Wiwink's privacy policy complies with international and European law (GDPR) on data protection. In addition, Wiwink intends to use this document to inform the user of their rights and obligations regarding the privacy of their data, as well as to explain the reason for the storage and use of the data.

This privacy policy regulates all aspects relating to the processing of the personal data of the various users – individuals – who browse the Wiwink website or use the services offered by Wiwink.

As a result, Wiwink distinguishes between the following users:

- Visiting Users (those who only visit the Wiwink website), Registered Users (those who have registered on the platform with Wiwink and have a user account with us), Client Users (those who have an account with Wiwink and have also engaged the services of Wiwink, either via a free trial or through payment). The general privacy policy (Section 1) applies to them.

- Recipient Users; these are users who receive the services that have been engaged by the Client User. In addition to the General Privacy Policy, where applicable, the specific Recipient User Privacy Policy (Section 2) will apply to them.

Data protection law distinguishes between the "Controller" and the "Processor" of the data.

Wiwink is the Controller for the data collected directly through our website or through our social media Profiles, and the user, a Wiwink Client, will be the Processor for the data of its clients. These will also be the target users of the services offered by Wiwink, and these services include: Electronic Signature, Biometric Signature, and Email Marketing Services, with Wiwink being the Data Controller in these cases.

Identity: Wink Insights S.L

CIF [Tax ID Code]: B87547642

Mailing Address: C/Gil de Jaz 2, piso 8º, 33004, Oviedo, Principado de Asturias

Email: [email protected]

We collect personal information about you by different means. In some cases you will contact us to share your personal information. Below, we will explain the different ways in which we collect personal information about you and some examples in which we use that information.

The User of the website can send questions and queries to Wiwink concerning the operation of the platform, the services that we offer, or any other issue. For this purpose, the user can contact Wiwink through the contact form available on the website. The following information must be provided on this form: Contact person, contact email, telephone number, and the query, so that we can contact Users and respond to their queries, or Clients can also contact Wiwink through the Chat service, which allows them to start a conversation and receive real-time support from our customer service team.

The users of the website will be able to register on the Wiwink platform and activate their customer profile. As well as their username, they will be required to provide a series of personal details, such as first and last names, telephone number, company and email at the time the platform is registered, as well as photographs or other documentation that the user chooses to upload to the application in the account information and contact information sections.

Wiwink collects all information entered into the platform by the user and stores it on the servers of the Wiwink storage provider. As a Cloud service, server storage is a requirement for the operation of the application, and the user accepts this.

Data is collected from Users for the purpose of providing the services offered by Wiwink. When registering as a Client User on the Website, an asterisk indicates the compulsory or optional nature of the data provided at the time it is collected..

The collection of your data occurs when the sender or customer of the platform indicates their name and contact email address as the recipient of the information or document that you send through Wiwink. Before sending their response, Recipient Users will be informed of the Privacy Policy that applies to them.

We may collect your data through your user profile on the social media we use.

Our advanced electronic signature incorporates biometric technology, allowing us to obtain biometric data from the signer's hand such as velocity, acceleration, pressure or pseudo-pressure. Therefore, when a signatory signs a document through our advanced electronic signature tool, we will be collecting their biometric data. To this end, we will seek their express consent under the provisions of European Regulation 679/2016.

In addition to the above, Wiwink also collects other information and data ("Other Information") in various ways:

1. Recorded data. As with most websites and technology services provided on the Internet, our servers automatically collect information when you access or use our Websites or Services, and collect it in log files. This log data may include the Internet Protocol (IP) address, the address of the webpage you visited prior to using the Website or Services, the type of browser and its settings, the date and time the Services were used, information about browser settings and plug-ins, as well as language preferences and cookie data.

2. Cookie Information. Wiwink uses cookies and similar technologies on our Websites and Services to collect other information. The Websites and Services may also include cookies and similar tracking technologies from third parties, which may collect Other Information about you through the Websites and Services, as well as through other websites and online services. For more information about how we use these technologies, your opportunities to decline them, and other options, please see our Cookie Policy.

