Privacy | Willow360

DATE OF LAST REVISION: MAY 2023

Supplemental Privacy Statements

What this Policy Covers
This Privacy Policy describes how Info Technology Supply Ltd, a company incorporated in England and Wales under number 2230502 whose registered office is at 2 Hobbs House, Harrovian Business Village, Bessborough Road, Harrow, HA1 3EX, United Kingdom trading as Willow360 and authorised resellers who may contract with a customer (together "Willow360" and affiliated entities ("We") collect, use, process and share your personally identifiable information. This Policy describes your choices regarding any applicable rights of access, deletion, and correction of your personal information. It forms part of our Terms of Service and is expressly incorporated in the Terms. Where we refer to “information” in this Privacy Policy, it means any information that relates to an identified person.
This Privacy Policy sets out your rights and provides information to which you are entitled under applicable data protection legislation including UK legislation known as UK GDPR and the Data Protection Act 2018 as amended in the UK and GDPR in the EU.
This Privacy Policy applies to use of data from or connected to our websites willow360.com, and eu.willow360.com and any other website that links to this Policy (the “Site”). This Privacy Policy also applies to the information that we collect through the services we offer (Willow360 services, we refer to as “Services”), through marketing and customer engagement, branded social media pages.
This Privacy Policy does not apply to the information we collect about our employees (our employment policies apply to this instead ) nor job applicants. This Privacy Policy also does not apply to information collected by third parties, such as third-party websites, social media platforms or accounts, third-party service providers or other third-party services or applications that integrate with our Services. This Privacy Policy also does not apply to any information that is not personally identifiable, like aggregated or anonymous information.
We may update this Privacy Policy from time to time and provide notice to you as described below in the section titled “Notice of Changes.”
Our Services are not directed at children under the age of 16 and we do not knowingly collect information from individuals under the age of 16. If you are under the age of 16, you may not use the Services nor provide your information to us through the Site or otherwise.
If you are a citizen of Switzerland, the United Kingdom or a country in the European Economic Area, we describe additional rights you may have in the European Privacy Rights statement. If you are a Californian resident, we describe additional rights you may have in the Californian Privacy Rights statement.

Personal Information We Collect
We collect or receive information in the ways we describe in this section.
Categories of Information We Collect

Information You Provide Us
When You Create an Account
Content or Information You Provide in the Services
Content You Provide Through Our Site
Support Channels
Marketing Information
Partner Program
Payment Processing Information
Technical, Device, and Connection Information
Cookies and Other Tracking Technology
Other Information Sources

Information You Provide Us
When you sign up to create an account in the Service, or respond to communications, you provide us with information like your name, email address, address, company, telephone number or other information. When you register as a partner, we collect account registration information like your name, email address, address, company, telephone number or other information. You may provide comments, communications, feedback, ratings or other information when you use the Services.

When You Create an Account
When you create an account, you provide us with your account registration and profile information (name, email address, company and similar information). We may automatically track certain information about your use of the Services. We may collect information about you when you login and how you interact with the Services, the features you use, clicks, log information about your use of the Services and how you interact with other users. We describe the information we collect through the Services in more detail in Willow360 Services Third Party Integration and Use of Data statement.

Content or Information You Provide in the Services
The Services allow you to create connections or integrations between the third-party applications you use. When you use the Services, information or content is transferred from one application to another application. We collect the information that is transferred between the third-party applications. We describe the information we collect through your use of the Services in more detail in the Willow360 Services - Third Party Integration and Use of Data statement. Other users may provide information about individuals when they submit content or information through the Services. Similarly, an administrator may provide your contact information if they designate you as a user, the billing contact, technical contact, or administrator. You or your administrator may integrate the Services with third-party applications. In such case, we will receive information that allows us to identify your account within the third-party applications (like name, email address, telephone number, tokens, or other identifying information), the log data, content, and device information. The information or content we receive from your organisation is subject to your organisation’s privacy policies. When you integrate our Services with a third-party application, the information we receive depends on the settings, permissions and privacy Statement controlled by that third-party application.

Content You Provide Through Our Site
If the Site or our social media platform pages allow you to upload content or information, we will collect the content or information you upload. For example, when you provide feedback, participate in any interactive features, surveys, contests, promotions, sweepstakes, activities, or events, you may provide us information or content.

Information You Provide Through Support Channels or Communities
You may provide information or content to us through the customer support or any chat functionality we make available on the Site, in the Services, or other sites that we control. When you engage with our support team, in addition to your account information, we may ask you to provide additional information about your issue, which may include information about your technology, software, internet connection, or screenshots.

Marketing Information
We receive information about you directly from you when you engage with the Site and automatically when you engage with the Site or open or click the emails, we send you (See Information You Provide Us and Cookies and Other Tracking Technology). We receive information from third-party sources like lead generation providers, content sponsors, event sponsors, or social media platforms. The information we collect from third-party sources including our resellers who may re-sell our Services to you, may include marketing or demographic information, contact information (name, email, company, address, job title), information about your profile on those platforms, or information about purchasing intent. We may combine this information with the information we collect.

