Updated 12th Sep, 2019
Data Protection & Information Security
It also applies to each Administrative User and End User whose employer has subscribed to Pattyrn pursuant to the Agreement; your employer is responsible for obtaining your consent to this policy and is your Data Controller jointly with WNDYR.
Data Controller (WNDYR Personnel), EU Representative, Data Protection Officer
Data Controller (WNDYR Personnel)
Where you apply to or do join the WNDYR personnel team or as an End User subscribe to Pattyrn (whether contracting with Pattyrn directly or through your employer as Subscriber), 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:
Reg no. 821252534
2021 McKinney Ave, Suite 430, Dallas, TX 75201
When you subscribe to Pattyrn (or your employer does on your behalf), you consent to our retention of your business details and activities on the platforms you use for the purpose of our providing Pattyrn Services. We shall hold this Personal Data as Data Controller in accordance with this Policy and otherwise for legitimate purposes pursuant to GDPR.
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
Office address: Suite 55, 20 Harcourt Street, Dublin 2 Co Dublin, Republic of Ireland
Tel: +35386 1407872
Data Protection Officer
WNDYR’s data protection officer can be contacted as follows:
Tel: +353 (0)86 140 7872 and ask for the DPO.
Purpose of the Processing and the Legal Basis for the Processing
We gather Personal Data when you:
We collect information from you when you subscribe to Pattyrn or otherwise contact us.
This information will only be used by us in accordance with the terms herein, to enable us to contact you, discuss what package would be right for you and in order to provide the agreed Pattyrn Services. The provision of your Personal Data is voluntary. However, if you do not provide us with the required Personal Data (name, email address and company name if applicable), we may not be able to provide you or your employer with the agreed Services.
Apply to Join the WNDYR (Pattyrn) Team
Where you provide your Personal Data to us as a prospective or current member of the WNDYR team, this enables WNDYR to fulfil its contractual obligations to you and/or is necessary for legitimate purposes. You will receive GDPR training and be asked to agree appropriate provisions in your contract.
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 some of information that can be found on a business card: first name, last name, employer name and work email.
How We Collect It
We collect your Personal Data when you decide to contact us or you subscribe to Pattyrn (or your employer does and has obtained your consent to use your Personal data for the purposes of enabling us to fulfil our contractual obligations).
What We Use Your Personal Data For
We use for Personal Data for very limited purposes:
- To respond to your enquiries or comments
- Send periodic emails when you Contact Us through this website or provide consent to the organizer 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.
- In addition, in order to carry out our lawful activities and for legitimate purposes, we may collect and process your Personal Data to:
- Provide the Pattyrn Services to you as Subscriber or to your employer where it has subscribed to Pattyrn Services
- We may post your avatar on a public accessible site in order to provide the Pattyrn service to you or to your employer
- Retain a record of incoming and outgoing communications (e.g. email).
- For billing, account management and other administrative matters. WNDYR may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
- 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
- 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; 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.
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 you would like to unsubscribe from receiving future communications, we include detailed unsubscribe instructions at the bottom of each communication.
You may terminate your Subscription to Pattyrn Services as the Agreement provides.
If the Subscriber is your employer, you must also contact it to discuss how use of your Personal Data for the Pattyrn Services may be terminated.
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 https://pattyrn.com/legal
If you wish to confirm that WNDYR is processing your Personal Data, or to have access to the Personal Data WNDYR may have about you, please contact us at https://pattyrn.com/legal
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 you or your employer as the Customer Product & Services Agreement provides or for a legitimate or other lawful purpose, you have a right to consent or object to such collection for the intended purposes. In respect of each such intended purpose where consent is required 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.
The Right to Lodge a Complaint with a Supervisory Authority
If 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 email@example.com
You may use this form:
Please copy any such communication to us so that we can work to resolve any outstanding issues promptly.
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 Terms and Conditions, 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.
Transferring Personal Data to the US or EU
The personal information WNDYR collects from you is stored in one or more databases hosted by third parties located in the United States. These third parties do not use or have access to your personal information for any purpose other than cloud storage and retrieval.
Security of your Personal Data
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. Given the nature of communications and information processing technology, Pattyrn cannot guarantee that Information, during transmission through the internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others. Pattyrn supports logins using two-factor authentication (“2FA”), which is known to reduce the risk of unauthorized use of or access to the Services. WNDYR therefore will not be responsible for any damages, losses or liability to Subscriber, Administrative Users,End Users or anyone else if any event leading to such damages, losses or liability would have been prevented by the use of 2FA.
If you believe you have found a security vulnerability on Pattyrn, please let us know straight away. We will investigate all reports and do our best to fix valid issues quickly.
We shall retain and store your Personal Data securely and for as long as necessary in order to meet our contractual obligations to you (or to your employer where it is Subscriber and has not required us to delete your own Personal Details as its employee). We retain personal data for up to 12 months after termination of the Agreement (unless expressly requested to delete the same in case an Agreement is re-commenced at Subscriber’s request. 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 https://pattyrn.com/legal.
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If your use of Pattyrn in through your employer which is our subscriber, in the first instance please direct any queries to your employer.