Updated and Effective as of June 6, 2019
The Sites are not intended for or directed at children under the age of 16 years and we do not knowingly collect data relating to children under this age.
This table provides information about the registration of our various subsidiaries:
|Legal entity||Registered with||Registration number|
|Winshuttle Holdings, LLC||Delaware Secretary of State||4854865|
|Winshuttle, LLC||Delaware Secretary of State||4855279|
|Winshuttle UK Limited||Registrar of Companies for England & Wales||5926669|
|Winshuttle France SAS||Creteil Trade Register||B 400 B22 011|
|Winshuttle (Deutschland) GmBH||Commercial Registry of the Lower Court of Bremerhaven||HRB5487BHV|
|Winshuttle Software Canada Inc.||British Columbia Registry Services||BC0980768|
|Winshuttle India Holdings LLC||Delaware Secretary of State||4865859|
|Winshuttle Software (India) Private Limited||Registrar of Companies||U40101CH2006PTC030629|
By postal mail
Winshuttle LLC, 20021 120th Ave. NE, Ste 101, Bothell, WA 98011, United States
+ 1 (800) 711-9798
Data Protection Principles
Winshuttle adheres to the following principles when processing your personal data:
- Lawfulness, fairness and transparency – data must be processed lawfully, fairly, and in a transparent manner.
- Purpose limitation – data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
- Data minimization – data must be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
- Accuracy – data must be accurate and, where necessary, kept up to date.
- Storage limitation – data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
- Integrity and confidentiality – data must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage by using appropriate technical or organizational measures.
Personal data we collect
Information you give us
You may provide us with information through the Sites or over the phone, email or otherwise, when you:
- request additional information or materials regarding our services or ask us to contact you;
- use our services or platform;
- download, update, or upgrade products;
- make any comment or contribution on our Sites and any blogs or community forums accessible through the Sites;
- use our referral service to tell a friend about a job listing.
The categories of personal data you provide may include:
- first and last name;
- job title and company name;
- email address;
- phone number
- mailing address;
- password to log onto the platform;
- any other identifier that permits Winshuttle to make contact with you.
We do not generally seek to collect sensitive personal data through our Sites. Sensitive personal data is information relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; health or sex life, sexual orientation; genetic data or biometric data. If we do collect sensitive personal data, we will ask for your explicit consent to our proposed use of that data at the time of collection.
Information we collect from you
Winshuttle collects, stores, and uses information about your visits to the Sites and about your computer, tablet, mobile, or other device through which you access the Sites. This includes the following information:
- technical information, including the Internet protocol (IP) address, browser type, internet service provider, device identifier, your login information, time zone setting, browser plug-in types and versions, operating system and platform, and geographical location;
- information about your visits and use of the Site, including the full Uniform Resource Locators (URL), clickstream to, through and from our Site, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), and website navigation and search terms used.
Winshuttle as data processor
Information related to data collected through our platform
When providing services to our clients through the platform, we collect and process personal data about our clients’ customers and affiliates on their behalf. Winshuttle collects such information under the direction of its clients and has no direct relationship with the individuals whose personal data it processes. In these circumstances, Winshuttle is acting as a data processor. The use of personal data shall be limited to the purpose of providing the service for which our clients have engaged us.
We collect information for our clients. If you are an applicant or potential applicant for employment by one of our clients or have otherwise requested to receive information from one of our clients and would no longer like to be contacted by that client, please contact the client that you interact with directly.
Service Provider, Sub-Processors/Onward Transfer
Access to Data Controlled by our Clients
Winshuttle acknowledges that you have the right to access your personal information. Winshuttle has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Winshuttle’s Client (the data controller). If requested to remove data 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.
We will retain personal data we process on behalf of our clients for as long as needed to provide services to our client. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
If you choose to use our referral service to tell a friend about our job listing, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site. We store this information for the sole purpose of sending this one-time email and tracking the success of our referral program.
Your friend may contact us at email@example.com to request that we remove this information from our database.
What we do with your personal data
Winshuttle will only use your personal data if we have a legal basis for doing so. The purpose for which we use and process your information and the legal basis on which we carry out each type of processing is explained in the table below.
|Purposes for which we will process the information||Legal Basis for the processing|
|To issue required products keys and/or user identifications.||It is necessary for the performance of our contract with you.|
|To send you information and instructions for product download, evaluation download and product updates.||It is necessary for the performance of our contract with you.|
|To alert you to product upgrades, special offers, updated information and other new services which may be relevant to you.||
It is in our legitimate interests to promote and upsell our products and services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
You have the right to opt out of receiving promotional communications at any time by using the “unsubscribe” link in emails or updating your marketing preferences by visiting our Subscription center.
|To retrieve tasks assigned to user on our workflow server site via the mobile application and to complete, approve or reject retrieved tasks.||It is necessary for the performance of our contract with you.|
|To enter into and perform contracts with you.||It is necessary for us to process your personal data in this way in order to enter into a contract with you and to fulfill our contractual obligations to you.|
|To provide you with information that you request from us.||It is in our legitimate interests to respond to your enqueries and provide any information requested in order to generate and develop business. To ensure we offer an efficient service, we consider this use to be proportionate and will not be prejudicial or detrimental to you.|
|To enforce the terms and conditions and any contracts entered into with you.||It is in our legitimate interests to enforce our terms and conditions of service. We consider this use to be necessary for our legitimate interests and proportionate.|
|To send you event information and marketing communications, including newsletters, surveys, and Winshuttle product offerings.||
It is in our legitimate interests to market our services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
You can visit our Subscription center to update your preferences or to unsubscribe at any time.
