Privacy Policy DRAFT

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    1. For the purposes of the General Data Protection Regulation 2016/679 (hereinafter: the GDPR), WP Salad (hereinafter: the Company) is the data controller of your personal data (hereinafter: the Information).
    2. The Company provides you with access and usage of the website (hereinafter: the Service Website), which is subject to the Terms and Conditions of Service. The Service website represents a webpage that provides informations about the Company’s product to its users, as well as give them a form through which they can contact the Company.
    3. The Company respects your privacy and is committed to protecting your personal data as defined by the GDPR. The Company complies with the principles of the GDPR and aims to maintain consistently high levels of protection and legal compliance in its processing of your information.
    4. This Privacy Policy (hereinafter: the Policy) is intended to inform you on how your personal data is collected, used and disclosed through your use of the Company’s Service Website. This Policy is intended to assist you in making informed decisions in connection to your Information when using the Company’s Service.
    5. By using the Company’s Service website and services you consent to the Company’s collection and use of your Information as described in this Policy. If the Company makes changes to the Policy and/or procedures, the Company will post those changes on the Company’s Service Website, as well as inform you via email to keep you aware of what Information it collects, how it uses it and under what circumstances it may disclose it.
    6. Your continued use of the website or services after this Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of this Policy, as amended. The Company encourages you to bookmark this Web page and review this Policy regularly.



    1. All your Information will be held and used in accordance with the GDPR where applicable.
    2. When you visit and use the Company’s Service Website or use the Company’s services you will either be prompted to provide the Company with your Information on a voluntary basis, or the Information will be collected through your use of the Company’s Service website, where the Company is not legally bound to collect consent.
    3. Information you voluntarily provide to the Company
      1. The Company collects and maintains Information that you voluntarily submit to it during your use of the Company’s website or services. For example:
        1. when you register on the Company’s Service website and use it, you may provide the Company with certain Information including your username, first name, last name, email address.
        2. You may provide The Company with Information in the course of email interactions, customer support interactions and surveys.
        3. Customer Contact
          • You may choose to provide feedback to the Service Website, for example through email or letters. If provided to the Service Website the comments in your feedback, as well as your contact information like your email, may be kept on record.
          • The feedback that you choose to provide is valuable in helping The Company make improvements to its the Company’s Service Website to you. In order to follow-up on the feedback you have chosen to provide, The Company may correspond with you using the contact information that you have provided.
      2. The legal basis for the processing of your personal information is:
        1. the necessity to provide you services;
        2. the Company’s obligation to process your information to the extent the Company is required by law (e.g. to comply with anti-money-laundering laws).
        3. the consent you provide to The Company to process certain data (in order to, e.g., send you marketing materials).
      3. You provide your information to the Company voluntarily and you can choose not to provide the Company with certain Information, however this may present a basis for the Company to prevent you from gaining access to the Company’s Service website or limit the features of the service that you can use on the Company’s Service website.
    4. Information the Company collects through your use of the Company’s Website
      1. As you use the Company’s Service website, Information may also be passively collected by the Company through the Company’s use of cookies, pixels, beacons, log files and other technologies. The information that is gathered pertains to your devices’ IP addresses, browser type, operating system, etc.
      2. This Information allows The Company to deliver more helpful information, services and tools in the future. To the extent such information constitutes personal data the Company processes it to the extent of the Company’s legitimate interests: to analyse usage of the Company’s Service website, in order to prevent breaches of security and to make improvements to the Company’s services. Please see the Company’s Cookie Policy for more information.
    5. Information the Company receives from third parties:
      1. The Company may also combine online and/or offline information received from third parties with your Information.
      2. The third party information is used for a variety of purposes including:
        1. to comply with applicable regulatory requirements (including anti-money-laundering requirements);
        2. to verify other Information about you (e.g., mailing address to send you requested products or services); and
        3. to enhance the content and services the Company provides to you.
      3. the Company processes this information to provide you the services you have requested and perform the Company’s obligations in accordance with any contract that the Company may have with you or to comply with the Company’s legal obligations. It is also in the Company’s legitimate interest to use your personal information in such a way to ensure that the Company provides you with the very best service.