3. Third-party services. Clients may choose to allow or restrict Third-Party Services for workspaces. Third-Party Services are generally software that integrates with our Services. Wiwink may also develop and offer other Wiwink applications that connect the Services to a Third-Party Service. Once enabled, a Third-Party Service provider may share certain information with Wiwink. For example, if a Cloud storage application has been enabled to allow files to be imported into a Workspace, we may receive the username and email address of authorized Users, along with additional information that the application has chosen to make available to Wiwink to facilitate integration. Authorized Users should check the privacy notices and settings on these Third-Party Services to find out what data may be disclosed to Wiwink. When a Third-Party Service is enabled, Wiwink is authorized to connect to and access other information available to Wiwink in accordance with our agreement with the Third-Party Provider and with any permission granted by the Client. However, we do not receive or store passwords from any of these Third-Party Services when connecting them to the Services.

4. Finally, Wiwink collects data from the connection device via cookies. Users can disable cookies in their browser to prevent Wiwink from collecting this information, should they not wish it to do so. This information is used to carry out studies on browsing and access to the application, as well as the use thereof. Browsing information includes the type of device and its characteristics, location, and connection times.

We use the information we collect in various ways to provide the Service and operate our business, including the following:

1. Operations

We use the information, other than customer data, to operate, maintain, improve and provide all functions of the Service, provide the services and information you request, respond to comments and questions, and provide assistance to users of the Service. We only process Client Data according to the instructions provided by Clients or relevant Users.

2. Improvements

We use the information to understand and analyze the usage trends and preferences of our visitors and users, to improve the Service and to develop new products, services, features and functions. If this purpose requires Wiwink to process Client data, then the data will only be used anonymously or in aggregate form.

3. Communications

We may use a User or Visitor's email address or other information, other than Customer Data, to contact that visitor or user (i) for administrative purposes, such as customer service, to address intellectual property infringement, violations of privacy rights or defamation issues relating to Customer Data or Personal Data posted on the Service or updates on promotions and events, relating to products and services offered by us and third parties with whom we work. You have the option to opt-out of receiving promotional communications by indicating this in your panel preferences.

4. Cookies and tracking technologies

We use information collected automatically and other information collected on the Service through cookies and similar technologies to: (i) personalize our Service, for example to remember a User or Visitor's information so that the User or Visitor does not have to re-enter it during a visit or subsequent visits; (ii) provide personalized advertisements, content and information; (iii) monitor and analyze the effectiveness of the Service and third-party marketing activities; (iv) monitor aggregate site-usage metrics, such as total number of visitors and pages viewed; and (v) track entries, shipments, and status concerning any promotion or other activities that are part of the Service. For more information please consult our cookie policy.

5. Google Analytics

We use Google Analytics to measure and evaluate access and traffic in the public area of the site and create user browser reports for our Website administrators. Google operates independently of us and has its own privacy policy, which we suggest you review. Google may use the information collected through Google Analytics to evaluate the activity of users and visitors to our Website. For more information, see Google Analytics data sharing and privacy.

We take steps to protect the technical information collected by our use of Google Analytics. The data collected will only be used as necessary to solve technical problems, administer the site, and identify visitor preferences, but in this case the data will be in a non-identifiable form. We do not use any part of this information to identify visitors or users.

6. Additional limits on the use of your Google user data

If you allow the application to access your Google data, the Application's use of that data will be subject to these additional restrictions:

• The application will only use the login access of your login data that allows users to create and manage their Google Meet meetings and will not transfer this Google Meet data to others unless necessary to provide and improve these features, comply with applicable law or as part of a merger, acquisition or sale of assets.
• The app will not use your Google data to post ads.
• The application will not allow humans to read this data unless we have their agreement for specific messages, where it is necessary for security reasons, such as investigating infringements, complying with applicable law or for internal operations of the application. Even in such cases, this shall only be done when the data has been aggregated and anonymized.
• The use of information received by the application and transfer of information from the application to any other application from the Google API shall comply with the User Data Policy of Google API Services, including limited use requirements.

The main reason we collect your personal information is to facilitate and improve the service that you as a client expect from us.

Wiwink details the main purposes below:

• Creating and managing a personal account to be used when engaging services offered by Wiwink
• Resolving and attending to requests for information required by the users
• Fulfilling contracts or services engaged by users with us
• Enabling Wiwink to act in their interests, respecting the rights of the User
• Managing the commercial and accounting aspects of the contract
• Facilitating the payment of the services engaged by Client Users
• Sending information that can be considered of interest to the user
• Reporting on news or activities that can be carried out by Wiwink
• Sending communications for advertising purposes
• Detecting malicious behavior (fraud, phishing, spam, etc.)
• Improving the browsing experience for site users

For the processing of your personal information, we rely on legal grounds for several reasons:

1. For the fulfillment of a contract and/or commercial relationship.
2. For the fulfillment of various legal obligations.
3. Due to legitimate interest, for example, for security reasons, fraud prevention, to improve our services and products, or to handle requests, inquiries or potential claims that may arise.
4. With their consent, for example, for the submission of personalized offers.

