PRIVACY POLICY

AT WEBCRAFF

WE ARE COMMITTED TO PROTECTING YOUR PRIVACY.

Our goal is to provide you with a positive experience on our website, apps, products and services, while keeping your Personal Information, as defined below, secure.

Our privacy practices are described below, as well as in separate notices given when a product or service is purchased or downloaded (our “Privacy Policy”). This Privacy Policy covers all Webcraff products and websites. By visiting the Webcraff website, using Webcraff products or providing us with your Personal Information (as defined below), you are accepting and consenting to the practices, terms and conditions described in this Privacy Policy.

You will not need to consent to this Privacy Policy but do acknowledge you have read and understand its terms.

For ease of reference, we will use the following terms in this Privacy Policy:

  • “our”, “us” or “we” means Webcraff
  • “Webcraff products” includes all Webcraff, products and services
  • “Webcraff website” includes all global Webcraff websites.

If you are in the European Economic Area (“EEA”), for the purposes of the EU General Data Protection Regulation 2016/679 (“GDPR”), the data controller is Webcraff.

Types of Information Covered by This Privacy Policy
Personal Information. This means any information that (either in isolation or in combination with other information) can be used to identify you directly or indirectly. Some examples of Personal Information include your name, address, email address, phone number, an ID number or location data.

Aggregated Information. Information may be aggregated and/or Anonymised. When information is aggregated, it is combined with information about other customers and users. Aggregated information that includes Personal Information is considered Personal Information until it has been Anonymised.

Anonymised Information. When information is Anonymised, Personal Information is removed from collected data and the remaining portion of the data is repurposed for internal or external use, such as, for example, to determine how many users of a particular router include an Internet-enabled television in a home network environment, or how many users viewed a particular website video or advertisement. Such information cannot be used to identify you. Some examples include usage data relating to Webcraff website and Webcraff products, language preferences and Webcraff website page views.

In general, usage data collected when you visit Webcraff website or use Webcraff products is both aggregated and Anonymised, so it does not identify you personally and therefore is not Personal Information.

Children’s Personal Information. The Webcraff website and Webcraff products are not directed to, nor does Webcraff knowingly collect Personal Information from children under the age of 16. If we are informed that we have collected the Personal Information of a child under the age of 16, we will delete that Personal Information from our systems. If you believe we might have inadvertently collected Personal Information from or about a child under the age of 16, please contact us at [email protected].

How We Collect Information 
We collect and process the following data about you:

Information you give us. If you fill in forms on Webcraff websites or correspond with us by phone, email or otherwise, you may be providing us with information about you, which may include Personal Information. This includes information you provide when you register on Webcraff websites, register or return a Webcraff Product, subscribe to any of our services, search for a product, place an order on Webcraff websites, participate in discussion forums or other social media functions on Webcraff websites, enter a competition, promotion or survey, participate in a training session or other event, download firmware, software and apps, or when you report a problem with Webcraff website or Webcraff products or otherwise request support. Personal Information you give us may include your name, address, email address, phone number and other contact information, financial and credit card information and any other information that can be used to personally identify you.

Information we collect about you. We automatically collect information when you use Webcraff websites or Webcraff products, including:

  • technical information, including the Internet Protocol (“IP”) address used to connect your computer or another device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and language preferences. This information is all normally provided by your web browser, and we do not specifically request it;
  • information about your visit to Webcraff websites, including the full Uniform Resource Locators (“URL”) clickstream to, through and from Webcraff website(including date and time); products you viewed or searched for; page response times; download errors; length of visits to certain pages; videos watched; page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page;
  • any phone number or email address used to contact customer support;
  • if you consent, certain apps collect information about your location. If you do not want this information collected, do not consent, or consult your device manual for instructions on how to change location settings.

Information we receive from other sources. We work closely with third parties who provide services to us (including, for example, business partners, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and we may receive information about you from them.

