Privacy Policy

WaveAccess Services respects and protects your privacy and personal data

This Privacy Policy describes how WaveAccess Services (hereinafter “we”, “us” or “our”) collects, uses, shares, and otherwise processes personal data about visitors (hereinafter also “you” or “your”) to our website www.wave-access.com.

Please read the following carefully to understand our views and practices regarding your personal data and how we treat it. By continuing to use this website you accept and consent to this Privacy Policy.

WaveAccess Services is committed to following the principles outlined in the EU’s General Data Protection Regulation (the “GDPR”) for all EU residents that provide their personal data to us and other applicable privacy laws.

Who we are

WaveAccess Services is a part of an international WaveAccess group of companies that provides software development and IT outsourcing to hundreds of companies globally. With respect to personal data collection on this website, WaveAccess Services is considered to be data controller.

Main definitions

Personal data – means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier.

Processing of personal data – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Controller – means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Collection and use of personal data

Whose personal data we collect

We collect personal data about visitors to this website, including visitors who are our current and prospective customers, suppliers, and partners.

This website is not intended for children under the age of 16 and we do not knowingly collect data relating to children. If WaveAccess Services has actual knowledge that personal data about a child under 16 years old has been collected, then WaveAccess Services will take the appropriate steps to delete such personal data.

Under no circumstances WaveAccess Services collects or processes special categories of personal data (sensitive data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) about you via this website.

Why we collect personal data

  • To receive, respond to and follow up on your enquiries and requests about our services and products.
  • To analyze how users engage with our website in order to make your experience of our website better and assist in our marketing efforts.
  • To send you marketing communications which you have subscribed to.
  • To send you information about our products and services that you have bought, downloaded, took a free trial, or downloaded a demo-version.
  • To perform direct sales and marketing activities in cases where legitimate and mutual interest is established.
  • And for other legitimate purposes related to promotion and sales of our services and products.

Our legal basis for collecting personal data

WaveAccess Services collects and processes personal data on the following legal basis:

  • Consents. The collection of personal data based on a consent from you will be done by using “Consent Forms” that will store documentation related to the consent. Individual consents will be documented and stored in our systems. You may at any time withdraw your consent by contacting us at privacy@wave-access.com.
  • Contract. We may collect and process your personal data if it is necessary for the performance of a contract with you, or in order to take steps at your request prior to entering into a contract.
  • Legitimate interest. We may collect and process personal data if it is considered to be of our legitimate interest (for example to develop our products and services and grow our business). When we are relying on legitimate interest as a basis for processing your personal data we will always ensure the privacy interests of the data subjects do not override this interest.
  • Other legal basis. We may collect and process personal data if such processing is necessary for compliance with a legal obligation to which the WaveAccess Services is subject, if processing is necessary in order to protect the vital interests of the data subject and in other cases when collection and processing of personal data is allowed by Art. 6 of GDPR.

How and what personal data we collect

1. Information you provide
You may provide us with your personal data:

  • When you communicate with us via this website, including filling out forms on this website (submitting enquiries, questions, comments, feedback, or contact requests) and by contacting us by email or phone;
  • When you subscribe to our marketing communications, which includes information about our services and products, events, offers, news, promotions and surveys;
  • When you become our customer, including buying, downloading, taking a free trial, downloading a demo-version of our software and products.

To fill out forms on this website, most commonly we ask you to provide your Name, Email, and Phone number. When you contact us via this website, in emails, phone calls, or other means of communication, at your discretion and where possible you may also provide us with other personal data by putting it in the textbox of enquiry or attaching a file.
2. Information we collect about you
Like most websites, this website uses cookies and web beacons.

You do not have to give us information in order to use our website. However, non-identifiable personal information about visitors to the website is automatically collected by cookies and web beacons. This includes technical information about your browser and operating system and actions you take on the website.

We use this information to understanding how visitors use our website, make your experience of our website better and assist in our marketing efforts.

If used alone, cookies and web beacons do not personally identify you.

For more details read about Cookies and Web Beacons.
3. Personal data we get from the third parties
From time to time, WaveAccess Services may receive personal data from other legitimate sources and third parties such as WaveAccess group of companies, data aggregators, marketing partners, public sources or social networks.

We may receive information about you if you use any of the other websites we operate or other services we provide within WaveAccess group of companies. In this case we will inform you when we collect that data that it may be shared internally and combined with data collected on this website.

If you do not want us to use your personal data which you have not provided to us yourself, you can let us know by contacting us at privacy@wave-access.com.

How long we keep personal data

We retain personal data no longer than it is necessary to fulfil the purpose for which personal data was collected and processed and as otherwise needed to comply with applicable legal requirements. We will delete your personal data when they are no longer required for the purposes for which they were originally collected, processed, and stored.

How we use collected personal data

WaveAccess Services uses personal data according to the purposes it was collected for and use only personal data that is relevant and sufficient for such purposes. Most commonly we use collected personal data for the following purposes:

  • To analyze how users engage with our website in order to make your experience of our website better and assist in our marketing efforts;
  • To receive, respond to and follow up on your enquiries and requests, which you have submitted to us via this website, by email or phone;
  • To provide you with information about our services and products that you have already requested from us and about other services and products we offer;
  • To notify you about changes to our services and products;
  • To carry out our obligations arising from any contract concluded between you and us and the contracts we are about to enter into;
  • To send you marketing communications which you have subscribed to;
  • To set up retargeting/remarketing campaigns.

We may use personal data you provided for marketing purposes, namely, to send you emails about our our services and products, events, offers, news, promotions and surveys. This communication is subscription based and requires your consent. While filling out forms on this website, you can indicate that you want to subscribe (opt in) to marketing communications by ticking the relevant checkbox on the form.

