Last Updated: July 4, 2018
“Personal data” is information relating to an identified or identifiable natural person.
- Who We Are
- Personal Data We Collect and Use
- Third-Party Recipients of Personal Data
- Cookies and Similar Technologies
- Use and Transfer of Your Information Out of the EEA
- Children’s Privacy
- Retention of Personal Data
- Information Security
- Your Rights
- Data Controller and Data Protection Officer
- How to Contact Us
Wicket collects, uses and is responsible for certain personal data about you. Wicket operates a cloud-based software platform used by our clients to provide access to a website for authorized individuals, including their employees and customers. The use of information collected through this platform is strictly limited to the purpose of meeting our contractual obligations to our clients and providing the services requested by our clients, which are defined within our service agreements. The information we collect is done so at the direction of our clients and we have no direct relationship with their customers, the individuals whose personal data we process.
If you are located in the European Economic Area (“EEA”), we are regulated under the General Data Protection Regulation which applies across the European Union (including the United Kingdom) and we are responsible as controller of that personal data for the purposes of those laws.
(a) Personal data that is collected when you communicate with Wicket: Wicket may collect, use, and is responsible for certain personal data that you provide when you voluntarily sign up for emails, schedule a demonstration, comment on social media or blog posts, register and post in our forums, fill out any type of form or otherwise contact Wicket via email, telephone or online. The information collected may include your name, organization name, phone number, email address and organization size. Clients who engage Wicket may also provide additional personal or business information. You are not required to provide personally identifiable information to merely access or visit this website.
To improve client service, subject to applicable laws, we may also record and review your conversations with us, and analyze any feedback provided to us through voluntary surveys concerning our client service.
Purposes and Legal Grounds:
- We use this information to provide you with client and service support and to monitor the quality and types of client and service support we provide to our clients. The legal ground for processing this information for these purposes is Wicket’s legitimate interest in providing quality client and service support.
(b) If you choose to sign up for our newsletter or any other communication from us, we will use your contact information for purposes of sending you the information you have requested. Wicket may also use your email address and other contact information for the purpose of sending you electronic marketing communications. You will have the opportunity to opt out of receiving any such communications at the time we collect your contact information as well as through the unsubscribe link at the bottom of our marketing emails.
- Purposes and Legal Grounds:
- The legal ground for processing your email address and other contact information for this purpose is our legitimate interest in sending electronic marketing communications to clients concerning our services. If you do not initially opt out of receiving electronic marketing communication but subsequently decide that you no longer wish to receive electronic marketing communications, you will have the opportunity to opt out from receiving electronic marketing communications from Wicket at any time by clicking the unsubscribe link provided at the bottom of our marketing emails.
- The legal ground for processing your personal data for this purpose is Wicket’s legitimate interest in providing its clients with information they have requested and with electronic marketing communications that are likely to be of interest to them.
(c) Wicket also processes contact information of our clients’ members and contacts, on our clients’ behalf, to assist our clients and their members and contacts with their use and operation of their Wicket sites. We do not contact our clients’ members or contacts except as related to the operation of our clients’ Wicket sites (e.g., notifications and reminders, membership renewals, security, and other notifications).
- Purposes and Legal Grounds:
- The legal ground for processing the contact information of our clients’ members and contacts on behalf of our clients and for such communications purposes is based on our legitimate interest in providing quality support for our sites and services and assisting our clients and their members and contacts with their use and operation of their Wicket sites.
Wicket respects your privacy and will never sell, trade or transfer your personal data to third parties (beyond what is necessary for fulfilling a customer service, or for the basic functionality of an online service) without your consent.
We do, however, share your name and email address with our third-party suppliers. These third-party suppliers are contractually bound to use personal data we share with them only to perform the services we have engaged them to provide. Our current third-party suppliers include:
- G Suite
This data sharing allows us to provide services to our clients and manage Wicket. These third-party recipients are based outside the EEA — for further information including on how we safeguard your personal data when this occurs, see “Transfer of Your Information Out of the EEA”.
If you give Wicket your permission, it may also use personal identification information for internal or external marketing and promotional purposes.
On occasion, Wicket may collect personal identification information from you in connection with optional contests, special offers or promotions. Wicket will share such information with necessary third parties for the purpose of carrying out the contest, special offer or promotion. We will ask for your consent to such disclosure and use of such information, prior to your participation in the contest, special offer or promotion.