How We Use Information
We use the information we collect for a number of purposes. These purposes will be consistent with the reason you provided the information to us or for a directly related purpose. The uses we make of such information are to:

  • set up an account for you on Webcraff website or Webcraff product
  • facilitate your purchase and/or download of Webcraff products;
  • authenticate use of your account or purchases and/or use of a Webcraff Product;
  • carry out our obligations arising from any contracts entered between you and us and to provide you with the information, products and services that you request from us;
  • assist you with customer support;
  • communicate about and administer participation in customer promotions and surveys;
  • notify you about changes to Webcraff websites and Webcraff products and changes to our terms, conditions and policies;
  • administer Webcraff websites and Webcraff products for internal operational purposes, including troubleshooting, data and statistical analysis, testing, research and survey purposes;
  • improve Webcraff websites and Webcraff products and to ensure that content is presented in the most effective manner for you and for your computer or device;
  • ensure the security of Webcraff websites and Webcraff products;
  • monitor and regulate interactive features of Webcraff websites and Webcraff products that you choose to participate in, including online forums and chat rooms relating to Webcraff products;
  • help you navigate Webcraff websites;
  • measure or understand the effectiveness of advertising we serve to you and others who visit Webcraff websites and to deliver relevant personalised advertising to you and others

Why We Use Information
Where we process your Personal Information to provide a product or service, we do so because it is necessary to perform contractual obligations that we owe to you and for our legitimate interest to provide products and services, to maintain our relationship with you and to protect our business. If you choose not to provide us with Personal Information, we will not be able to provide a product or service.

We also use your Personal Information to protect our business (for example, against fraud), or to comply with legal requirements to which we are subject (for example, tax or financial reporting requirements).

We will always seek your consent before we send you any direct marketing communications.

Sharing Information
Under no circumstances do we rent or sell your Personal Information to third parties for marketing purposes. We only share your Personal Information with third parties for marketing purposes if you have granted us permission to do so and in accordance with the Marketing section below. We share Personal Information in the following ways:

  • within Webcraff for purposes of data processing or storage;
  • with business partners, service vendors, authorised third-party agents or contractors to provide a requested service or transaction, including processing orders, hosting websites, storing your information, providing email communications on our behalf and providing customer support. For example, when making purchases on the Webcraff website stores, Webcraff uses a payment processor to verify your payment card information. Your payment card information is passed through to the payment processor and is not collected or stored by Webcraff. The payment processor is authorised to use this information only to authenticate your purchase and for no other purpose. We only provide these third parties with the minimum amount of Personal Information necessary to complete or provide the requested service or transaction, and we do not allow third-parties to use your Personal Information for a different purpose than what was disclosed to you;
  • with service providers, advisors or other third parties to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition or sale of all or a portion of our assets. If Webcraff merges with is acquired by another entity, Personal Information would be transferred as a whole to the successor entity;
  • to comply with the law or legal process (such as responding to subpoenas or court orders), to comply with government reporting obligations and to exercise our legal rights or defend against legal claims; and
  • to protect our legal rights or those of others, such as protecting the Webcraff brand or investigating violations of Webcraff terms of use, violations of law, intellectual property infringement, misuse of Webcraff websites, fraud or potential threats to personal safety.

In addition, we share aggregated Anonymised information, including usage data about Webcraff products, with third parties for a variety of purposes, including to analyse trends about home networking and utility use, to show third parties how their products could work with Webcraff products and to generally improve home networking. We’ve taken steps to ensure that this information cannot be linked back to you and we require third parties to keep all shared information in its Anonymised form.

Any third parties with whom we share your Personal Information are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose. We will take all reasonable steps to make sure these third parties comply with the same privacy principles that govern our collection of your Personal Information.

We will ask for your consent, such as by email response, opt-in box or click-through agreement acceptance before we use or share your Personal Information for any other purpose

Marketing
You have the right to ask us not to process your Personal Information for marketing purposes. We will inform you (before collecting your Personal Information) if we intend to use your Personal Information for marketing purposes, or if we intend to disclose your Personal Information to any third party for marketing purposes.