You have the right to object to processing of your personal data for marketing purposes and unsubscribe (opt out) from marketing communications at any time by clicking the unsubscribe link in any of these emails or by contacting us at privacy@wave-access.com.

Sharing and disclosing personal data

Under no circumstances we sell, rent, or trade your personal information with any third parties.

We do not share your information without your consent, except for cases that are described below. We may share your personal data with selected third parties:

  • WaveAccess group of companies with the purpose to maintain and provide our services and products, and to maintain and improve this website.
  • Business partners, suppliers and sub-contractors for the performance of any agreement we enter into with you or we are about to enter into to provide the best service to you;
  • Analytics services and search engine providers that assist us in the improvement and optimization of our website and services;
  • Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others (subject to the relevant consent to receive marketing communications).

We may share personal data when it’s required by mandatory legal obligations and to comply with any subpoena, court order and ongoing or prospective legal proceedings, or other governmental request. We may also share personal data to establish or protect our legal rights, property, or safety (e.g, for the purposes of fraud prevention and reducing credit risk).

We may also share anonymous statistics or other information that does not identify individuals personally.

We require all third parties to respect the security of personal data and to treat it in accordance with the legal requirements and in accordance with our instructions. In any way third-parties are not authorized to use your personal data for their own purposes and are only permitted to process your personal data for specified purposes which it was initially collected for.

International transfers of Personal Data

WaveAccess Services is a part of an international WaveAccess group of companies with offices in USA, Denmark, UK and development centers in Eastern Europe. In this regard we may transfer personal data to jurisdictions outside of the individual's home country and outside of European Economic Area (EEA) as necessary for the purposes the data collected and is processing. Collected personal data may also be processed by staff operating outside the EEA who work for us or for one of our subsidiaries and affiliated parties.

We take all steps necessary to provide suitable safeguards to protect the privacy and security of your personal data during the cross-border transfer and to ensure that your data is treated securely and in accordance with this Privacy Policy. With respect to such cross-border transfers to non-EEA jurisdictions, we implement standard contractual clauses approved by the European Commission and other approved mechanisms to protect such Personal data.

Cookies and web beacons

Like most websites, this website uses cookies and web beacons.

When you use this website we may automatically collect the following data:

  • Internet Protocol (IP) address, browser type and version, geographic location, time zone and language settings, operating system type, platform and version;
  • Uniform Resource Locators (URL) clickstream to, through and from our website including date and time, information you searched for, response times, errors, length of visits, interaction information (such as scrolling, clicks, and mouse-overs), forms filled out and submitted.

We use this information to understanding how visitors use our website, improve our website, present content in the most efficient and engaging manner and assist in our marketing efforts.



Links to other websites

This website may contain links to third-party websites that are not administered by WaveAccess Services and are not governed by this Privacy Policy.

We encourage you to familiarize yourself with the privacy policy and security practices of the linked third-party websites before providing any personal data on those websites.

Security

We recognize our responsibility to protect the personal data you provided us with.

WaveAccess Services uses reasonable measures (technical and organizational) designed to protect personal data from unauthorized access, use, disclosure, copying, modification or destruction, and from unintentional loss, misuse and alteration. We use a variety of secure techniques to protect your information, including access restrictions, secure servers, firewalls, antivirus programs, intrusion detection system, and system penetration testing.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a data breach where and within the period we are legally required to do so. We also require that third parties to whom personal data is transferred also provide such reasonable security measures.

Your rights

Once you have provided us with your personal data you have rights under the GDPR and applicable data protection laws in relation to your personal data, including the following:

  • Right to request access. You may request details of personal data which we hold about you and to check that we are lawfully processing it;
  • Right to request correction. If you believe that any personal data we are holding on you is incorrect or incomplete, please contact us at privacy@wave-access.com. We may need to verify the accuracy of the new data you provide to us.
  • Right to request erasure. You may ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Right to object to processing. At any time on grounds relating to your particular situation you have right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your personal data for direct marketing purposes.
  • Right to request restriction of processing. You may ask us to suspend the processing of your personal data where one of the following applies: (a) if you want us to establish the data’s accuracy; (b) if the processing of personal data is unlawful but you do not want us to erase it; (c) if we no longer require your personal data but you need us to hold the data since you need it to establish, exercise or defend legal claims; (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Right to request the transfer of your personal data to you or to a third party. You may ask us to provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Right to withdraw consent at any time. If you have previously provided us with your consent to collect and process your personal data, you can change your mind and withdraw such consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. Note that if you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at privacy@wave-access.com. Note that before acting on any such request, we will need to verify your identity and you may previously provide us with personally identifiable information. To the extent WaveAccess Services does not have sufficient information about you or is unable to verify your identity, we may not be able to honor your request.

Changes to Privacy policy

WaveAccess Services may update this Privacy Policy from time to time by posting the updated version of on this website. The effective date of our Privacy Policy is posted below.

If we make changes that significantly alter our Privacy Policy, we will post a notice on our websites prior to the change taking effect or notify by email. We encourage you to check this Privacy Policy periodically to stay informed about our privacy practices.

Contact information

If you have questions or comments regarding this Privacy Policy and our privacy practices, or you have any requests to exercise your legal rights, please contact us at:

Email: privacy@wave-access.com

Registered address:
Office 4d, 19 Bolshaya Morskaya st, Saint-Petersburg, Russia, 191186

Tel./Fax: +7 812 407 2350

Your right to complain with a supervisory authority

If you are unhappy with the way in which your personal data has been processed, you may, in the first instance, contact privacy@wave-access.com.

If you remain dissatisfied, then you have the right to apply directly to your national data protection supervisory authority for a decision.

The supervisory authorities can be contacted at:

European Data Protection Supervisor:
https://edps.europa.eu/





This Privacy Policy is effective May 25, 2018
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