Privacy Policy

Last updated: 23rd April, 2018.

This Privacy Policy applies to the websites: “autochart.io”, “portal.autochart.io” and “support.autochart.io” (the “Websites”) and also to the Tracking API related to the Autochart hosted service which is owned and operated by Winter Wind Software Ltd (collectively, “Autochart”, “we”, “us”, or “our”). This Privacy Policy describes how Winter Wind Software collects, uses, shares and secures the personal information provided to us by our customers or prospective customers, as well as the data transferred to us for processing on behalf of our customers. It also describes your choices regarding use, access and correction of your personal information.

What user data does the Autochart service collect/process?

We collect/process 2 broad categories of user data:

  1. Direct Customer Data – provided directly to us by a customer or prospective customer. This is data that we are considered to be the “Data Controller” for, under GDPR terminology.
  2. Customers’ Users’ Data – sent to the Autochart API from our customer’s website visitors which we process on their behalf to deliver our lead management and content personalisation services. This is data that we are considered to be the “Data Processor” for, under GDPR terminology.

The specific data points related to each category are detailed in the following sub-sections.

Direct Customer Data

The above data fields are used for the following purposes:

Winter Wind Software and its partners use cookies or similar technologies to analyse trends, administer the website, track user activity on our websites, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

Our Customers’ Website Visitor Data

All of the data below is captured only on the customer website where Autochart lead tracking script is installed. Tracking of user activity on third-party websites (e.g. via use of third-party cookies) is not performed.

The above data fields are used for the following purposes:

We act as a data processor for our customers’ data which is sent to us via the Autochart Tracking API. We have no direct relationship with the individuals whose personal data we host as part of the Autochart service. Each customer is responsible for providing notice to its own users concerning the purpose for which they collect their personal data and how this data is processed in or through the Autochart service.

Information Sharing

1. Service Providers

We may share your information with third parties who provide services on our behalf to help with our business activities. These companies are authorised to use your personal information only as necessary to provide these services to us, to which these services may include:

We may disclose personal data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

We also reserve the right to disclose personal data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Autochart service and any facilities or equipment used to make the service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.

How we protect your information

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. We ensure that all source code, files and data remain private and confidential. We restrict access to personal information to Winter Wind Software employees, contractors and agents who need to know that information in order to operate, develop or improve our service. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

If you have any questions about the security of your personal information, you can contact us at the contact information below. We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.

Data Access Requests

Upon request, we will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by contacting us at the contact information below. We will respond to your request within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.

We acknowledge that you have the right to access your personal information. We have no direct relationship with the individuals whose personal data is processed by the Autochart service. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to Winter Wind Software’s customer (the data controller). If we are subsequently requested to remove data by our customer, we will respond within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.

Changes to our Privacy Policy

If we decide to change our privacy policy, we will post those changes on this page, send an email notifying you of any changes, and/or update the Privacy Policy modification date above. We encourage you to periodically review this page for the latest information on our privacy practices.

Contacting Us

If there are any questions or feedback regarding this privacy policy you may contact us at support@autochart.io.