We only store your personal information to the extent that we need it in order to use it for the purpose for which it was collected, and on the legal basis for its processing under applicable law. We will maintain your personal information as long as there is a contractual and/or commercial relationship with you, or as long as you do not exercise your right to delete, cancel and/or limit the processing of your data. In these cases, we will keep the information properly blocked, without using it for any purpose, for as long as this may be necessary for the exercise or defense of claims or where any kind of judicial, legal or contractual liability for its processing may arise, which must be attended to and for which its recovery is necessary.

The personal data collected is intended for Wiwink's commercial and accounting departments. It may be communicated to Wiwink's subsidiaries, or to the Service Providers or subcontracted companies on which Wiwink may rely in the context of the provision of its services.

In this context, personal data may be communicated to member states of the European Union and non-member states. Wiwink implements guarantees that ensure the protection and security of such data, in accordance with the law.

We do not share personal information with companies, organizations or individuals who are not related to Wiwink, unless one of the following circumstances exists:

• Consent: We will share your personal data with companies, organizations or individuals outside Wiwink when you have given us your consent to do so. Your consent will be necessary to share specially protected personal data.
• External processing: We provide personal information to our affiliates or other trusted individuals or companies for processing by Wiwink, following our instructions and in accordance with our Privacy Policy, and other appropriate security and confidentiality measures.
• Legal grounds: We will share your personal data with companies, organizations or individuals outside Wiwink if we believe in good faith that there is a reasonable need to access or use, retain or disclose such data in order to: comply with any requirements provided for in the applicable laws or regulations or comply with any request of an administrative or judicial body, to comply with the provisions of the current Terms of Service, including the investigation of possible infractions, to detect or prevent any fraud or security or technical incidents, or otherwise address them, protect the rights, property or security of Wiwink, our users, or the general public to the extent required or permitted by applicable law.

Anyone has the right to obtain information as to whether or not Wiwink Insights S.L. is processing personal data that concerns them.

Interested parties have the right to access their personal data, as well as to request the correction of inaccurate data or, where appropriate, to request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

In certain circumstances, interested parties may request a limitation on the processing of their data, in which case we will retain it only for the purpose of exercising or defending claims.

In certain circumstances and for reasons relating to their particular situation, interested parties may object to the processing of their data. In this case, Wiwink Insights S.L. will cease processing the data, except for legitimate and compelling reasons, or the exercise or defense of any claims.

In certain circumstances, interested parties may receive their personal data provided in a structured, commonly used and mechanically readable format, and be able to communicate it to another data controller, wherever technically possible.

You can materially exercise your rights in the following way: By sending an email to [email protected] duly identifying yourself and expressly indicating the specific right that you wish to exercise.

If you have given your consent for any particular purpose, you have the right to withdraw the consent given at any time, without affecting the legality of the processing based on prior consent to its withdrawal.

In the event that you feel your rights are violated in terms of the protection of your personal data, especially when you have not obtained satisfaction in the exercise of your rights, you can file a complaint with the relevant Data Protection Supervisory Authority through its website: www.agpd.es.

Wiwink informs the users of the software of all its products and electronic signature solutions that the data processing performed as a result of the use of the software is carried out by Wiwink in its capacity as Data Processor, the Data Controller for this processing being the individual or legal entity who has acquired our products or engaged our services.

Wiwink hereby informs users who use biometric signatures to sign documents that the technology used for this purpose allows us to obtain biometric data from the signer's hand such as speed, acceleration, pressure or pseudo-pressure. We will therefore seek express consent under the provisions of European Regulation 679/2016 (Article 9.2), and the processing of biometric data derived from that signature shall be undertaken by Wiwink in the capacity of Data Processor, the Data Controller for this processing being the individual or legal entity who has acquired the product or engaged the service from which the collection of the signature is derived. The biometric data collected shall be processed in accordance with the legally established security measures, and it shall be encrypted.

