GW Apps - Privacy Policy

For residents of California, the CA Consumer Addendum to our Privacy Policy can be found at https://www.gwapps.com/california-privacy.

At GW Apps (“GW Apps”, “we” or “us”), we place the highest importance on respecting and protecting the privacy of individuals. We would like to share with you the following principles that govern our information practices and other privacy aspects of our website and our service when accessed through gwapps.com, app.gwapps.com or any of their subdomains.

This privacy policy includes addendums that address privacy considerations for individuals located in or residing in various geographic areas and these may be updated from time to time. Please review these addendums carefully to determine if they apply to you.

Changes To This Privacy Policy

We will update this privacy policy when necessary to reflect changes in our services as well as applicable laws, rules and regulations. When we post changes to this policy, we will revise the “last updated” date at the top of the policy. We encourage you to periodically review this privacy policy to learn how GW Apps is protecting your information. Using GW Apps websites or services after a notice of changes has been published on our website shall constitute consent to the changed terms and practices. Unless stated otherwise, our current privacy policy applies to all information that GW Apps has about you and your account.

You Can Contact Us

If you have privacy-related questions that are not addressed here, please contact the Privacy Team or write to us at: [email protected].

Definitions

Personal data: Means any information relating to a natural person identified directly, indirectly, or identifiable (e.g. name, phone number, date of birth, etc.).

Data Controller: Means any legal or natural person who determines the purposes and means of a personal data processing. The Data Controller is in charge of the respect of the GDPR within their organization, including the rights of employees (right of access, right to modify, right to erasure, etc.).

Data Processor: Means any natural or legal person who processes personal data on behalf of the Data Controller on the basis of the instructions they have given. “Processing” of personal data means any operation or set of operations which is performed upon personal data, whether or not by automated means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure or dissemination, and erasure or destruction.

Data Subject: Means any person whose personal data is being collected, held or processed. Personal Data can refer to anything from his/her name, home address or his/her posts on social media.

GW Apps Service: Means the online services offered by GW Apps that are available via URLs starting app.gwapps.com. These services currently include a no-code application development and hosting environment. (“GW Apps Service” or “service”.)

GW Apps Website: Means the public facing website available via URLs starting gwapps.com. This website describes the services and commercial offerings available from GW Apps, but is not involved with the delivery of the GW Apps Service. (“GW Apps Website” or “website”.)

If you are a user of the GW Apps Service, you are subject to the provisions of the Privacy Policy in two distinct ways:

• Your relationship with GW Apps: GW Apps acts as your Subcontractor, we are a Data Processor.
• Your relationship with the users of the GW Apps applications that you run: You are the Data Controller of their personal data.

The commitments of the GW Apps Service as a Data Processor

GW Apps only process personal data of users in connection with the execution of the GW Apps service to which they, or their organization, have subscribed. We will never sell or use the personal data of users of the GW Apps Service for marketing or commercial purposes.

Within the GW Apps service, we only collect the following Personal Information (“Account Information”):

• Email address
• First name
• Last name

For users authenticated via certain services, for example Google, we also have access to the same headshot image used within that service. We will display that image in various places on the screens of the GW Apps Service, but do not store the image.

All this data is collected for specific purposes and is only kept for the duration of the service. We only process the data entrusted to us for specific and defined purposes.

For the sake of clarity, Account Information does not include data you may upload and store within GW Apps Service apps (collectively, “App Data”). We do not have access by default to your App Data. If you do request that we access your Apps Information for any reason, including for technical support, that access will be provided by you and you remain in control of the App Data. Client App Data is purged after the client terminates their use of the GW Apps Service.

Your commitments as a Data Controller

You are responsible for controlling the personal data your users communicate to the GW Apps Service as part of their use of the services. The Data Controller defines the purpose of personal data and its processing. You are responsible for controlling the data. You are responsible for putting in place appropriate technical and organizational measures to ensure and prove that the data is processed in accordance with the Regulation. The obligations concern the principles of legality, fairness, transparency, limitation of purpose, minimization and accuracy of data, as well as respect for the rights of data subjects. You manage, through the GW Apps Service, the personal data of your application users. As a result, your application users have rights to this data. It is your responsibility to allow them to exercise them. GW Apps can help you fulfill this obligation via the address [email protected].

• Right of access: The Data Subject has the right to obtain from the Data Controller access to his / her Personal Data. Depending on the configuration of the application, users have access to information that concerns them (or may request access to it). You alone, as a Data Controller, should or should not give this opportunity to your application users.
• Right of rectification: The Data Subject has the right to obtain from the Data Controller, as soon as possible, the rectification of the Personal Data concerning them which are inaccurate.

• Right to be forgotten: The Data Subject has the right to obtain from the Data Controller the erasure, as soon as possible, of personal data concerning them.

Personal Information We Collect via the Website

By using the website, we collect certain personal information about you in order to provide the GW Apps Website and for us to learn how to be better able to serve you. We use a variety of technologies on our website. Among these are cookies, which are pieces of information that our website provides to your browser. Most browsers accept and maintain cookies by default. Check the “Help” menu of your browser to learn how to change your cookie preferences.

When we track activity on our website, we collect information such as your IP address, browser type and version, and pages you view. We also keep track of how you got to our website and any links you click on to leave our website. Once you leave our website, we do not track you. We analyze aggregate website activity to help us refine our website’s messaging and functionality..

We may access and set cookies using web beacons, also known as single-pixel GIFs which are invisible graphical images. These web beacons tell us useful information regarding our website such as which pages users access. When we send you emails, we may include a single-pixel GIF to determine the number of people who open our emails. When you click on a link in an email, we record this individual response to allow us to customize our offerings to you.

