Privacy Statement
This Privacy Statement applies to the processing of personal data by Windsor Group AG (“Windsor”, “we”, “us”) in connection with our website, platform, and related services (collectively, the “Services”). It describes what personal data we collect, why we collect it, how we use and share it, and what rights you have in relation to it. Windsor Group AG may also provide the Services on behalf of a licensor or partner (“Application Partner”), in which case that partner’s separate privacy policy may also apply. By using or otherwise accessing the Services, you acknowledge that you accept the practices and policies outlined in this Privacy Statement.
Windsor Group AG processes personal data in accordance with the Swiss Federal Act on Data Protection (“FADP”) and, where applicable, the EU General Data Protection Regulation (“GDPR”). The competent supervisory authority for data protection matters in Switzerland is the Federal Data Protection and Information Commissioner (“FDPIC”).
What data we collect
We collect the following types of information from our users:
Data you provide to us
We may receive and store any information you submit to the Services (or otherwise authorize us to obtain – such as, from (for example) your Facebook account). The types of personal data collected may include your full name, email address, gender, IP address, browser information, username, demographic information, and any other information necessary for us to provide the Services.
Legal basis: processing of this data is necessary for the performance of our contract with you to provide the Services.
Data we collect automatically
We receive and store certain types of usage-related information whenever you interact with the Services. For example, Windsor Group AG may automatically receive and record information regarding your computer’s IP address, browser information, Facebook user ID, Facebook Page fan status, and URLs accessed. Such information may be shared in aggregate (non-personally identifiable) form with our partners.
Legal basis: processing of this data is based on our legitimate interest in understanding how our Services are used and in improving them.
Email communications:
We may use the email addresses you provide during the signup to send you messages that are essential for your experience with our Services. This includes:
– Onboarding guidance to help you get started with the product
– Updates about new features, improvements, or changes to the service
– Newsletters and marketing communications — sent only to users who have provided explicit consent at the time of subscription
– Important notifications regarding your account or the Services
You may withdraw your consent and unsubscribe from newsletters and marketing communications at any time by following the unsubscribe instructions included in each email. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
Legal basis: service-related communications are sent on the basis of contract performance. Newsletters and marketing communications are sent on the basis of your consent.
How we use your data
Windsor Group AG uses the information described in this Privacy Statement (i) internally, to analyze, develop, and improve its products and services, and (ii) as set forth below in the “How we share your data” section below.
Legal basis: we process your data to perform our contract with you, to comply with legal obligations, and on the basis of our legitimate interest in maintaining and improving our Services.
Application partners
Windsor Group AG may provide personal information to the applicable Application Partner. The Application Partner’s use of your personal information is subject to the Application Partner’s separate privacy policy – and not this Privacy Statement. The Application Partner’s privacy policy is linked to from within the Partner’s Facebook application.
How we share your data
Personal information about our users is an integral part of our business. We neither rent nor sell your personal information to anyone (with the exception of sharing your information with an applicable Application Partner – see the “Application partners” section above). We share your personal information only as described below.
Application Partners: We will share your personal information with an applicable Application Partner (see the “Application partners” section above).
Service providers (data processors): We engage third-party service providers acting as data processors to perform tasks on our behalf and to help us operate and deliver our Services. These providers process personal data only on our documented instructions and are contractually bound to protect it in accordance with applicable data protection law, including the FADP and GDPR where applicable. They may not use personal data for any purpose other than providing services to us. We remain responsible for ensuring that any processor we engage provides sufficient guarantees as to the security and lawful handling of your personal data.
Legal basis: engagement of service providers is based on our legitimate interest in operating our Services and on the performance of our contract with you.
Business Transfers: In some cases, we may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that are transferred. Moreover, if Windsor Group AG, or substantially all of its assets, were acquired, or in the unlikely event that Windsor Group AG goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Windsor Group AG may continue to use your personal information as set forth in this policy.
Protection of Windsor Group AG and Others: We may release personal information when we believe in good faith that release is necessary to comply with the law; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Windsor Group AG, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
Legal basis: disclosures for legal compliance and fraud prevention are based on our legal obligations and our legitimate interest in protecting our business and users.
Windsor is a part of the team.blue Group and has a joint controllership with team.blue N.V. The team.blue Group, led by team.blue N.V., consisting of several brands and subsidiaries, can improve coordination and resource allocation by sharing data internally. This allows for more efficient collaboration on product, campaign, and customer service improvements. Customer data such as contact, user, billing, and purchase information may be shared with team.blue N.V for marketing statistics, internal administration, and reporting purposes, but only to the extent necessary for the intended use and with proper protective measures in place to prevent unauthorized access or disclosure.