For direct marketing sent by email to new contacts (i.e. individuals who we have not previously engaged with), we need your consent to send you unsolicited direct marketing.
|To post testimonials, comments and reviews on our Sites which may contain personal information.||
We obtain consent from the client to post the client’s name with any testimonials, comments, and reviews posted on our Sites.
If you wish to request the removal of your testimonial from our Sites, please email us as provided in “Contacting Us,” above.
|To post information to blogs or community forums.||
We allow users to post information on publicly accessible blogs and community forums on the Sites and it is in our legitimate interests to do so for promotional purposes.
You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal data from our blog or community forum, please contact us as provided in “Contacting Us,” above. In some cases, we may not be able to remove your personal data, in which case we will let you know if we are unable to do so and why.
|To send you a link to our Sites if you have been referred for a job listing at Winshuttle.||It is in our legitimate interest to recruit. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you.|
|To send you information regarding changes to our policies, other terms and conditions, and other administrative information.||It is in our legitimate interests to ensure that any changes to our policies and other terms are communicated to you. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you.|
||For all these categories, it is in our legitimate interests to continually monitor and improve our services and your experience of the Sites and to ensure network security. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you.|
|To measure or understand the effectiveness of any marketing we provide to you and others, and to deliver relevant marketing to you.||It is in our legitimate interests to continually improve our offering and to develop our business. We consider this use to be necessary in order to effectively generate business and will not be prejudicial or detrimental to you.|
Where you provide consent, you can withdraw your consent at any time and free of charge, but without affecting the lawfulness of processing based on consent before its withdrawal. You can update your details or change your privacy preferences by contacting us as provided in “Contacting us,” above.
Winshuttle will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you in a timely manner and we will explain the legal basis which allows us to do so.
Disclosure of your personal data to third parties
We will share your personal data with our group companies, affiliates, and advisers as necessary to carry out the purposes for which the information was supplied or collected (i.e. to provide the product or service you have requested).
Personal data will also be shared with our third party service providers who assist with the running of the Sites and our services, which could include hosting providers, email service providers, or members of Winshuttle’s partner network. Our third party service providers are subject to security and confidentiality obligations and are only permitted to process your personal data for specified purposes and in accordance with our instructions. Our third party service providers will not have any right to use your personal data beyond what is necessary to assist Winshuttle. If you do not want us to share your personal data with these companies, you may contact us at: firstname.lastname@example.org.
In addition, Winshuttle may disclose information about you:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;
- if all or substantially all of Winshuttle’s assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets;
- if we are under a duty to disclose or share your personal information in order to comply with any legal obligation or lawful requests by public authorities, including to meet national security or law enforcement requirements (Winshuttle will disclose your personal information only to the extent required in the event it must respond to subpoenas, court orders or other legal process);
- if necessary to protect the vital interests of a person; and
If Winshuttle is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Sites of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
To deliver services to you, it is necessary for us to transfer your personal data outside of the European Economic Area (“EEA“) with our group companies and with our service providers located outside the EEA. This includes systems in the United States.
Where personal data is transferred to and stored in a country not determined by the European Commission as providing adequate levels of protection for personal data, we take steps to provide appropriate safeguards to protect your personal data, including:
- entering into standard contractual clauses approved by the European Commission, obliging recipients to protect your personal data;
- under the EU-U.S. Privacy Shield Framework which enables U.S. business to self-certify as a means of complying with EU data protection laws (see below).
If you want further information on the specific mechanism used by us when transferring your personal data out of the EEA, please contact us using the details set out above.
EU-U.S. Privacy Shield Framework / Swiss-U.S. Privacy Shield Framework
Winshuttle participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Winshuttle is committed to subjecting all personal data received from European Union (EU) member countries, the United Kingdom, and Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s www.privacyshield.gov/list.
Winshuttle is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Winshuttle complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, the United Kingdom, and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Winshuttle is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Winshuttle may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the www.privacyshield.gov/welcome, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Security of your personal data
Winshuttle uses appropriate technical and organizational security measures to protect personal data both online and offline from unauthorized use, loss, alteration, or destruction. We use industry standard physical and procedural security measures to protect information from the point of collection to the point of destruction. This includes encryption, firewalls, access controls, policies and other procedures to protect information from unauthorized access.
Only authorized personnel and third-party service providers are permitted access to personal data, and that access is limited by need. Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorized disclosure of personal data.
Despite these precautions, however, Winshuttle cannot guarantee the security of information transmitted over the Internet or that unauthorized persons will not obtain access to personal data. In the event of a data breach, Winshuttle has put in place procedures to deal with any suspected breach and will notify you and any applicable regulator of a breach where required to do so.