    1. The Company will use your Information in the ways described below and as described at the time that the Information is collected.
    2. For the provision of the services through the Service Website:
      1. The Company shall use your Information as necessary or appropriate for the Company’s business purposes, including to:
        1. administer your account where you have opened an account with the Company;
        2. register you and provide you access to the Service Website or services requested by you, as well as identify you when you use the Service Website in order to enjoy a customized and personalized experience;
        3. fulfill your requests for products, services;
        4. identify, prevent or detect fraud, money-laundering or other crime;
        5. respond to inquiries or requests that you direct to the Company;
        6. send communications and administrative emails to you about the Service website or other services;
        7. analyse, benchmark and conduct research on user data and user interactions with the website and the Company’s services;
        8. as a security measure, to send you an email confirming your account registration;
        9. allow the Company Service website or the Company to process and complete your purchases;
        10. provide information on the basis of which the Company’s customer service agents could contact you when necessary;
        11. send you our optional periodical updates;
        12. if you were to opt for it, send you information about products and services which may be of interest to you;



    1. Where you have provided us with the legally appropriate consents, or where the Company may have a legitimate interest to do so, the Company may send you marketing materials about other products or services offered by the Company.
    2. In addition, where you have provided us with the legally appropriate consent, the Company may also pass your Information to one or more selected third parties for marketing purposes.
    3. However, be assured that the Company understands the irritations of unsolicited communications and that the Company is fully committed to ensuring the rights and obligations set out in the GDPR are respected.
    4. If the Company sends you marketing materials about products or services offered by third parties, whom the Company provided with your Information, sends you such materials, you can always withdraw your consent. This will not affect the lawfulness of using your Information for marketing purposes before withdrawal.



    1. Under the GDPR you have the right to ask the Company to provide you with all the information it stores on you. You have the right to request a copy of the Information that the Company holds about you, however, if you require additional copies, the Company may need to charge a reasonable fee. The Company may deny you the right to access your information if the Company is under a legal obligation not to disclose information or if such disclosure would reveal an identity of another person.
    2. You also have the right to ask the Company to rectify or delete your personal information, as well as to restrict its use. With regards to information you provided to the Company based on legal grounds for processing you have the right to have your information ported to another organization. You have the right to request additional information about the handling of your personal data. In order to realize your rights the Company may require two pieces of identification to prove your identity.
    3. Where the Company has asked for consent to process your data, you also have the right to withdraw this consent. After withdrawal of your consent, the Company may also process your information if it still needs to process it to fulfill the Company’s legal obligations or if this is necessary to perform the contract you have concluded with us.



    1. The Company may share your Information with third parties as specifically approved by you or under the circumstances described below.
    2. Disclosure to third party organizations to provide the services:
      1. Where you use the services available on the Company’s Service Website the Company may disclose your Information to relevant third parties with whom you are contracting in order for them to fulfill the terms and conditions of those arrangements. Such disclosure shall only take place following entry into the relevant agreement.
      2. Disclosure will be made in the following scenarios for the following purposes:
        1. When you make purchases on the Service Website;
        2. To successfully complete your purchases or otherwise implement our terms of service, your personal information is provided as needed to the Service Website’s third party product and service providers or other third parties authorized by the Company, if any;
    3. Disclosure for legal or regulatory reasons:
      1. The Company may disclose your Information if the Company is under an obligation to disclose or share your Information to comply with any legal obligation or in order to enforce or apply or fulfill the Company’s Terms and Conditions of Service and other agreements or protect the rights, property, or safety of the Company’s customers or others. This includes exchanging information with other companies, regulators and organizations for fraud protection.
      2. The Company uses a number of third party organizations to help provide a professional level of service to the Company’s customers. These organizations act as data processors and are strictly controlled in how they may or may not use your Information and the Company remains responsible for the protection of your Information.



    1. In the event that the Company goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of the Company’s assets, your Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Policy.
    2. In the event that the Company is terminated, the gathered Information shall be permanently deleted, prior to which you will receive an email notice of the exact date and time of the deletion. The deletion of the Information shall only pertain to such information that the Company is legally required to delete in the aforementioned event.



