Website User Privacy Policy

Updated 28 January 2022

Pattyrn is a product brand wholly owned by WNDYR, Inc., a Delaware C corporation. This Privacy Policy applies to your use of this website and any contact made by you with WNDYR through it. It is part of the User Terms to which you agree. When you subscribe to Pattyrn, you will be invited to read a more detailed privacy policy and subscription terms of use. Please see our Cookies Policy too.

This Privacy Policy applies to your use of this website and all WNDYR processing of Personal Data where you have contacted WNDYR; WNDYR is the Data Controller in respect of your Personal Data in these circumstances.

Our website, products and services are all directed to people who are at least 18 years old or older. If you are under 18 years of age, you must first ask a parent or guardian to read and explain these terms, our Privacy Policies and PSA Terms.

Introduction
Data Controller (WNDYR personnel), EU Representative, Data Protection Officer, a Processor (deployments and services)
Purpose of the Processing and the Legal Basis for the Processing
What categories of Personal Data we collect, how we collect and use (process) it and for what purpose(s)
Your Rights
Questions, Concerns and Complaint with a Supervisory Authority
Disclosure of Personal Data
Transferring Personal Data from the EU to the US
Security of Personal Data
Retention
Terms of Use of this Website and Cookies
Changes and Updates to this Privacy Policy
Contacting Us

1. Introduction

We recognize the importance of protecting the privacy of Personal Data or personally identifiable information, being information which relates to an identifiable individual (“Personal Data”). We respect the rights of such individuals whose Personal Data we process and the obligations imposed by applicable law and are committed to protecting your privacy in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679 (“GDPR”) as implemented in UK, the ePrivacy Directive and other applicable law, (the “Data Protection Acts”) and Statutory Instrument 336 of 2011 - European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011. The following Privacy Policy discloses what information we gather, how we use it, and how to correct or change it.

WNDYR complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. WNDYR has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

We reserve the right, in our sole discretion, to modify, alter or update our Privacy Policy at any time. Such modifications, alterations, and updates shall be effective immediately upon posting. Your continued use of this website following the posting of a modified, altered, or updated Privacy Policy will mean you accept those modifications, alterations or updates.

2. Data Controller (WNDYR Personnel), EU Representative, Data Protection Officer

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
WNDYR Inc, c/o EEPB, 2950 North Loop West Suite 1200, Houston, TX ,77092
General info email - admin@wndyr.com

Similarly, when you contact us through this website by way of a general enquiry, in order to find out more about Pattyrn (or other WNDYR products and services) or request a demo, you consent to our retention of your email address and name for the purpose of responding to your enquiry. We shall hold this personal data as Data Controller in accordance with this Policy and otherwise for legitimate purposes within GDPR.

Please note that the transmission of your Personal Data in response to the Contact Us form will be un-encrypted.

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

Office address: Suite 55, 20 Harcourt Street, Dublin 2 Co Dublin, Republic of Ireland
Tel: +35386 1407872
Email:accounts@wndyr.com or trudy@wndyr.com

Data Protection Officer

WNDYR’s data protection officer can be contacted as follows:
DPO@wndyr.com
Tel: +353 (0)86 140 7872 and ask for the DPO.

3. Purpose of the Processing and the Legal Basis for the Processing

We gather Personal Data when you: 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 “Request a Demo” 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. 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 further information.

Subscribe to Pattyrn

When you or your employer contracts with us in respect of Pattyrn, a more detailed Subscriber Privacy Policy and User Terms will apply.

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 a more detailed Privacy Policy which is an important part of that training.

4. What Categories of Personal Data We collect, How We Collect and Use (process) it and for What Purpose(s)

How We Collect It

We collect your Personal Data as this Privacy Policy when you decide to contact us.

