Introduction

This page describes how the personal data of users (the “Users”) of the website https://www.wethod.com/ (the “Site”) and of the online platform, accessible by logging in to the same website in order to use Wethod’s SaaS services (the “Platform”), is processed.

The information on this page does not apply to third-party websites, apps and content in general, even if accessible from the Site. In such cases, the data protection provisions of those third parties may apply; these may differ from the present ones, and we recommend that you consult them before communicating any data.

1 Controller and Controller’s contact details

The data controller is Wethod S.r.l., an innovative start-up operating in the project management sector and, in particular, in the development of IT systems to facilitate, simplify and manage project activities and human resources.

WETHOD S.R.L., with registered office in Roncade (TV), 31056, Via Sile n. 41, Tax Code and VAT No. 04732090263 (hereinafter “Wethod”, the “Company” or the “Controller”).

If you have any questions about how the Company processes personal data, you may contact it at any time:

• by e-mail at info@wethod.com
• by post at Via Sile n. 41, 31056, Roncade (TV), Italy.

2 Methods of data collection and categories of data processed

Browsing data collected automatically by the Site: access and browsing data

Whenever Users access the Site, the IT systems and software procedures responsible for the operation of the Site acquire, in the course of their normal operation, access and browsing data (for example: IP addresses or domain names of the computers used by Users, the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server and other parameters relating to the User’s operating system and IT environment – the “Browsing Data”).

Data communicated by Users to contact the Controller: personal details, contact details and personal data voluntarily provided by Users

Through the Site it is possible to get in touch with Wethod by (i) entering one’s e-mail address in the “Email us” section of the Site; (ii) entering one’s e-mail address to obtain a demo version of the software that runs the Platform; and/or (ii) using the “Chatbot” function available on every page of the Site, in order to request information or clarification regarding the services offered through the Platform. The only data requested are the User’s e-mail address and any data voluntarily communicated in the message accompanying the e-mail and/or in the chatbot message.

Pursuant to Article 14 of the GDPR, please also note that, where Wethod is contacted via social networks, the Request Data may also be provided through such social networks; in this case, the party transmitting the Data to us will be the company that owns the social network concerned, which processes users’ personal data in accordance with the information available on its website.

The provision of such data is voluntary: if Users do not provide them, they may still browse the Site but will not be able to receive a response to their requests or obtain the information or clarification they wish to receive from Wethod.

Users are asked not to communicate personal data of third parties unless this is necessary (for example, because the User who wishes to obtain information from Wethod does not have his or her own e-mail address or any other direct contact details): in such a case, please remember that it is the User’s responsibility to comply with the legal obligations relating to the protection of personal data and, in particular, to inform the third parties of the communication and, where appropriate, to obtain their consent.

Data communicated by Users to create a Wethod Account: personal details and contact details

In the “Try it now” section of the Site, it is possible to begin the registration process for the Platform, during which the User is asked, after accepting the SaaS Licence Terms and Conditions and this privacy policy, to provide specific personal data: first name, surname, e-mail address and team name, where applicable. In particular, such data are requested in order to register an account giving access to a reserved area through which it is possible to use the services (the “SaaS Services”) relating to the use of the Platform. Without prejudice to the foregoing, the SaaS Services will furthermore be available to the User subject to entering his or her credit card details and paying for the chosen subscription plan – with the exception of the free subscription – in accordance with the SaaS Licence Terms and Conditions.

The provision of such data is voluntary: if Users do not provide them, they may still browse the Site but will not benefit from the functionalities of that area or from the SaaS Services. Furthermore, such data are collected only if, to the extent that and in the manner in which they are communicated by the Users themselves.

Users are asked not to communicate personal data of third parties unless this is necessary (for example, because the User who wishes to access the reserved area does not have his or her own e-mail address or any other direct contact details): in such a case, please remember that it is the User’s responsibility to comply with the legal obligations relating to the protection of personal data and, in particular, to inform the third parties of the communication and, where appropriate, to obtain their consent.

Data communicated by Users to receive the newsletter: e-mail address

Users may subscribe to Wethod’s newsletter service by entering their e-mail address in the relevant box in the footer of the Site. In particular, such data are requested in order to enable the User to benefit from this service and, therefore, to receive by e-mail updates on the functionalities and features of the Platform and on the SaaS Services.

Tracking pixels in e-mails (Web Beacons / Tracking Pixels)

In our newsletters (via Brevo), commercial e-mails (via Pipedrive) and support messages (via Intercom), we use statistical tracking systems known as “tracking pixels”. These are fragments of code or small transparent images (1x1 pixel) embedded in e-mails. They allow us to detect whether a communication has been opened, the time it was opened, the IP address, the type of device and the e-mail client used by the recipient.

The provision of such data is necessary: any refusal will make it impossible for Wethod to send the newsletter to the User.

