updates. Permission is your clear and verifiable agreement, which can happen in situations like:
- Sharing your email address on our site without making a purchase or indicating you don't want to receive emails.
- Providing your email address when ordering or attempting to order a product or service, even if unsuccessful, without indicating you don't want to receive emails.
- Entering your email address when leaving items in your cart, without indicating you don't want to receive emails.
- When you communicate with any of our staff, without indicating you don't want to receive emails.
- Giving your email address during contests, events, or surveys after we've informed you we'll send marketing emails.
- Subscribing to our email newsletter through a form on our site.
- Filling out a form and checking an opt-in box (unchecked by default) to get emails after we've told you the emails will be commercial.
C. Opting out of marketing emails:
- All marketing emails will clearly show that you can opt out of receiving more marketing emails from us at no cost.
- All marketing emails will have a one-click unsubscribe or opt-out option.
- Once you opt out or unsubscribe, we will stop sending marketing emails to you immediately.
D. How we use your personal information:
We may use your personal information, such as your name, address, phone number, email address, and other relevant data, to run our business, improve our site, create new products and services, provide information and support, understand your needs and interests, personalize communications and advertising, fulfill contractual obligations, and generally offer a quality experience for you. For example, we may use your personal information, including your email address, to:
- Communicate, interact, and build our relationship with you.
- Customize content, products, and services for you.
- Contact you with information about us and affiliated third parties.
- Process, fulfill, and follow up on transactions and requests for products, services, support, and information.
- Show recent purchases on our website through pop-ups.
- Verify your authority to use our services.
- Confirm purchases and rewards for referrals.
- Conduct market research and analysis.
- Improve our products, services, website effectiveness, and marketing.
- Comply with legal requirements.
- Provide targeted advertising, including re-targeting technology.
- Send marketing materials, such as newsletters, to inform you about products and services we think you'd like.
- Prevent fraud and other prohibited or illegal activities.
E. Managing email preferences:
To stop receiving marketing and non-transactional emails, click the "unsubscribe" link at the bottom of those emails. If you decide not to receive our emails or newsletters, you can opt-out by emailing us at firstname.lastname@example.org
F. Telemarketing (when legally allowed):
By providing us your phone number, you give us permission to contact you with information about our products and services. This means we may contact you by email, phone, text message, social networks, or other communication methods your device can receive, even if your number is on the Do-Not-Call Registry or a local Do-Not-Call list. Examples of giving permission for telemarketing include:
- Providing your email address on our site without making a purchase and without indicating you don't want to be contacted.
- Providing your email address while trying to order or ordering a product or service, even if the purchase isn't successful, without indicating you don't want to be contacted.
- Entering your email address when leaving items in your cart, without indicating you don't want to be contacted.
- Providing your email address while participating in contests, events, or surveys, after we've told you we'll contact you.
- Subscribing to our email newsletter through a form on our site.
- Completing a form and checking an opt-in box (which is unchecked by default) to be contacted, after we've informed you the contact will be commercial in nature.
G. Opting out of telemarketing:
You don't need to agree to our telemarketing efforts to buy goods or services from us. If you don't want to receive marketing calls, let us know by emailing us at email@example.com
. We'll honor opt-out requests immediately.
H. Limitations on opting out:
You might not be able to opt out of all information sharing, such as sharing with credit card processors for orders you place with us. Choices you make about marketing communications won't affect transactional, relationship, or legally required communications.
I. Legal disclosure of personal information:
We may disclose your personal information to law enforcement or other government officials if necessary to comply with the law or at their request.
K. Confidentiality and security:
We treat all information on our site as confidential. It is stored securely and accessed only by authorized personnel. We take appropriate measures to protect personal data from unauthorized use, loss, destruction, damage, theft, or disclosure.
L. Consent for personal information:
How we obtain your consent:
When you give us personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery, or return a purchase, you're consenting to our collection and use of that information for that specific purpose.
If we need your personal information for another reason, like marketing, we'll ask for your direct consent or give you a chance to say no.