Wiwink hereby informs users who receive emails from our Client Users that, in order to provide its Services, Wiwink shall have access to the information included in the email distribution lists created by Client Users in their personal accounts and the processing that takes place in order to send the emails through our platform is conducted in our capacity as Data Processors, with the Data Controller for this processing being the individual or legal entity who has created these distribution lists and acquired our products or engaged our services.

Should the target user wish to exercise their data protection rights when Wiwink is acting as the data processor, they must address the request to the Data Processor, i.e., the individual or legal entity who has engaged Wiwink’s service. Wiwink also declares that, as data processor, it shall provide support for the exercise of these rights.

Many of our services allow you to share information with other users. Remember that when you share information publicly, it can be indexed by search engines. Our services give you different options on how to share and delete your content. How to access and update your personal data whenever you use our services. Our goal is to provide you with access to your personal information. If this information is not correct, we strive to provide you with ways to quickly remove or update it, unless we need to maintain that information for legitimate business or legal reasons. By updating your personal information, we may ask you to verify your identity so that we can process your request.

We may reject requests that are more repetitive than reasonable, require disproportionate technical effort (for example, developing a new system or radically changing an existing practice), compromise the privacy of other users, or are impractical (for example, requests that reference information stored in backup systems). When we can offer you the ability to access and modify your personal data, we will do so free of charge, unless this requires a disproportionate effort.

By providing our services, we will protect your data from accidental or intentional deletion. For this reason, even if you delete your data from our services, we may not immediately destroy any residual copies stored on our active servers or the data stored on our security systems.

At Wiwink, safety is the most important thing. The data storage service is currently carried out through specialized providers with security certificates and anti-hacking systems. Wiwink has decided to outsource storage to ensure that the vendor meets the highest security standards, at levels that Wiwink could not offer on its own storage servers.

We strive to protect Wiwink and our users from any unauthorized modification, disclosure or destruction of the data we hold against unauthorized access thereto. In particular, we encrypt many of our services using the SSL protocol. We review our data collection, storage and processing policy, including physical security measures, to prevent unauthorized access to our systems. We limit the access of Wiwink vendors, agents and employees to the personal information they are required to process for Wiwink and ensure that they comply with strict contractual confidentiality obligations and that they are subject to appropriate disciplinary conditions.

At Wiwink, we verify compliance with our Privacy Policy on a regular basis. We also adhere to different self-regulation codes. If we receive a formal written complaint, we will contact the person who made the complaint to follow up on it. We will work with the relevant regulatory authorities, including local data protection authorities, to resolve any claims relating to the transfer of personal data that we have not been able to resolve directly with you.

Our Privacy Policy may be amended at any time. We will not limit your rights under this Privacy Policy without your express consent. We will post all changes to this Privacy Policy on this page and, if significant, publish a more prominent notice.

Wiwink is present on the main social media channels: Facebook, LinkedIn, Instagram, Twitter and YouTube. For this reason, it assumes the role of Data Controller concerning data included in profiles provided by friends, likes, followers, comments, pins, etc..

The user expressly agrees to be bound by the terms and conditions of privacy provided by the different social media channels or platforms on which Wiwink is present, allowing the latter to use the means provided by these networks to inform users about the different activities and services it carries out.

When we require information from you, we will always ask you to voluntarily provide it to us by expressly providing consent through the means offered for this purpose.

The processing of the data collected through the data collection forms of the website or other means shall be incorporated into the Registry of Processing Activities for which Wiwink Insights S.L. is responsible

Wiwink Insights S.L. processes data in a confidential manner and takes appropriate technical and organizational measures to ensure the appropriate level of security for the processing, as required by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 and other applicable data protection legislation.

However, Wiwink Insights S.L. cannot guarantee the absolute invulnerability of the systems. For this reason, it assumes no responsibility for any damages arising from alterations that third parties may cause to the computer systems, electronic documents or user files.

If you choose to leave our website via links to websites not owned by us, Wiwink Insights S.L. shall not be responsible for the privacy policies of those websites or the cookies they may store on your computer.

Our policy regarding the sending of our emails is focused on sending only communications that you have asked to receive. If you prefer not to receive these emails, the emails themselves contain mechanisms to exercise your right of removal and waiver of the receipt of these messages, as per the provisions of Title III, Article 22 of Law 34/2002, on Services for the Information Society and Electronic Commerce.

For more information on Wiwink's code of ethics, click here.