    1. There are a number of ways in which you can control the collection, use, and sharing of your Information and update your Information and preferences.
      1. Cancelling your user registration
        1. You may at any time choose to close your account with the Company. The Company will then cease processing your Information for any new purposes, but such closure shall not affect the Company’s ability to retain and process any Information required for the performance of obligations arising from law or for the completion of any services which are in process.
      2. Opting-out of receipt of marketing communications
        1. When you receive marketing communications from us you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the marketing e-mail or newsletter.



    1. The Company will retain your Information only for as long as it is necessary for the purposes set out in this policy and for the provision of the Company’s services. The Company may retain and use your Information to the extent necessary to comply with the Company’s legal obligations, resolve disputes, and enforce the Company’s agreements.
    2. The Company also retains log files for internal analysis purposes. These log files are generally retained for a short period of time, except where they are used for website security in order to improve website functionality. For more information of the period of retention of log files please read the Company’s Cookie Policy.
    3. Please note that:
      1. even if you delete your Information, the Company may retain your Information in conformance with the Company’s data retention policy; and
      2. the Company is not responsible for updating or removing your Information contained in the lists or databases of third parties who have been provided with your Information as permitted by this Policy.



    1. Please remember that when you use a link to go from the Company’s website to another website or you request a service from a third party, the Company’s Policy no longer applies. Your browsing and interactions on any other website or your dealings with any other third party service providers, is subject to that website’s or third party service provider’s own rules and policies. The Company does not monitor, control, or endorse the information collection or privacy practices of any third parties.
    2. The Company encourages you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their privacy policies and practices. This Policy applies solely to information collected by the Company through its Service Website and does not apply to these third party websites and third party service providers.



    1. The Information that the Company collects from you will be transferred to and stored at a destination inside the European Economic Area (hereinafter: EEA). However, for technical reasons the Information might also be transferred to a destination outside the EEA. Your Information may also be processed by staff operating outside the EEA who works for the Company or for one of its suppliers. Countries where your Information may be transferred may offer different levels of data protection laws to the country from where you submitted your Information.
    2. The Company will take all steps reasonably necessary to ensure that your Information is treated securely and in accordance with this Policy and the GDPR. Where this is required by local laws, the Company will make arrangements with entities receiving your Information that they shall ensure that security measures are in place, and that your Information is processed only in accordance with EU Data Protection laws.
    3. If your Information is transferred to a jurisdiction outside the EEA, it will be done so under agreements with the Company’s counterparts, which contain standard data protection contract clauses (so called “Model Clauses” adopted by the European Commission). Such clauses provide safeguards for your Information that is transferred outside of Europe. In addition, the transfer may be undertaken on the basis of an adequacy decision, as prescribed by the GDPR.



    1. The Company follows appropriate security procedures in the storage and disclosure of your Information so as to prevent unauthorized access by third parties. The Company also requires those parties to whom the Company transfers personal information to comply with the same. Unfortunately, the transmission of information via the internet is not completely secure. To that end, the Company cannot ensure the security of your Information transmitted by you to the Company via the internet. Any such transmission is at your own risk and you acknowledge and agree that the Company shall not be responsible for any unauthorized use, distribution, damage or destruction of your Information, except to the extent the Company is required to accept such responsibility by the GDPR. Once the Company has received your Information the Company will use security procedures and features to prevent unauthorized access to it.
    2. You can play your part in safeguarding your personal information by never disclosing your login password or account information to anybody. Whenever you log in as a member on the Service Website, particularly on somebody else’s computer or on public internet terminals, you should always log out at the end of your session. Your assistance will help us protect the privacy of your personal information.
    3. The Company cannot be held responsible for lapses in security caused by third party accesses to information as a result of your failure to keep your personal information private. Please notify us immediately if there is any unauthorized use of your account by any other internet user or any other breach of security.



    1. If you wish to make a compliant about how your personal data is being processed by us or the Company’s partners, you have the right to complain to (EMAIL). If you do not receive a response within 30 days you can complain to the Information Commissioner’s Office