Withdrawing your consent:
If you change your mind after giving consent, you can withdraw it at any time by contacting us at email address firstname.lastname@example.org
Keep in mind that withdrawing consent won't affect information sharing you can't opt out of, such as sharing with credit card processors for orders you place with us. Choices you make about information sharing won't affect transactional, relationship, or legally required communications. For some services, collection and use of your personal data might be necessary for the service to work.
M. Circumstances without separate consent:
- When fulfilling our contractual obligations to you;
- To comply with laws, regulations, court orders, or other legal obligations, or to assist in investigations; or
- For legitimate interests, such as operating our business and providing services, except when overridden by your interests or fundamental rights and freedoms that require personal data protection.
N. Managing and Deleting your Personal Data:
You can request to edit, update, access, or delete your information by emailing us at email@example.com
. Within 30 days of receiving your request, we will delete your Personal Data from our records and comply with any instructions regarding the deletion of remaining Personal Data. We won't retain data longer than necessary for its intended purpose or as required by law.
- Requesting a copy of your Personal Data: You may request a free, electronic copy of your Personal Data. We will provide it in a commonly used and machine-readable format, allowing you to transfer it to another company.
- Deletion of Personal Data: We will delete your Personal Data within 30 days if any of the following occurs:
a. The data is no longer needed for its original purpose or a legitimate business purpose;
b. It's no longer necessary to provide our services;
c. Your account with us is deleted;
d. The platform used for our services requests deletion for your protection; or
e. We must comply with a legal ruling or obligation.
III. Personal Data Disclosure
- Affiliates and Partners: We may share your data with companies or ventures we own or control, and internally within our company, to provide and improve services, for marketing purposes, and for advertising.
- Service Providers and Vendors: We may share your data with business partners, marketing partners, and vendors to provide, improve, and personalize our services.
- Advertising and Marketing: With your consent, we may share your data with advertising and marketing partners for advertising and marketing purposes on our behalf and on behalf of third parties, including social network providers, if any.
- Analytics and Improvement: We may share your data with certain companies for analytics and improvement of our services.
IV. Cookies and Third-Party Services
A. Cookies: We may use "cookies" to enhance your online experience, making it easier for you to navigate through our website and improving certain features. Cookies are text files that websites often place on a user's hard drive when the user visits the website. These files identify a user's computer and can record preferences and other data about the user's website visit. We don't extract information about individual users during this process. You may be able to disable cookies through your web browser, but please note that some services may not function properly without them, and your experience on our website could be affected.
B. Third-Party Cookies: We may work with third-party advertising companies that serve ads on our behalf across the internet. These companies may collect and use information about your visits to our website and other websites, as well as your interaction with our products and services. They do this to provide you with advertisements about goods and services that may interest you. However, no personally identifiable information (like your name, address, email, or phone number) will be connected to this information. They may use information about your visits to this and other websites to target ads and track user responses. These targeted ads may appear on our website or other sites you visit. Anonymous information is collected using pixel tags or cookies, which are standard technologies used by most major websites. If you don't want these companies to collect this information, you can opt out.
To learn more about the use of this information or to opt out from certain third-party advertising partners, please visit the Network Advertising Initiative at http://www.networkadvertising.org/choices
. Note that if you delete your cookies, use a different browser, or buy a new computer, you'll need to renew your opt-out choice.
C. Third-Party Services: Generally, the third-party providers we use will only collect, use, and disclose your information as necessary to perform specific services they provide to us. Some third-party services, like payment gateways and transaction/payment processors, must comply with security standards, such as the Payment Card Industry Data Security Standard (PCI-DSS). PCI-DSS is a set of security standards designed to ensure that all payment processors handling credit card information maintain a secure environment. All direct payment gateways we use adhere to PCI-DSS.
While we don't store your credit card information, payment gateways and transaction/payment processors may store your purchase transaction data as required by law. These third parties have their own privacy policies about how they handle your personal information during purchase-related transactions. We recommend reading their privacy policies to understand how your information will be handled.
Keep in mind that some providers may be located in, or have facilities in, a different jurisdiction than you or us. If you proceed with a transaction involving a third-party service provider, your information may be subject to the laws of the jurisdiction(s) where the provider or its facilities are located.