Partner Programs
We have several partner programs that we make available such as our developer program (which allows third-party application providers to build integrations to Willow360). Partners may also help us to market and promote our Services, generate leads, or they may resell our Services. We may add partner programs in the future. Through partner programs, we collect account registration information (such as name, email address, company and telephone number), information about an individual’s technical skill set, comments, questions or feedback, rating or ranking information, images, content or other information you provide. We may also receive information from our partners (such as business contact information, address, job title, email address or telephone number). We will combine the information you provide and the information we receive with your account information.

Payment Processing Information
When you create a paid account within the Services or otherwise initiate a transaction with us including with our resellers, we or they will use a third-party payment processor to process the payment. We do not collect your credit card number, expiration date nor pin number. The transaction details we (including our resellers) retain are those details that allow us to verify that you paid for the Services or transaction, including price, currency, date of payment, payment method, name, and account name. We and/or our resellers will combine that information with your account information.

Technical, Device, and Connection Information
When you use the Services or interact with our Site, we automatically collect information about the device you use to access the Site or Services. When you interact with our branded social media sites, the social media platform automatically collects information and provides it to us. This information includes information that identifies you and connection type, settings, operating system, browser type, IP address, URLs of referring/exit pages, device identifiers and crash data.

Cookies and Other Tracking Technology
We use cookies, web beacons, pixels, or other tracking technology on the Site and in the Services to provide functionality, personalise your experience and recognise you across services or devices. This information includes internet protocol (IP) addresses, location, device type, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, click data, device-identifying data. We may combine this automatically collected information with other information that you provide us through other channels. You can learn more about our cookies in our Cookie Notice statement. When you interact with our social media sites, the social media platform automatically collects information and provides it to us.

Other Information Sources
We receive information about you from other sources like third-party service providers, public databases, and our business and channel partners. This information may include business contact information, address, job title, email address and/or telephone number. We may combine this information with information we collect through other means.

How We Use Personal Information We Collect
We use the information we collect for the following purposes:

to provide and support the Services
to improve the Services
to provide, support, and improve the Site, our partner programs
to process your requests
to process your payments or transactions
to provide you with information about our products and services
to combine information about you with other information we receive from third parties
to tailor the content or information that we provide to you
to protect the integrity or security of our business, the Site, Services or third-party applications, or we may also use your information to: carry out our obligations, enforce our rights, comply with any legal obligation (including assisting our customer to comply with their legal obligations), where it is necessary for our legitimate interests or to fulfil any other purpose for which you provided the information.

How We Share Personal Information
We may share information when one of the following circumstances applies:
With your Consent/Purposes: We may share your information with companies, organisations, and other third parties with your consent or to fulfil the purpose for which you provided the information.
With our Resellers/Partners: We may share information with our partners (including resellers, referral, integration partners, experts in our community, or developer platform partners) for the purposes of the agreement with them or to enable our partner programs.
To Provide the Services, Reseller/Partner Programs: We may share your information with your colleagues, account administrators, billing or technical account users. We will also share your information with third-party applications (at your direction or the direction of an account owner) when an account holder uses the Services. To deliver the Site, Services, partner programs or communities, we may share your information with our service providers. If you participate in our reseller/partner programs, we may share your information with other resellers/partners, or customers.
For Business Purposes: We provide information to vendors and services providers to help us provide the Site, Services, reseller/partner programs and communities and for our business purposes. Examples of our service providers include hosting or infrastructure providers, chat widgets, helpdesk ticket providers, website hosts, customer relationship management providers, email providers, collaboration tools and other service providers.
To Market our Services or Partner Programs: We may share information that you provide to us with third-party service providers who help us market our Services or our reseller/partner programs. These service providers may provide virtual or live events, email marketing tools, sales engagement or lead generation tools.
For Corporate Transactions: We may share personal data with actual or prospective acquirers, their representatives and other relevant participants in, or during negotiations of, any sale, merger, acquisition, restructuring, divestiture or change in control involving all or a portion of our business or assets, including in connection with a liquidation, administration or similar proceedings. If we undergo a sale or corporate restructure, we may disclose information to a buyer or other successor in interest.
For Legal Reasons: We may share your information if we believe that it is necessary or desirable to comply with any court order, law, legal obligation or legal process, including to respond to any government or regulatory request. We may share your information if we believe that it is necessary to enforce our rights (including, without limitation, our rights under the Terms of Service, Website Terms of Use, Acceptable Use Policy, or the Willow360 Integration Platform Agreement), or the rights of our customers or users. We may share your information if we believe that it is necessary or appropriate to protect our rights or safety or the rights or safety of our customers, other users, partners or service providers.
With Third-Party Widgets: If you click on a widget or social media feature, such as the Twitter “tweet” button or Facebook “like” button, these widgets will share information with the widget provider (such as your IP address, details of the webpage you are visiting on the Services and may set a cookie to enable the feature to function correctly).