If you have any questions about security on our Sites, you can contact us as provided in “Contacting us,” above.
How long we keep your personal data
Your personal data will not be kept for longer than is necessary for the purposes for which it was collected and processed. We will retain your personal data for as long as your account is active or as needed to provide you with services or products you have requested.
The criteria we use for retaining different types of personal data, includes the following:
- General enqueries – when you make an enquiry or contact us by email or telephone, we will retain your information for as long as necessary to respond to your queries. After this period, we will not hold your personal data for longer than two years if we have not had any active subsequent contact with you;
- Direct marketing – where we hold your personal data on our database for direct marketing purposes, we will retain your data for no longer than two years if we have not had any active subsequent contact with you.
- Legal and regulatory requirements – we may need to retain personal data for up 7 years after we cease providing services to you where necessary to comply with our legal obligations, resolve disputes or enforce our terms and conditions.
Winshuttle mobile application
- Acquired Information
- The Winshuttle mobile application does not require registration and therefore it does not collect user’s personal data like name, phone, email-id etc. It only uses user’s credentials which users get from registering on another Winshuttle product (i.e. “Winshuttle Workflow server”).
- Scope of use of acquired information
- User’s credentials are used to retrieve tasks, assigned to user on the “Winshuttle Workflow Server” site.
Complete, approve or reject retrieved tasks with comment for logged in user.
- User’s credentials are used to retrieve tasks, assigned to user on the “Winshuttle Workflow Server” site.
- Our Disclosure for Acquired Information:
- The Winshuttle mobile app will not sell, rent, trade, or otherwise transfer any personal and/or traffic data or communications content outside of Winshuttle. Information will only be used by Winshuttle products.
- Security for Acquired Information:
- The Winshuttle mobile app will take appropriate technical measures to protect the user’s credentials and traffic data provided to it or collected by it. Your credentials and traffic data can only be accessed by products of Winshuttle.
Access to and updating your personal data
You have the right to access information which we hold about you (“data subject access request“).
Upon request, Winshuttle will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. If your personally identifiable information changes, you may correct, update, delete, or deactivate it by logging into your account and accessing your member information page or by emailing us at email@example.com. We will respond to your request to access within 30 days.
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.
Please keep us informed if your personal data changes during your relationship with us.
You may also have the right to receive personal information which you have provided to us in a structured and commonly used format so that it can be transferred to another data controller (“data portability“). The right to data portability only applies where your personal data is processed by us with your consent or for the performance of a contract and when processing is carried out by automated means.
Right to object
You have the right to object at any time to our processing of your personal information for direct marketing purposes.
Where we process your information based on our legitimate interests
You also have the right to object, on grounds relating to your particular situation, at any time to processing of your personal information which is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise, or defense of legal claims.
Your other rights
You also have the following rights under data protection laws to request that we rectify your personal information which is inaccurate or incomplete.
In certain circumstances, you have the right to:
- request the erasure of your personal information erasure (“right to be forgotten”);
- restrict the processing of your personal information to processing in certain circumstances.
Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.
Exercising your rights
Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.
Cookies, other tracking technologies, and social media widgets
Technologies such as: cookies, beacons, tags, and scripts are used by Winshuttle and our partners, affiliates, or analytics or online customer support service providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site, and to gather demographic information about our user-base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
A cookie is a small amount of data which often includes a unique identifier that is sent to your computer or mobile phone (device) from the Sites and is stored on your device’s browser or hard drive. The cookies we use on the Sites won’t collect personally identifiable information about you and we won’t disclose information stored in cookies that we place on your device to third parties.
You can find more information about how to manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device.
We currently set the following cookies:
||Allows our platform to remember your actions from page to page.|
|Google Analytics||Gives us the ability to evaluate the use of our services.|
|Inspectlet||Gives us the ability to evaluate the use of our services.|
|Salesforce||Allows some of our sites to remember your actions from page to page.|
|Marketo||Provides analytics information about our visitors and allows us to manage targeted advertising.|
|TechTarget||Provides information about our visitors visiting from particular targeted advertisements.|
|Triblio||Provides analytics information about our visitors and allows us to manage and display targeted advertising.|
|ToutApp||Provides analytics information about our visitors and allows us to manage targeted advertising.|
|Swiftype||Provides search engine functionality for users on our platform.|
As is true of most Web sites, Winshuttle.com uses third party tracking-utility partners to gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site, and to gather demographic information about our user base as a whole.
We use Local Storage Objects such as HTML5 to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.
We partner with a third party to either display advertising on our Site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here) Please note this does not opt you out of being served ads. You will continue to receive generic ads.
Links and framing
The Sites include links to and from the websites of our partner networks, advertisers, and affiliates. Note, some of our pages utilize framing techniques to serve content to and from our partners while preserving the look and feel of our Sites. Please be aware that you are providing your personal information to these third parties and not to www.winshuttle.com.
If you follow a link to any of these websites, please note that these websites have their own privacy policies and Winshuttle does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
If you are located outside of the EEA and you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
If you are located in the EEA, you also have the right to complain to the relevant supervisory authority in the EEA. In this UK, this is the Information Commissioner’s Office (https://ico.org.uk/).