V. Payment Information
A. Payment Processing: If you use a direct payment gateway to complete your purchase of our services, we will store your credit card data, which is encrypted using the Payment Card Industry Data Security Standard (PCI-DSS). We store your purchase transaction data only as needed to process your purchase, including any subscription payments if applicable, which are automatically renewed each month.
B. Cancellation of Automatic Renewal: You can cancel the automatic renewal of your purchase transactions, including the associated purchase transaction data, at any time by contacting us at email address firstname.lastname@example.org
C. Payment Security: All direct payment gateways follow the standards set by PCI-DSS, which is managed by the PCI Security Standards Council. This council is a joint effort of major credit card brands like Visa, MasterCard, American Express, and Discover. PCI-DSS requirements ensure that our site and service providers securely handle your credit card information.
VI. Electronic Communications, Phone Calls, and Text Messages
A. Electronic Communications: By giving your consent in accordance with applicable law, you agree to receive electronic communications from us. We may choose to communicate with you through email or by posting notices on our site. All agreements, notices, disclosures, and other electronic communications we send to you satisfy any legal requirement that they be in writing.
B. Phone Calls and Text Messages: When you give your consent as per the Telephone Consumer Protection Act (TCPA) or any applicable law, you agree to receive phone calls, including artificial voice calls, pre-recorded messages, and calls delivered via automated technology, as well as text and SMS messages to the phone number(s) you provided. Message frequency varies, with a maximum of 20 messages per month and no more than three text messages per day. Mobile carriers are not responsible for delayed or undelivered messages.
C. Privacy: Be aware that text messages we send may be seen by anyone with access to your phone. To maintain privacy, take steps to protect your phone and text messages.
D. Opting Out: To stop receiving text messages, reply "STOP", "END", or "QUIT" to any text message we've sent. You can also request to stop receiving text messages by calling or emailing us at email@example.com
E. Help and Support: For our contact information or instructions on stopping text messages, reply "HELP" to any text message we've sent or click here for support. Message and data rates may apply to any text/SMS communication.
VII. External Links
We take reasonable precautions and follow industry best practices to protect your personal information from being lost, misused, accessed, disclosed, altered, or destroyed inappropriately.
When you give us sensitive information, like login details and credit card information, we encrypt it using secure socket layer technology (SSL) and store it with AES-256 encryption. While no method of online transmission or electronic storage is 100% secure, we comply with all PCI-DSS requirements and follow generally accepted industry standards to protect your personal information.
IX. Data Breach
If a data breach occurs, which may include accidental, unauthorized, or unlawful destruction, loss, alteration, disclosure, or access to personal data, we will notify you as soon as reasonably possible under the circumstances, but no later than 72 hours after becoming aware of it. This notification will include a detailed description of the data breach and the type of data affected. We will also communicate the following:
A. The name and contact details of our data protection officer or other point of contact for more information.
B. A description of the likely consequences of the data breach.
C. A description of the measures we've taken or propose to take to address the data breach, including any measures to mitigate its possible adverse effects.
D. Any other information you may reasonably request relating to the data breach.
We will promptly investigate the data breach and use industry-standard, commercially reasonable efforts to mitigate its effects. We will also, subject to your prior written agreement, carry out any recovery or other actions necessary to remedy the data breach. Unless required by applicable privacy laws, we won't release or publish any filing, communication, notice, press release, or report concerning the data breach. If required by law, we will report the data breach to the relevant supervisory authority within 72 hours of becoming aware of it, where feasible.
X. Geographic Location
If we process personal data originating from the European Economic Area (EEA) outside the EEA, in a territory that has not been designated by the European Commission as ensuring an adequate level of protection under applicable Privacy Laws, we will undertake the transfer pursuant to Section 8 mentioned above, which we will maintain in full force and effect. We have data processing agreements in place to ensure compliance with all relevant Directives, and all processing is performed according to the highest security regulations.
XI. Age of Consent
By using this site, you confirm that you are at least the age of majority in your state or province of residence. If you are the age of majority in your state or province of residence and have given us consent to allow any of your minor dependents to use this site, you may do so.