Your Choices - Opting Out or Correcting Your Information
Automatically Collected Information: There are various resources available to you to manage cookies. In most modern browsers, you can block or delete cookies by clicking Settings > Privacy > Cookies. Instructions for blocking or deleting cookies in other browsers may be available in each browser’s privacy or help documentation. You can also disable or delete the stored data used by technology similar to cookies, such as Local Shared Objects or Flash cookies, by managing your browser’s “add-on settings” or visiting the website of its manufacturer. To find out more about cookies, including how to see what cookies are used and stored and how to manage and delete them, visit www.aboutcookies.org If you disable or refuse cookies, some parts of the Site or Service may then be inaccessible or not function properly. Please see our Cookie Notice statement for more information about cookies.
Our Marketing Activities: If we sent you a promotional email, you may opt-out by clicking the opt-out link at the bottom of the email. This-opt out does not apply to information necessary to deliver the Services nor reseller/ partner programs, such as your account information or notices we send about the Services’ operation. If you have an account in the Services, you can manage your communication preferences in the settings page of your account profile.
Services: You can review and change your personal information in the Services by logging into the Service and visiting your account profile page. You may also send us an email at privacy@willow360.com to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. You can manage your communication preferences within the settings page of your account profile.
Our Marketing Activities: If we sent you a promotional email, you may opt-out by clicking the opt-out link at the bottom of the email. This-opt out does not apply to information necessary to deliver the Services, or partner programs, like your account information or notices we send about the Services’ operation. If you have an account in the Services, you can manage your communication preferences in the settings page of your account profile.
Services. You can review and change your personal information in the Services by logging into the Service and visiting your account profile page. You may also send us an email at privacy@willow360.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. You can manage your communication preferences within the settings page of your account profile.

Data Security
Willow360 takes reasonable steps to protect your personal information from loss, misuse and unauthorised access, disclosure, alteration, or destruction, considering the risks involved in the processing and the nature of the personal data. However, no application, Internet, or email transmission is ever fully secure or error-free and we do not guarantee the security of any personal information. You are also responsible for ensuring that your account and the passwords we provide you are protected. We advise all users to back up their data.

Data Storage, Retention and International Data Transfers
Information that we collect from the Site will be exported from various countries including the UK and transferred to and processed in the European Union and in any other country where Willow360 or its affiliates, subsidiaries or third party service providers maintain facilities or personnel. These countries may have data protection laws that are different from the laws of your country (and, in some cases, may not be as protective). We follow applicable data protection laws when transferring personal data. If you are resident in or a visitor from the EEA, United Kingdom or Switzerland, we will protect your Personal Information when it is transferred outside of such locations by processing it in a territory which the European Commission or UK have determined provides an adequate level of protection for Personal Information; or otherwise implementing appropriate safeguards to protect your Personal Information, including through the use of Standard Contractual Clauses or another lawful transfer mechanism approved by the European Commission and/or the United Kingdom.
For data transfers and storage of information we collect from your use of the Services, please refer to the detail in the Willow360 Services statement.
We keep your data for the data retention periods set out in our Data Privacy at Willow360 document, available on our Site. That document also sets out the sub processors including third party sub processors we currently use to process personal data.

Dispute Resolution
You may direct any questions or complaints about this Privacy Policy to us by contacting us through the channels indicated in the Contacting Willow360 section below. Residents of the EEA and Switzerland may file a complaint with a data protection authority in their country and those in the UK may file a complaint with the UK Information Commissioner. The data protection authority will in most cases require you first to attempt to resolve any complaint with us; please see Contacting Willow360 below to file a complaint with Willow360.
Any disputes arising out of or related to this Privacy Policy will be subject to English law and jurisdiction. In the case of our customers or their users this is stated in our Terms of Service or users of our developer integration platform, the Willow360 Integration Platform Agreement. In the case of visitors to the Site, that means English law and jurisdiction as our Website Terms of Use.

Notice of Changes
The Services, the Site and our business may change from time to time. As a result, we may make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time. If we make changes to this Privacy Policy, we will post the changes on this page and will indicate at the top of this page the date these terms were last revised. If we make material changes, we will notify you through the Services user interface, as a pop up on the Site, in an email notification or through other reasonable means. Your continued use of the Site or Services after the date any such notice constitutes your acceptance of the modifications.

Contacting Willow360
If you have any questions or comments about this notice, how we collect and use your information, your choices, or rights regarding such use or wish to exercise your rights, please do not hesitate to contact us at:

Email: privacy@willow360.com
Postal Address:
Attn: Willow360/Privacy
Info Technology Supply Ltd.
2 Hobbs House, Bessborough Road, Harrow, Middlesex, HA1 3EX, UK

Company no. 2230502

Change Log
Date of Change: May 2023
Description of Change: V2