We store your personal information for a period of time that is consistent with our business purposes.
We do not transfer or disclose your information to third parties for purposes other than the ones provided.
Compliance with Google API Services User Data Policy
Windsor.ai’s use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
We access Google user data only to provide or improve our services. We do not use this data for advertising, nor do we transfer it to third parties except as necessary to operate or improve the functionality of our services, in full compliance with Google’s policies.
We use encryption to protect your information.
Google Workspace APIs are not used to develop, improve, or train generalized/non-personalized AI and/or ML models.
Google Workspace & API Limited-Use Compliance
Windsor.ai’s use and transfer of information received from Google APIs fully complies with both the Google API Services User Data Policy and the Limited Use of user data requirements of the Google Workspace API User Data & Developer Policy.
– We access Google user data only to provide or improve features that are clearly visible in our user interface.
– We never use Google user data for advertising purposes.
– We never transfer Google user data to third parties except as necessary to operate or improve those features, comply with the law, or as part of a merger/acquisition.
– Human access to Google user data occurs only with the user’s explicit consent, to resolve security issues, or to meet legal obligations.
CONDITIONS OF USE
If you decide to use or otherwise access the Services, your use/access and any possible dispute over privacy are subject to this Privacy Statement and our Terms of Use, including limitations on damages, arbitration of disputes, and application of the law of Switzerland.
Third Party Applications/Websites
The Services may permit you to link to other applications or websites. Such third-party applications/websites are not under Windsor Group AG’s control, and such links do not constitute an endorsement by Windsor Group AG of those other applications/websites or the services offered through them. The privacy and security practices of such third-party applications/websites are not covered by this Privacy Statement, and Windsor Group AG is not responsible for the privacy or security practices or the content of such websites.
Accessing your personal data
Windsor Group AG allows you to access the following information about you for the purpose of viewing, and in certain situations, updating that information. This list may change in the event that the Services change.
– Account and user profile information
– User e-mail address, if applicable
– Facebook profile information, if applicable
– User preferences
– Application-specific data
Your data protection rights
Subject to applicable law, you have the following rights regarding your personal data:
– Right of access: You have the right to request confirmation of whether we process personal data about you and, if so, to receive a copy of that data.
– Right to rectification: You have the right to request correction of inaccurate or incomplete personal data we hold about you.
– Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you have withdrawn consent and there is no other legal basis for processing.
– Right to restriction: You have the right to request that we restrict the processing of your personal data in certain circumstances.
– Right to data portability: Where processing is based on your consent or a contract, you have the right to receive your personal data in a structured, commonly used and machine-readable format.
– Right to object: You have the right to object to processing based on our legitimate interests. You also have the right to object to direct marketing at any time.
– Right to withdraw consent: Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.
To exercise any of these rights, please contact us at [email protected]. We will respond to your request within the timeframes required by applicable law.
If you are located in Switzerland, you have the right to lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC) at www.edoeb.admin.ch. If you are located in the EU/EEA, you may lodge a complaint with your local data protection supervisory authority.
Can Children Use The Application?
Our site and the services available through Windsor Group AG are not intended for children under the age of 13. Windsor Group AG does not knowingly or specifically collect information about children under the age of 13 and believes that children of any age should get their parents’ consent before giving out any personal information. We encourage you to participate in your child’s web experience.
Changes To This Privacy Statement
Windsor Group AG may amend this Privacy Statement from time to time. Use of information we collect now is subject to the Privacy Statement in effect at the time such information is used. If we make changes in the way we use personal information, we will notify you by posting an announcement on our Site or sending you an email. Users are bound by any changes to the Privacy Statement when he or she use or otherwise access the Services after such changes have been first posted.
Data Retention
We retain your personal information for as long as necessary to provide you with our services and to comply with our legal obligations. This period may vary depending on the nature of the information and the purposes for which it is processed. Once personal information is no longer required, we will securely delete or anonymize it to prevent unauthorized access or use.
Retention And Deletion Of Google User Data
We retain Google user data only for as long as necessary to provide our services and fulfill the purposes outlined in this privacy policy, unless a longer retention period is required or permitted by law. Once the data is no longer needed, we will delete it or anonymize it in accordance with applicable laws.
Our application’s use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
If you wish to request the deletion of your Google user data, please contact us at [email protected], and we will respond to your request in accordance with applicable laws and regulations.
Questions Or Concerns
If you have any questions or concerns regarding privacy on our Website, please send us a detailed message at [email protected]. We will make every effort to resolve your concerns. You have the right to request the deletion of your personal data. To make such a request, please contact us at [email protected]. We will respond to your request in accordance with applicable laws.
Windsor vs Coupler.io