2. Data Controller (WNDYR personnel), EU Representative, Data Protection Officer,
Data Processor (deployments and services)
3. Purpose of the Processing and the Legal Basis for the Processing
4. What categories of Personal Data we collect, how we collect and use (process) it
and for what purpose(s)
5. Your Rights
6. Questions, Concerns and Complaint with a Supervisory Authority
7. Disclosure of Personal Data
8. Transferring Personal Data from the EU to the US
9. Security of Personal Data
13. Contacting Us
In addition, it applies in respect of all applications for the supply of products and services and employment contracts with WNDYR where you have contracted directly with WNDYR; WNDYR is the Data Controller in respect of your Personal Data in these circumstances.
Where your employer has subscribed to WNDYR products such as Pattyrn directly, your employer and WNDYR are joint Data Controllers.
We do not collect any information from anyone under 16 years of age. Our website, products and services are all directed to people who are at least 16 years old or older.
2. Data Controller (WNDYR Personnel), EU Representative, Data Protection Officer, Data Processor (all deployments and services)
2.1 Data Controller (WNDYR Personnel)
Where you apply to or do join the WNDYR personnel team, the Data Controller controlling the means of processing of your Personal Data and the purposes of such processing (subject to the circumstances in clause 2.4 below) is:
WNDYR Inc reg no. 821252534 2021 McKinney Ave, Suite 430, Dallas, TX 75201 general info email - firstname.lastname@example.org
Please note that the transmission of your personal data in response to the Contact Us form will be unencrypted.
2.2 EU Representative
Where one of the WNDYR group companies is responsible for controlling or processing Personal Data outside the EU, WNDYR Limited registered in Ireland is its EU representative.
WNDYR Limited (trading as WNDYR) Registered in Ireland with company number 470526 Registered address in Ireland at: 5th Floor, 5 Lapp’s Quay, Cork
2.3 Data Protection Officer
WNDYR’s data protection officer can be contacted as follows:
Tel: +353 (0)86 140 7872 and ask for the DPO.
2.4 Data Processor (WNDYR Processing on Behalf of Deployment Partner or Clients)
Where we process your Personal Data on behalf of one of our deployment partners or clients, we shall not be controlling the means of processing nor the purposes for which the Personal Data is processed. In those circumstances it will be the deployment partner (or client who is your employer) who is the Data Controller primarily responsible for your Personal Data; we shall be a data processor acting upon the instructions of that deployment partner (or your employer) with whom you are contracted. In the first instance you should direct any queries regarding your Personal Data to that deployment partner (or employer) with whom you have a contract.
3. Purpose of the Processing and the Legal Basis for the Processing
We gather two types of information when providing services or products to you:
3.1 Personal Data:
3.1.1 Contact Us
We collect information from you when you register on our site or fill out a form.
When registering on our site, through the “Set Up A Call” page or any other area where you may submit your CV, request newsletters / blogs or provide feedback, or consent to the provision to us of your details by a webinar or seminar organiser, you may be asked to enter your: name, e-mail, address and/or telephone number information as appropriate. This information will only be used by us in accordance with the terms herein, to enable us to contact you and discuss what products (eg Pattyrn) and/or services we can provide to you now or in the future.
3.1.2 Deployment Services
The provision of your Personal Data is voluntary. You can request that we delete it at anytime. However, if you do not provide us with the required Personal Data, we may not be able to provide you or your employer with the product/service requested.
3.1.3 WNDYR Team
3.2 Non-Personal Data:
We may collect information about your visit to and use of this site, including sales data, traffic data and related site information. We may also collect anonymised information during the course of deployments which we provide. This information helps us to evaluate and improve our site and services and may also be used for investment analysis purposes. As Non-Personal Data does not personally identify you, we may use it for any purpose.
4. What Categories of Personal Data We collect, How We Collect and Use (process) it and for What Purpose(s)
With a few exceptions, this information is limited to the kinds of information that can be found on a business card: first name, last name, job title, employer name, work address, work email, and work phone number.
4.2 How We Collect It
4.2.1 we are contracted with a deployment partner and the information is collected by them within their system.
4.2.2 you apply to join the WNDYR team or contract with us directly;
4.2.3 when you use this site, register as a user or we collect information from you with your consent from live lectures (webinars or seminars) which you attend when one of our personnel is speaking;
4.2.4 when your employer subscribes to one of our products, Pattyrn.
4.3 What We Use Your Personal Data For
We, and our third party deployment partners (and your employer) with whom you are contracted (where applicable), collect information from you within the relevant deployment partner’s own system, which may be used as follows:
Where you have subscribed to a third party deployment partner service and we are providing that service on behalf of that third party, we shall process and administer your Personal Data and process transactions, fulfil your employer’s requests, orders and/or to provide other information they have requested. We shall process Personal Data in accordance with that third party’s instructions, as controlled by them (clause 2.4 above refers).
We require this Personal Data in order to be able to complete our contractual obligations to our deployment partner with whom you have contracted.
Complete delivery of your employer’s order for our products or services. We require this Personal Data in order to be able to complete our contractual obligations to our deployment partner where you are contracted with them.
Provide Pattyrn product and services pursuant to our contract with your employer.
Retain order details for repeat orders and/or when your employers has opened an account with us and/or where you request us or our deployment partners to do so We require this Personal Data in order to be able to complete our contractual obligations to our deployment partner with whom you or your employer has contracted.
Personalize your experience
Improve customer service
To respond to your enquiries or comments submitted through our website
Send periodic emails . You consent when you Contact Us through this website or provide consent to the organiser of a webinar or seminar where you request such updates from WNDYR expressly.
