This Privacy Policy describes how Weagree B.V., a limited liability company under the laws of the Netherlands (Weagree, we or us) collect, hold, use and disclose personal data; the kinds of personal data we collect; how you can access and correct it; how to make a privacy complaint; and how we handle privacy complaints. We are subject to Dutch Implementation act data protection regulation (Uitvoeringswet algemene verordening gegevensbescherming) and the EU General Data Protection Regulation (GDPR).

First of all, we take your privacy seriously and are committed to protecting your personal data against unauthorised or inappropriate use.

To demonstrate compliance to the latest regulations, such as GDPR, we have implemented ISO 27001 and set up an information security management system (ISMS). We have implemented measures to ensure adequate protection of data, both in transit and at rest. Processes have been adjusted to make sure data is never stored longer than necessary to perform our services.

Do we collect personal data?

In this Privacy Policy, personal data means information or an opinion about an individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in a material form or not.

We only collect personal data for the purposes of conducting our business, including in relation to the licensing and implementation of our document creation, automation and management software (our products and services).

What kinds of personal data do we collect and how?

The type of personal data we collect depends on your relationship with us – whether you are a client, prospective client or a prospective employee. Examples of the types of information we collect are:

– If you are an end-user authorised by our customer:

• your name and contact details, including phone number, e-mail address and postal address;
• your contact details at a business that is a sales lead;
• your passwords or personal identification codes (PINs) in encrypted form.

– If you are a purchaser of our books or masterclasses (or other paid courses):

• your name and contact details, including e-mail address, each to the extent you have submitted it to us;
• your postal address, if needed to delivery the book;
• your passwords or personal identification codes (PINs) in encrypted form.

– If you are a member of our community, an uploader or downloader of model contracts or model clauses shared on our website, a
subscriber to our newsletter or if you otherwise indicated your interest
in Weagree or our services:

• your name and contact details, including e-mail address, each to the extent you have submitted it to us;
• your professional background information, including education and jurisdictions for which you are qualified as a legal professional, each to the extent you have submitted it to us;
• your passwords or personal identification codes (PINs) in encrypted form.

– If you are an employee, an independent professional working for us, or VAT-withholding exempted resident of an EU member state (other than the Netherlands):

• your tax file number or other government related identifiers;

– If you are an employee or wish to become one (applying to a vacancy):

• your employment history and qualifications, your study results and background checks relevant to your job application;
• employee number;
• your testimonials, feedback and complaints.

Our website offers in some places the possibility to react, for example by commenting on weblogs or by requesting us information. If you react via e-mail, we will obviously use some of your details (your name and address or e-mail address) to service your reaction. Here also, we will respect your privacy (and not use your reaction for other purposes than your reaction may indicate.

We may collect your personal data in a number of ways, including in person, by telephone, by e-mail or electronically when you contact us or visit our website to:

• request a brochure or product information;
• issue a request for proposal;
• order our products or services from us;
• execute a demo of our software on our website;
• respond to Weagree surveys;
• attend Weagree-sponsored events or conferences; or
• apply for a job at Weagree.

We may also collect your personal data from third parties, including data available on the internet, and data purchased from third party sources (for example, Salesforce from whom information may be purchased for the purpose of compiling sales leads). Where personal data is obtained from third party sources, the collection, use and disclosure of that personal data will be governed by the third party’s privacy policy as well as by applicable privacy laws. If you are a prospective employee, we may also collect personal data from credit agencies (after seeking your consent to do so).

Why do we collect personal data and how do we use or disclose it?

We use personal data to provide our products and services in meeting our customers’ needs. We collect, hold, use and disclose your personal data to:

• deliver our products and services, including our consultancy services, hosting services and data capturing services;
• develop and enhance our products and services;
• market and promote our products and services;
• explore prospective sales leads;
• organise events and promotions; and
• comply with our legal obligations.

The access to the Weagree Wizard demo-version is subject to our Terms of use. Information provided by you to us in connection with the use of the demo-version may be used by us for evaluation purposes or for approaching you for licensing the Weagree Wizard. Weagree will not use such information for other purposes and will not convey any such information to third persons.

Information inserted in response to the Wizard’s questionnaire will be treated as confidential and personal, except in the event of apparent abuse or apparent wilful misconduct of the Weagree Wizard. We reserve the right, in all cases, to remove any parts of information provided via the Weagree Wizard questionnaires from the website.

Personal data under the control of licensees

In some circumstances, we may access and use personal data that has been collected by a licensee in the course of their use of our software products. This personal data remains under the control of the licensee at all times. We will only use this information on a limited basis to fulfil our contractual obligations to the licensee to:

• diagnose and address software programs;
• provide hosting services;
• fulfil IT-related duties for technical maintenance and the backup of the hosting environment;
• provide consulting services in relation to the installation and configuration of our software;
• assist with the preparation and migration of data to our software;
• develop product enhancements; and
• provide data capturing services.

Can you choose to remain anonymous?

You may elect not to identify yourself or you may use a pseudonym in your dealings with us, except where it is impracticable for us to deal with you on this basis (for example, we will need to identify you to provide most of our products and services).

How can you request not to receive direct marketing?

We may use your personal data for direct marketing. This includes the use of personal data to:

• invite you to a Weagree Wizard users conference; and
• notify you about an existing or new product or service.

If you prefer not to receive these communications from us, you may ask us at any time to stop sending you direct marketing information or to stop being contacted by us. You can do this with the unsubscribe-option at the bottom of our generic mailings or by e-mailing us at support@weagree.com.