XII. CCPA Data Privacy
This section applies specifically to California residents for so long as WowSuite maintains Personal Information (as defined in and to the extent protected by the CCPA) This section prevails over any conflicting terms found elsewhere in the WowSuite legal documentation, but does not otherwise modify the remaining portions not in conflict. All capitalized terms not defined in this section shall have the meanings set forth in the CCPA or the WowSuite terms.
The parties agree as follows:
1. Scope and Applicability.1.1. This section applies to the collection, retention, use, and disclosure of the Personal Information to provide services to you pursuant to the WowSuite terms or to perform a Business Purpose.
1.2 You are a Business and appoints WowSuite as a Service Provider to process the Personal Information on behalf of you. You are responsible for compliance with the requirements of the CCPA applicable to Businesses.
1.3. WowSuite’s collection, retention, use, or disclosure of Personal Information for its own purposes independent of providing the services specified in the WowSuite terms are outside the scope of this section.
2. Restrictions on Processing.2.1. WowSuite is prohibited from retaining, using, or disclosing the Personal Information for any purpose other than for the specific purpose of performing the services specified in the WowSuite terms for you, as set out in this section, or as otherwise permitted by the CCPA.
2.2. WowSuite shall not further collect, sell, or use the Personal Information except as necessary to perform the Business Purpose. For the avoidance of doubt, WowSuite shall not use the Personal Information for the purpose of providing services to another person or entity, except that WowSuite may combine Personal Information received from one or more entities to which it provides similar services to the extent necessary to detect data security incidents, or protect against fraudulent or illegal activity.
3. Notice. You represent and warrant that you have provided notice that the Personal Information is being used or shared consistent with Cal. Civ. Code 1798.140(t)(2)(c)(i).
4. Consumer Rights.4.1. WowSuite shall provide reasonable assistance to you in facilitating compliance with Consumer rights requests.
4.2. Upon direction by you and within a commercially reasonable amount of time, WowSuite shall delete the Personal Information. 4.2.1 WowSuite shall not be required to delete any of the Personal Information to comply with a Consumer’s request directed by you if it is necessary to maintain such information in accordance with Cal. Civ. Code 1798.105(d), in which case WowSuite shall promptly inform you of the exceptions relied upon under 1798.105(d) and WowSuite shall not use the Personal Information retained for any other purpose than provided for by that exception.
5. Deidentified Information. In the event that either party shares Deidentified Information with the other party, the receiving party warrants that it: (i) has implemented technical safeguards that prohibit reidentification of the Consumer to whom the information may pertain; (ii) has implemented business processes that specifically prohibit reidentification of the information; (iii) has implemented business processes to prevent inadvertent release of Deidentified Information; (iv) will make no attempt to reidentify the information.
6. Mergers, Sale, or Other Asset Transfer. In the event that either party transfers to a Third Party the Personal Information of a Consumer as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the Third Party assumes control of all or part of such party to the Agreement, that information shall be used or shared consistently with applicable law. If a Third Party materially alters how it uses or shares the Personal Information of a Consumer in a manner that is materially inconsistent with the promises made at the time of collection, it shall provide prior notice of the new or changed practice to the Consumer in accordance with applicable law.
7. As Required by Law. Notwithstanding any provision to the contrary of the WowSuite terms, WowSuite may cooperate with law enforcement agencies concerning conduct or activity that it reasonably and in good faith believes may violate international, federal, state, or local law.
8. No Sale of Personal Information. The parties acknowledge and agree that the exchange of Personal Information between the parties does not form part of any monetary or other valuable consideration exchanged between the parties with respect to the Wowsuite legal documentation.
If our Company is acquired or merged with another company, we may disclose your Personal Data with our prospective or actual purchasers, investors, or successor entities in connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction, pursuant to assurances of sufficient data handling practices and safeguards.
For residents of the European Economic Area, our disclosure is limited to situations where we are permitted to do so under applicable European and national data protection laws and regulations.
XIV. Questions and Contact Information
If you would like to access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information, contact us at email address firstname.lastname@example.org
We have a "Data Protection Officer" who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at the following email address: email@example.com
A. Headings and Interpretation
Section headings are for convenience only and don't affect interpretation. References to parties, persons, entities, or corporations include appropriate gender and number as needed.
B. No Waiver