Notify you about important news or blogs concerning our products, industry updates, events, promotions and competitions, reports and other information. You consent when you Contact Us through this website or provide consent to the organiser of a webinar or seminar where you request such updates from WNDYR expressly.
Provide you with information about products and services that you request from us or, where you have consented to be contacted, for such purposes which we feel may interest you
To obtain your feedback
In addition, in order to carry out our lawful activities and for legitimate purposes, we may collect and process your Personal Data to:
Allow you to use interactive features in our services
Retain a record of incoming and outgoing communications (e.g. email).
In respect of our resources, communications may be subject to automated monitoring to ensure that ours and our partners’ confidential information and personal data are protected as our GDPR policies provide and to detect breaches of security
Protect the security and integrity of the website and our services
Prevent and detect fraud or other prohibited or illegal activity
In response to a court order, request for cooperation from a law enforcement or other government agency
To permit applications for employment with us and related activities to such applications and contracts for service or services
To establish or exercise legal rights
To bring or defend legal claims
For responsible corporate governance or as otherwise required or permitted by applicable laws and/or regulations
In circumstances in which we believe disclosure is appropriate in connection with fraud prevention and prevention of other illegal, or unlawful activity or any other activity which is or may be contrary to our legal and regulatory compliance obligations
To protect and defend the rights, property or safety of WNDYR and/or other companies in the WNDYR group, its/their investors and other clients, staff, and/or service providers.
We continually strive to improve our services and the website offerings based on the information and feedback we receive from you. Your information helps us to respond more effectively to your requests and support your needs. Note: If at any time (other than in relation to a deployment contract with your employer) you would like to unsubscribe from receiving future communications, we include detailed unsubscribe instructions at the bottom of each communication.
5. Your Rights in respect of your Personal Data
This Privacy Notice is intended to provide you with information about what Personal Data WNDYR collects about you and how it is used. If you have any questions, please contact us at email@example.com or DPO@wndyr.com.
You have various rights in respect of your Personal Data which can be summarised as follows:
- The right to be informed. Where WNDYR intends to collect your Personal Data, where this is not for fulfilling a contractual obligation owed by WNDYR to a deployment partner, you have a right to consent or object to such collection for the intended purposes. In respect of each intended purpose you will be asked to tick box to indicate your consent to each intended purpose for processing of your Personal Data
- The right of access. You may request to receive a copy of any Personal Data held by us, which personally identifies you. We may ask you to verify your identity and for more information about your request
- The right to rectification. We will correct or erase inaccuracies in the information we hold about you when we learn of the inaccuracy
- The right to erasure. Personal Data may be erased if we do not have a contractual or legitimate reason for retaining the information
- The right to restrict processing
- The right to data portability
- The right to object
Rights in relation to automated decision making and profiling. WNDYR does not carry out any automated decision making.
Please contact WNDYR in writing with any requests and provide verification that you are who you say that you are.
If you are an employee of one of our deployment partners or Pattyrn customers, we suggest that in the first instance you contact your employer who is a Data Controller.
6. The Right to Lodge a Complaint with a Supervisory Authority
IIf you have a reason to complain about how your Personal Data has been controlled and processed by WNDYR, please in the first instance contact your employer or WNDYR and we shall endeavour to resolve your queries promptly. If you remain unsatisfied, you may lodge a complaint with:
Data Protection Commission,
Address: Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland.
Phone +353 (0761) 104 800 | LoCall 1890 25 22 31 | Fax +353 57 868 4757 | email firstname.lastname@example.org
You may use this form: https://www.dataprotection.ie/docs/raise-a-concern-Form/m/1727.htm
Please copy any such communication to us so that we can work to resolve any outstanding issues promptly.
For US Residents:
For purposes of enforcing compliance with the Privacy Shield, WNDYR is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission.
In compliance with the Privacy Shield Principles, WNDYR commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact WNDYR at: email@example.com and copy to firstname.lastname@example.org
WNDYR has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship and non-human resources data.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
7. Disclosure of Personal Data
Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the product or service requested.
We may also disclose Personal Data in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our deployment Terms of Service, or may be causing injury to or interference with any of our rights or property, other users, or anyone else. We may disclose or access account information when we believe in good faith that the law requires it and for administrative and other purposes that we deem necessary to maintain, service, and improve our products and services.
8. Transferring Personal Data to the US or EU
To help protect the privacy of data and personally identifiable information processed by us, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your Personal Data to those WNDYR personnel who need to know that information to provide benefits or services to you. In addition, we train our personnel about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.
10. Retention Period
We shall retain and store your Personal Data securely and for as long as necessary in order to fulfil our and our deployment partners’ or Pattyrn customers’ (where applicable) contracts with you. We shall then only retain Personal Data for as long as necessary to comply with our legal obligations under relevant law and our legitimate interests.
For more information on where and how long your Personal Data is stored, and for more information on your rights of erasure and portability, please contact the WNDYR’s data protection officer at email@example.com or DPO@wndyr.com.
11. Terms of Service and Cookies
Please also visit our Terms of Service section establishing the use, disclaimers, and limitations of liability governing the use of our website at https://wndyr.com/
13. Contacting Us
Deployments. Where we process your Personal Data on behalf of one of our deployment partners, or on behalf of your employer, we shall not be controlling the means of processing nor the purposes for which the Personal Data is processed. In those circumstances it will be the deployment partner (and/or your employer) who is the Data Controller primarily responsible for your Personal Data; in the first instance you should direct any queries to that deployment partner and employer with whom you have a contract.
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