(The data referred to in the preceding paragraphs are hereinafter jointly referred to as the “Data”)

3 Purposes and legal basis of the processing

The Browsing Data will be used: (i) to monitor the correct functioning of the Site; (ii) in anonymous and aggregated form, for statistical purposes connected with understanding how the Site is used by Users, in order to improve its ease of access and increase its attractiveness; and (iii) to detect any technical problems as soon as possible.

The legal basis for such processing is the Controller’s legitimate interest in improving its digital services, which is compatible with the position of the data subjects since: (a) monitoring the functioning of the Site and the statistical data relating to its use do not entail direct identification; and (b) the Company’s interest can reasonably be considered to be shared by the Users as well, who will thus be able to enjoy an increasingly high-performing and optimised Site.

The Data communicated to contact Wethod will be used to respond to the requests made by Users and/or to provide the demo version of the software that runs the Platform.

The legal basis for such processing is the need to take pre-contractual steps (e.g. responding to specific requests for clarification regarding the SaaS Services) at the specific request of the User.

The Data communicated to create the account will be used to enable the creation of a User account, which gives access to a reserved area through which the User can use Wethod’s SaaS Services. Please note that the e-mail address forming part of the Account Data will also be used to send information exclusively on the progress, updates and operational functionalities of Wethod’s SaaS Services.

The legal basis for such processing is the need to perform a contract to which the User is a party (i.e. the SaaS Licence Terms and Conditions).

The Data communicated to receive the newsletter will be used to send the User e-mails about updates on the functionalities and features of the Platform and on the SaaS Services, as well as on Wethod’s activities, so that the User can assess the opportunities offered by the Platform over time.

The legal basis for such processing is the need to take pre-contractual steps at the specific request of the User. The newsletter service may be disabled by its recipient at any time by clicking the “UNSUBSCRIBE” button.

Statistical tracking of e-mails

The data collected through tracking pixels are used solely to analyse the effectiveness of our communications and to optimise their content.

• Legal basis: processing for marketing and sales purposes (Brevo and Pipedrive) is based on the user’s explicit and optional consent, which may be withdrawn at any time via the preference management link in the e-mails. Tracking of technical support e-mails (Intercom) sent to active customers is based on the Controller’s legitimate interest in providing the service and ensuring IT security.

4 Recipients of the Data

The Data will be communicated to, and may be accessed by, (i) employees and collaborators of the Controller, duly instructed regarding the processing; and (ii) third parties, specifically appointed as processors (or sub-processors), who provide services ancillary or instrumental to the Controller’s activities in relation to the development, provision and operational management of the Site, the reserved area and the SaaS Services.

5 Place of processing and transfer of Data abroad

The User’s Data will be processed at the Company’s registered office indicated above, and the Data will be stored on servers located within the European Union.

Any further transfers of Data abroad to countries that do not benefit from an adequacy decision of the European Commission and, therefore, do not offer an adequate level of protection for personal data, will take place only (i) subject to the adoption of appropriate safeguards such as, by way of example, the signing of the standard contractual clauses approved by the European Commission; or (ii) where a derogation from the prohibition on transfers outside the European Union applies and, therefore, again by way of example, subject to obtaining the User’s explicit and informed consent, or only to the extent necessary for the performance of a contract concluded between the User and the Company, or between the Company and a third party for the benefit of the User, or for the implementation of pre-contractual measures taken at the User’s request.

6 Methods of processing, security measures and Data retention period

The Data will be processed both in paper form and by electronic, IT or automated means, using systems that ensure their protection, security and confidentiality. Furthermore, the Controller has adopted specific and appropriate logical, legal, organisational and technical security measures to prevent the loss of the Data, their unlawful or unauthorised use and unauthorised access.

Browsing Data – which do not allow the identification of Users – are not kept for more than 7 days and are deleted immediately after being aggregated (save where required by the competent Judicial Authority for the investigation of criminal offences). Data used to respond to Users’ requests will be retained for up to 12 months after receipt of the request.

Data used to respond to the User’s request to register on the Platform and use Wethod’s SaaS Services will be retained for the entire duration of the contractual relationship and for the limitation period provided for by the applicable legal provisions.

Data communicated to receive the newsletter will be retained and processed for up to 24 months from subscription.

The Data will be retained for longer periods where necessary to fulfil statutory and/or legal obligations, as well as to ensure the legal protection of the Company’s rights, in compliance with the ordinary limitation periods.

7 User rights

Users, as data subjects (i.e. the persons to whom the Data relate), hold the rights conferred by the GDPR. In particular, pursuant to Articles 15-23 of the GDPR, data subjects have the right to request and obtain, at any time, access to their personal data, information on the processing carried out, the rectification and/or updating of their personal data, erasure and restriction of processing. They also have the right to object to processing and to request data portability (i.e. to receive their personal data in a structured, commonly used and machine-readable format). Finally, data subjects always have the right to withdraw their consent – where given – at any time (this will in any event not affect the lawfulness of processing carried out on the basis of consent given prior to its withdrawal) and to lodge a complaint with the supervisory authority (in Italy: the Italian Data Protection Authority, Garante per la protezione dei dati personali)

The above rights may be exercised at any time by simple request to the Controller, to be sent:

• by e-mail to info@wethod.com
• by post to Via Sile n. 41, 31056, Roncade (TV), Italy.