We will always give you choices about your Personal Information. Some choices are presented upfront in the form of opt-in notices or acceptance boxes for marketing to you or sharing your Personal Information with third parties. You always have the choice to opt-out if you later change your mind. One form of opt-out is clicking the Unsubscribe link in a marketing email. This will take you off our marketing email list. Please note that these opt-in/opt-out choices do not apply to the receipt of mandatory website, service or software communications, such as update or downtime information, or receipt of order or shipping confirmation on Webcraff website stores, which you may receive periodically as part of Webcraff performing its contract with you, unless you cancel your service or terminate use of software in accordance with the applicable terms of use or license agreement.

If you do not wish to receive direct marketing material from us or a third party, in addition to following the “Unsubscribe” instructions in a marketing email, you can send us an email request at [email protected].

Where We Store Your Information

We will take such steps as are reasonable to make sure we and our service providers do not breach the privacy principles that govern our collection of your Personal Information and that your Personal Information is treated securely and in accordance with this privacy policy as well as applicable data protection laws. By providing your Personal Information to us, you fully understand that Webcraff will transfer, processing and storage of Personal Information outside of your country of residence where data protection standards may be different and disclose your Personal Information to overseas service providers who may not fully comply with the particular laws of your country.

Our Privacy Policy and our practices are designed to provide a globally consistent level of protection for Personal Information all over the world. This means that even in countries whose laws provide for less protection for your information, Webcraff will still handle your information in the manner described in this Privacy Policy and in conformity with all applicable laws. This includes, where relevant, entering into EU standard contractual clauses (or equivalent measures) with the party outside the EEA (available here).

Accessing and Updating Your Personal Information 
We need your help in keeping your Personal Information accurate and up to date, so please notify us of any changes to your Personal Information. You can access and update your Personal Information and communication preferences at any time in the following ways:

  • by clicking the “Unsubscribe” link in any email you receive from us;
  • by sending an email to [email protected]. Please be sure to include your name, email address and specific relevant information about the information you would like to change or the material that you no longer wish to receive; or
  • on Webcraff websites, by signing into your online account (if available) located at the URL provided when you signed up for the Webcraff website or service.

We will honour your request to:

  • correct your data if it is inaccurate or incomplete;
  • transfer Personal Information you have provided to us to a third party if we are processing that data on either on the basis of your consent or to perform a contract with you;
  • delete your Personal Information, unless we are required to retain it by law or to establish, exercise or defend legal claims; and/or
  • provide you with a copy of your Personal Information held on our current records. If you are outside the EEA, we may make a reasonable charge if records must be accessed from backed up or archived records.

If you are resident in the EEA, you also have the right to:

  • withdraw your consent to our processing of your Personal Information at any time after you have consented, including opting-out of receiving marketing materials. The easiest way to do this is by clicking the “Unsubscribe” link in any email you receive from us;
  • restrict our processing of your Personal Information where you believe such data to be inaccurate, our processing is unlawful, or that we no longer need to process such data for a particular purpose (unless we are not able to delete the data due to a legal cause or other obligation or because you do not wish for us to delete it); and/or
  • object to such processing on grounds relating to your particular situation, where the legal justification for our processing of your Personal Information is our legitimate interest. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data to establish, exercise or defend legal claims.

You can make a request to exercise any of these rights in relation to your Personal Information by sending the request by email to [email protected].

We will respond to your request promptly upon receipt. If you are in the EEA, this will be within one month of receipt, or if further time is required, we will inform you of this and the reason for the delay. We may ask you to verify your identity before we can act on your request. If your Personal Information has been disclosed to a third party in accordance with this Privacy Policy, we will take reasonable steps to notify the third party of any updated information you provide to us.