Do we use cookies on our website?

We or our third-party partners may collect information automatically when you enter our website by using cookies, which are small data files placed on your computer or other device to collect information. This information includes your domain name, browser, your computer operating system, information about the web page from which you linked to the site, and time spent on different pages within the site. We cannot identify you from this information.

We or our partners may use this information to evaluate and improve our site or deliver web content specific to your interests, and may share the information with third parties on an aggregated basis to enhance our products and services. You can set your browser to notify you when you receive a cookie which will provide you with an opportunity to either accept or reject it in each instance, or to disable cookies. Please be aware that cookies may be required to complete certain functions on our website and other websites you may link to from our website. This means that, if you disable cookies, you may be unable to use certain parts of our website or other websites.

Who do we disclose your personal data to?

We may disclose your personal data to third parties for the purposes explained above to:

• third party services providers to assist us in developing, promoting, establishing, maintaining or providing Weagree-related products and services to you, including joint marketing efforts or promotions; and
• data storage and payroll service providers.

Do we disclose your information outside the EU?

We may share your personal data with affiliated companies and partner implementation companies, some of which may be located outside the Netherlands.

Where personal data is transferred from the EU or Switzerland to the US, we will cooperate in investigations by and comply with the advice of EU data protection agencies and the Swiss Federal Data Protection and Information Commissioner (FDPIC).

Weagree will reply to lawful requests from public authorities, including to meet national security or law enforcement requirements, for disclosure of personal data.

Weagree will not transfer personal data originating in the EU or Switzerland to third parties unless such third parties have entered into an agreement in writing with us requiring them to provide at least the same level of privacy protection to your personal data as required from us. We will only transfer data to our agents, resellers or third-party service providers (such as accountants, attorneys, consultants and other service providers) who have a legitimate need-to-know or need-to-access the information to provide services to or perform activities on behalf of Weagree, including in connection with the provision of services, Weagree’s administration or legal responsibilities. We acknowledge our liability for such data transfers to third parties.

Where do we store and process your personal data and keep it secure?

Weagree operates globally, so your personal data may be stored and processed outside of your home country. We take steps to ensure that the information we collect is processed according to this Privacy Policy and the requirements of applicable law wherever the data is located.

Weagree has databases, servers, support and helpdesks located in Amsterdam, and may engage local implementation partners worldwide. We collaborate with third parties such as cloud hosting services, suppliers and technology support located in the Netherlands to serve the needs of our customers and the continuity of our Services. We take appropriate steps to ensure that personal data is processed, secured and transferred according to applicable law. We hold your personal data in electronic and (occasionally) hardcopy files. We use security techniques to protect your personal data that we hold from misuse interference and loss, and from unauthorised access, modification or disclosure. The techniques we use include firewalls and access control procedures. For example, when you use Weagree software over the internet, the information exchange between you and the Weagree software is encrypted using a secure sockets layer (SSL) protocol.

All our employees are bound by extensive and strict confidentiality obligations aimed to prevent them from disclosing any personal data or other confidential information. Further, our employment agreements state that our employees must abide by all applicable laws and regulations.

Our policies also limit access to personal data to only those employees, contractors or representatives that a need-to-know or need-to-access the information to perform their obligations or assist us with providing our products and services to you.

How long do we keep your personal data?

We will keep personal data for as long as it is necessary to provide our products and services, and to comply with our business, tax and legal requirements. Once information is no longer needed for the purposes for which it was collected, we will take reasonable steps to de-identify and destroy it.

How can you seek access to and correct your personal data?

We will, upon your request, and subject to any exemptions under GDPR or applicable privacy laws, provide access to the personal data that we hold about you. We will need to first identify you, your entitlement and understand the types of information you wish to access. We will generally deal with access requests within 30 days. We may charge for our reasonable costs of providing access. If we deny access to all or any part of the personal data that you request, we will notify you of our reasons in writing and explain how you can complain if you are not satisfied with our decision.

You can ask us to confirm whether we are processing your personal data, or to correct or update personal data we hold about you at any time. We will need to verify your identity. We will also independently take reasonable steps to correct personal data we hold if we are satisfied that it is inaccurate, out-of-date, incomplete, irrelevant or misleading, having regard to the purpose for which it is held.

If you require access to, or wish to update your personal data, please contact us at security@weagree.com.

How can you seek further information or complain about a breach of your privacy?

If you have questions, concerns, or complaints about this Policy or our privacy practices, please contact our Privacy Officer by e-mail at security@weagree.com or by telephone on +31 20 616 9696. We will respond to your inquiries as soon as practicable.

In compliance with the Privacy Shield Principles, Weagree commits to resolve complaints about our collection or use of your personal data. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Weagree by e-mail at security@wearee.com or by telephone on +31 20 616 9696. If required, complaints will be referred to Weagree’s Data Protection Officer.

You may also lodge complaints with the lead supervisory authority for Weagree, the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) by contacting:

Phone: +31 70-888 85 00
Address (by appointment only): Bezuidenhoutseweg 30, 2594 AV The Hague, the Netherlands
Website: https://autoriteitpersoonsgegevens.nl/en

How will you be notified about updates to this Privacy Policy?

We may update this Privacy Policy at any time in connection with our ongoing efforts to improve our services and to comply with our legal obligations. If there are any material changes to this Privacy Policy, we will post a notice on our websites in a prominent position.

Last updated: May 2022