For further information or clarification regarding the rights mentioned above, the Controller may be contacted using the same contact details.

8 Cookie policy

The specific purpose of this Cookie Policy is to:

• explain the types of cookies used on the Site and the Platform, and how they are used; and
• provide Users with guidance on the steps to take to refuse or delete such cookies, should they so wish.

Cookies are small text strings that the websites visited send to the browser on the Users’ device, where they are stored and then sent back to the same websites the next time the Users visit them. This serves to make the internet browsing experience smoother and more personalised.

While browsing a website, Users may receive “first-party” cookies on their device, when these are managed directly by the owner and/or operator of the website, as well as cookies sent by different websites or web servers (so-called “third-party” cookies); this happens because the website visited may contain elements that reside on servers other than the one hosting the Site, set by a website other than the one currently being visited.

Depending on the purposes actually pursued by the controller, cookies may be (a) technical; (b) analytical; and (c) profiling cookies.

(a) Technical cookies

What are they?

Technical cookies are used solely for the purpose of carrying out the transmission of a communication over an electronic communications network, or to the extent strictly necessary for the provider of an information society service to provide a service explicitly requested by the user. The use of session cookies, which are not stored persistently on the user’s computer and are deleted when the browser is closed, is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow safe and efficient browsing of the Site; this makes it possible, for example, to use a service or to log in to access restricted areas.

Users’ prior consent is not required for the installation of such cookies.

Which technical cookies are used on the Site?

The Site uses the following technical cookies:

(b) Analytical cookies (so-called analytics)

What are they?

Analytical cookies are those cookies used to collect information, analyse and measure – in aggregate form – the number of Users and how they visit the Site. These cookies do not collect personal data, but exclusively anonymous and/or aggregated data, which is in any event not shared with third parties.

Which analytical cookies are used on the Site?

The Site uses the following first-party analytical cookies.

(c)Profiling cookies

What are they?

Profiling cookies make it possible to create a profile of Users based on their browsing experience and habits on the Site. In this way, advertising targeted to their interests can be provided instead of generic advertising.

Which profiling cookies are used on the Site?

The Site does not use first-party profiling cookies.

However, please note that the Site uses the following third-party profiling cookies:

We use Hotjar to better understand our users’ needs and to optimise the service provided by this website. Using Hotjar’s technology, we gain a better understanding of our users’ experiences (e.g. how much time users spend on which pages, which links they click on, what they like and dislike, etc.), which helps us to align our services with their feedback. Hotjar uses cookies and other technologies to collect information on the behaviour of our users and their devices.

Personal data collected: device IP address (recorded and stored only in anonymised form), screen size, device type (Unique Device Identifiers), information on the browser used, location (country only), preferred language for displaying our website. Hotjar stores this information in a pseudonymised user profile. The information will not be used by Hotjar or by us to identify individual users or to be combined with other data on individual users.

Place of processing: Ireland, Amazon Web Services infrastructure – Privacy Policy.

You may object to the storage of a user profile and of information relating to your visit to our website by Hotjar, as well as to the setting of Hotjar tracking cookies on other websites, by clicking on this opt-out link.

Finally, please note that the so-called social buttons on the Site’s home page are merely simple links to the relevant external social media pages, which do not install cookies.

(d) Whether the provision of data by users is mandatory

Users authorise the use of cookies by continuing to browse after reading the banner displayed on the home page. The provision of data is optional.

Cookie preferences may be changed at any time by means of specific browser settings, in accordance with the specific procedures described below. Browser preferences can also be used to delete cookies installed in the past, including any cookie in which consent to the installation of cookies by the Site may have been saved.

Should the User decide to disable cookies, they will not have access to many features that make the Site more efficient, and some of the Company’s services accessible via the Site will not function correctly.

With regard to third-party cookies, the User may also exercise their right to object to processing by consulting the third party’s privacy policy, via the opt-out link if explicitly provided in the aforementioned privacy policy or cookie policy, or by contacting the third party directly.

(e) Options regarding the use of cookies

Cookies can be controlled through the settings of the browser used. As each browser has different functions, the User should check the “help” menu of their browser to understand how to change cookie settings correctly. The User can then change the browser settings so that cookies are deleted or are not saved on their computer or mobile device without their explicit consent. The following links will help the User better understand how to configure their browser:

• Internet Explorer: https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-mana ge-cookies
• Mozilla-Firefox: https://support.mozilla.com/en-US/kb/cookies-information-websites-store-on-your-com puter#w_cookie-settings
• Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
• Safari: http://support.apple.com/kb/PH504

For further information on cookies, the User can always visit www.allaboutcookies.org

9 API

The Platform uses the Google Maps APIs to improve the User experience. For further information, please consult Google’s Privacy Policy.

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The Controller may amend this privacy notice to reflect future expansions of or changes to the Site.