If you are in the EEA, you also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. Please click here for a list of contact details for the EEA data protection authorities.

Retention of Personal Information 
We will only retain your Personal Information to fulfil the purposes for which it was collected, as required for legitimate business purposes as described in this Privacy Policy, or otherwise permitted by law. When we no longer need to use Personal Information, we will remove it from our systems and records and/or take steps to anonymise it so that you can no longer be identified from it.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Cookies, Web Beacons and Other Web Tools
To learn more about how we use cookies, web beacons and other web tools, and how to control which cookies, web beacons and other web tools are used, please see our Cookie Policy.

Security
We strive to maintain appropriate administrative, technical and physical safeguards designed to protect the information collected by Webcraff websites and Webcraff products. Unfortunately, the transmission of information via the Internet is not 100% secure.

It is important to note that if you use a computer or device that can be accessed by others, other people may be able to access unencrypted Personal Information. If you do not want your information to be available to others, exercise caution when using public computers or devices or when using any computer or device to which users unauthorised by you may have access.

We recommend that you take every precaution in protecting your Personal Information when you are on the Internet. For example, change your passwords often, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser. You should also be aware that names that you give your Wi-Fi-enabled devices, home networks and services (also known as “friendly names“) may be detectable by others outside your home, so you should not use Personal Information as part of your friendly names.

Updates and Upgrades
Webcraff products may be updated or upgraded from time to time to provide additional features, address technical issues, and generally make your user experience better. Some Webcraff products include an auto-update feature, which gives us the ability to make updates automatically. You can change auto-update options by changing your settings within the Webcraff Product account information. In very limited cases, updates may still be automatically applied, regardless of the auto-update setting. For example, we may provide an automatic update that prevents or fixes a security vulnerability or breach to your network.

Third-Party and Social Media Linked Sites
The Webcraff website and online services may contain links to websites or online services operated by third parties. Webcraff products may also use or offer products and services from third parties, such as a third-party apps that work with a Webcraff product. Once you leave a Webcraff website and Webcraff products, your activities are governed by the terms of use and privacy policies of the third-party websites and online services. Webcraff is not responsible for the privacy practices or the content of these websites and online services, and we encourage you to carefully read the terms of use and privacy policies of any website and online service you visit.

Webcraff website and Webcraff products may contain social media features, such as Facebook “Like” buttons. These features may collect information about your device’s IP address, set cookies to facilitate interaction with social media features or link you to social media websites where you may post Personal Information. All interactions with social media features are governed by the privacy policy of the social media company providing the feature.

Forums/Chat Rooms
If you participate in or post information to a discussion forum or chat room on any Webcraff website or Webcraff Product, you should be aware that the information you provide there will be made broadly available to others and can be read, collected, forwarded or used by other users of these forums, potentially inside or outside Webcraff, who have access to that forum. This information could also be used to send you unsolicited messages. Please recognise that individual forums may have additional rules and conditions. Each participant’s opinion on a forum or chat room is his or her own and should not be considered as reflecting the opinion of Webcraff. We are not responsible for Personal Information or any other information you may choose to submit in these forums, or the consequences of any submission. If at any time you would like to remove a posting, please email us at [email protected]. Keep in mind that removal of a post from a forum or chat room does not mean that the post will be deleted from our systems, or that it has been completely removed from the Internet.

Updates to this Privacy Policy
We may update this Privacy Policy from time to time, so please review it frequently. If we change our Privacy Policy, we will post the revised version here, with an updated revision date. If we make material changes to our Privacy Policy, we will notify you by email or prominently post a notice on this website.

How to Contact Us
Should you have any privacy-related questions or comments related to this Privacy Policy, please contact us at [email protected]

If you have any complaints or concerns about this Privacy Policy, please contact us at the above email. We treat all complaints about a breach of the privacy laws seriously. Someone from Webcraff will investigate your complaint and respond to you within a reasonable time.

Updated October 2021