How We Use Personal Information

We use the Account Information you provide to (i) provide our website and services to you and administer your use of our website and services, (ii) to communicate with you and fulfill requests you may make, and (iii) to provide you with information and announcements with respect to our service. We need to use this information to provide our service and to meet our related contractual obligations to you.

Additionally, we may use your Account Information to communicate with you strictly about your service through email to provide you with customer support and other information on services and products (collectively, “Customer Service Messaging”). We need to provide Customer Service Messaging to you in order to meet our contractual obligations to you and you cannot opt-out of Customer Service Messaging.

How We Share Personal Information

We do not sell or rent your personal information to anyone.

Third Party Service Providers. We have limited relationships with third parties to assist us in providing the GW Apps Service to you, for example, by using a third-party data hosting service to ensure the data you upload to our platform remains secure. These service providers are contractually required to maintain the confidentiality of the information we provide them. The contracts outline the appropriate use and handling of your information and prohibit third parties from using any of your personal information for purposes unrelated to the product or service for which they’ve been contracted. Vendors are required to maintain the confidentiality and privacy of the information we provide to them.

Legal Disclosures. We may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required to comply with applicable laws, rules or regulations, and other agreements, or to protect the rights, property, or safety of GW Apps, users of our service, or others. For example, we may be required to disclose personal information to cooperate with regulators or law enforcement authorities, to comply with a legal process such as a court order, subpoena, search warrant, or a law enforcement request.

Business Transfers. Should we sell, merge or transfer any part of our business, part of the sale may include your personal information and you agree that any such third party will have the right to continue to use your personal information and other information that you provide to us or which we obtain through your use of the service.

If you use an email address provided by your organization, such as your employer or school, to sign into the GW Apps service, the owner of the domain associated with your email address may: (i) control and administer your account and (ii) access and process data you share with GW Apps. If your organization is administering your use of the GW Apps service, please direct your privacy inquiries to your administrator.

We will provide an individual opt-out or opt-in choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To limit the use and disclosure of your personal information, you can submit a written request to [email protected].

Security of Personal Information

We protect the confidentiality and security of your personal information by using industry-recognized security safeguards such as firewalls, coupled with carefully developed security procedures to protect your information from loss, misuse or unauthorized alteration. Whenever we ask for sensitive information we encrypt it as it is transmitted to us. Our employees are trained and required to safeguard your information and, using physical, electronic and procedural safeguards, we restrict access to personal information to those employees and agents for business purposes only.

Although GW Apps uses industry standard security measures, the Internet is not a 100% secure environment and GW Apps cannot, and does not, ensure or warrant the security of any information you transmit or store using the GW Apps service. There is no guarantee that your information may not be accessed, disclosed, altered or destroyed by breach of any of GW Apps physical, technical or managerial safeguards and we are not responsible for third party circumvention of your privacy settings or GW Apps’s security measures. You are responsible for maintaining the secrecy of your unique password and account information and for controlling access to your GW Apps account.

Our Retention of Personal Information

We retain personal information for as long as necessary to provide our service and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements.

Third Party Links

When you click on links on our website, you may leave our website. We are not responsible for the privacy practices of other websites and we encourage you to read the privacy statements at such websites.

Where We Store and Process Personal Information

GW Apps is hosted in the United States. For users accessing GW Apps from outside of the United States, information will be processed and stored in the United States. Personal information collected in the European Economic Area or Switzerland, which is transferred to countries that have not been recognized by the European Commission and the Swiss Federal Data Protection Commissioner, respectively, as providing an adequate level of data protection, will be transferred based on mechanisms adopted by the European Commission. If you have a complaint, you may bring your complaint directly to GW Apps at [email protected] and GW Apps will respond to you within 45 days. An independent recourse mechanism will be available to you and designed to investigate and expeditiously resolve your complaint. Where appropriate, we will use Standard Contractual Clauses approved by the European Commission.

EU-US Data Privacy Framework Certification Information

The following information aligns GW Apps Privacy Policy with the specific points required by the Data Privacy Framework (DPF) self-certification process, and ensures GW Apps’s compliance with the DPF Principles.

GW Apps  complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-US DPF as set forth by the U.S. Department of Commerce. GW Apps has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the UK (including Gibraltar) in reliance on the EU-U.S. DPF and the UK Extension to the EU-US DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

GW Apps’s accountability for personal data that it receives under the Data Privacy Framework and subsequently transfers to a third party is described in the DPF Principles. In particular, GW Apps remains responsible and liable under the DPF Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless GW Apps proves that it is not responsible for the event giving rise to the damage.

In compliance with the DPF Principles, GW Apps commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or UK individuals with inquiries or complaints regarding this privacy policy should first contact GW Apps at [email protected].

GW Apps has further committed to refer unresolved privacy complaints under the Data Privacy Framework Principles to an independent dispute resolution mechanism. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please submit a complaint directly to your local data protection authority  (i.e., EU/EEA Member State data protection authority; UK Information Commissioner’s Office (ICO) or Gibraltar Regulatory Authority (GRA).  Your data protection authority may refer your complaint directly to the U.S. Department of Commerce’s International Trade Administration (ITA) on your behalf.  If referred to the ITA, the DPF team will then work with the organization to seek to resolve your concern. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf.

GW Apps is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Organization Information:

GW Apps, 555 W. 5th Street, 35th Flr, Los Angeles, CA 90013