(b) Governmental entities and third parties: We may disclose personal data about you to governmental entities, such as regulatory agencies, law enforcement and judicial authorities, as well as other third parties under any of the following conditions: (a) if we have your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, legal process or other legal obligation; (c) to enforce any of our terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims.
We will not share your personal data with any other third party.
Website Analytics: To help analyze how you and other visitors navigate this site, compile aggregate statistics about site usage and response rates, help diagnose any problems with Wicket’s servers and administer the site, we, with assistance from third-party analytics service providers, such as Google Analytics, collect certain information when you visit our site. This information includes IP address, geographic location of the device, browser type, browser language, date and time of your request, time(s) of your visit(s), page views and page elements (e.g., links) that you click. We use this information to provide better, more relevant content on our site, to identify and fix any problems with our site, and to improve your overall experience on our site. Third-party service providers that collect this data on our behalf may offer information about their data collection practices, and in some cases, an opt out on their respective websites which you can access here: http://www.google.com/analytics/.
- If you do not want information collected through the use of these technologies, there is a procedure in most browsers that allows you to automatically decline many of these technologies, or to be given the choice of declining or accepting them.
- Legal Grounds: The legal ground for processing this personal data is our legitimate interest in understanding how our clients interact with our services and website so we can enhance the client experience and functionality of our services and website.
This website is operated in Canada and the third parties with whom we might share your personal data as explained above are also located in Canada, the United States or other countries located outside of the EEA. If you are located in the EEA or elsewhere outside of Canada, please be aware that any information you provide will be transferred to Canada and the United States. By using this website, participating in any of its services and/or providing your information, you consent to this transfer.
Whenever we transfer your personal data out of the EEA, we will ensure one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or
- We will ensure there is some other protection in place which has been approved by the European Commission as giving personal data the same protection it has in Europe.
If you would like further information, see “How to Contact Us” below.
Our site is not directed to individuals under the age of 16, and we request that individuals under 16 not provide personal data to Wicket. If we learn that we have collected personal data from a child under 16, we will take steps to delete the information as soon as possible.
We will retain your personal data for as long as necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting or reporting requirements.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
See section below under “Your Rights” for additional information pertaining to the right of erasure, as well as other data subject rights.
We implement appropriate technical and organizational measures designed to assist in: (i) maintaining the security and confidentiality of personal data; (ii) safeguarding against anticipated threats to the confidentiality, integrity and availability of personal data; and (iii) protecting your personal data against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure or access.
Whenever personal data is processed, however, there is a risk that such data could be lost, misused, modified, hacked, breached, and/or otherwise accessed by an unauthorized third party. No system or online transmission of data is completely secure. In addition to the technical and organizational measures that Wicket has in place to protect your personal data, you should use appropriate security measures to protect your personal data. If you believe that any information you provided to us is no longer secure, notify us immediately at firstname.lastname@example.org.
If you want to unsubscribe from receiving emails from Wicket, you may do so at any time. Each email from Wicket includes instructions for unsubscribing from these e-mail communications.
If you are covered by the General Data Protection Regulation, you have a number of important rights free of charge. In summary, those include rights to:
- Fair processing of information and transparency over how we use your use personal data;
- Access to your personal data;
- Require us to correct any mistakes in your information which we hold;
- Require the erasure of personal data concerning you in certain situations;
- Receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
- Object at any time to processing of personal data concerning you for direct marketing;
- Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
- Object in certain other situations to our continued processing of your personal data; and
- Otherwise restrict our processing of your personal data in certain circumstances.
You may also have the right to claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation, available at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ .
If you would like to exercise any of those rights, please email, call, or write to us at:
318 Richmond Road, 2nd Floor
Ottawa, ON, Canada
Tel: +1 (613)-234-5975
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
If your personal data was collected by and on behalf of Wicket (e.g., through our website), then such personal data is controlled by Wicket Inc. which is located at 318 Richmond Road, 2nd Floor, Ottawa, ON, K1Z 6X6, Canada and which you can contact by email at email@example.com. However, if your personal data was collected by or on behalf of a Wicket client, then such personal data is controlled by our client, with Wicket acting as a data processor.
318 Richmond Road, 2nd Floor
Ottawa, ON, Canada
Tel: +1 (613)-234-5975