What We Use Your Personal Data For

We use for personal data submitted through this website for very limited purposes:

To respond to your enquiries or comments submitted through our website
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. You may also receive mail outs as a customer (or employee of a customer) of WNDYR. You may opt out of such communications at any time
Notify you about important news or blogs concerning our products, industry updates, events, promotions and competitions, reports and other information
Anonymise Personal Data for our own lawful uses
In addition, in order to carry out our lawful activities and for legitimate purposes, we may collect and process your Personal Data to 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
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.

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 accounts@wndyr.com or DPO@wndyr.com.

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 accounts@wndyr.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 you or your employer 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.

6. Questions, Concerns, Complaints

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: info@dataprotection.ie. 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: accounts@wndyr.com and copy to trudy@wndyr.com

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 and non-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 disclose your Personal Data within the WNDYR group, to your employer with whom you are contracted (where applicable), professional advisers, and to such other third parties as may reasonably be required in connection with the purposes referred to in this Privacy Policy, such as operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. Where we are a Data Processor processing Personal Data at the instruction of a corporate Subscriber, we are nonetheless responsible to you for processing your Personal Data responsibly and safely as GDPR and Privacy Shield principles provide; we also take responsibility for our third party suppliers who process your Personal Data on our behalf and require them to have in place appropriate technical and organisational measures to protect your Personal Data. We reserve the right to disclose any and all pertinent information to law enforcement or other governmental officials as we, in our sole discretion, believe necessary or appropriate.

The disclosures of your Personal Data described in this Privacy Policy may, if you are outside of the European Economic Area (EEA), involve the transfer, storage or processing of your Personal Data to such country, where the level of data protection is not as high as in the EEA. By providing us with your Personal Data in such circumstances you agree to such transfers of your Personal Data. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.

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 User Terms, 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 from the 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.

The United States has not received a finding of “adequacy” from the European Union under Article 45 of the GDPR, though it has in place a Privacy Shield framework to protect personal data. WNDYR relies on derogations for specific situations as set forth in Article 49 of the GDPR and your US employer’s Privacy Shield (where applicable). In particular, WNDYR collects and transfers to the U.S. Personal Data only: with your consent; to perform a contract with you or your employer; or to fulfil a compelling legitimate interest of WNDYR in a manner that does not outweigh your rights and freedoms. WNDYR endeavors to apply suitable safeguards to protect the privacy and security of your Personal Data and to use it only consistent with your relationship with WNDYR and the practices described in this Privacy Policy. WNDYR also minimizes the risk to your rights and freedoms by not collecting or storing sensitive information about you. Where the transfer of Personal Data is through a third party processor, WNDYR has in place a Data Processing Agreement which protects your rights in compliance with EU law.

9. 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.

10. Retention Period

We shall retain and store your Personal Data securely and for as long as necessary in order to meet your requests having contacted us. 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 accounts@wndyr.com or DPO@wndyr.com.

11. Website User Terms and Cookies

Please also visit our Acceptable Use Policy and Website User Terms section establishing the use, disclaimers, and limitations of liability governing the use of our website at https://pattyrn.com/.

As is true of most other websites, the WNDYR website collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of the WNDYR website, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences. The WNDYR website also uses cookies and web beacons. It does not track users when they cross to third party websites, does not provide targeted advertising to them, and therefore does not respond to Do Not Track (DNT) signals.

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information. Cookies make web-surfing easier for you by saving your preferences so that we can use the saved information to facilitate your use of our website when you return to the website. The use of cookies is an industry standard, and as such, you will find that most major websites use them.

We use cookies to compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

Please see our Cookie Policy For More Detail.

12. Changes to our Website User Privacy Policy

If we decide to change our Privacy Policy, we will post those changes on this page. We reserve the right to amend the Privacy Policy and Terms of Use at any time, for any reason, without notice to you, other than the posting of the amended Privacy Policy and Terms of Use at this site. We may communicate periodic reminders of our notices and terms and conditions and will communicate material changes thereto, but you should check our site frequently to see the current Privacy Policy and Terms of Use that is in effect and any changes that may have been made to it.

13. Contacting Us

If there are any questions regarding this Privacy Policy you may contact us.