Privacy policy and data protection

Wooclap provides its customers with a unique application allowing users to give presentations to, and interact with their audience, in a truly efficient way. We need to collect and process personal data to fully satisfy your needs and optimize the way you use our application and website. This Privacy Notice (herein below “Notice”) is to help you understand and describe how we collect, use, and disclose information that we obtain about users of our websites, services, plug-ins, software or other Downloadable Tools (all of which we refer to as the “Platform”).

This Notice describes the following:

• How do we collect your personal data?
• Who collects your personal data?
• Which personal data does Wooclap collect?
• For which purposes does Wooclap use your personal data?
• Which rights do you have and how can you exercise them?
• Your opt-out choices
• How long will Wooclap keep your personal data?
• Security and storage of the information
• Third party links
• Changes to the Notice and Contact Information and

This Notice is effective as of December 26, 2022 and was last revised on December 26, 2022.

Data Processing Agreement (DPA)

A DPA can be signed between Wooclap as a subprocessor, and the Wooclap Client as the data controller. This agreement is added to the contract, and supersedes the terms of the privacy policy available on the Wooclap Website.

Special note for teachers

Wooclap is mostly intended for educational purposes. Within this context, Wooclap’s applications may be used in schools, institutes or other organisations serving educational and recreational purposes, by children under the age of 16. We understand the importance of protecting children’s privacy and recognize the need to be transparent and clear towards children with regard to how we use their personal data. In this regard, we are committed to taking appropriate measures to protect children’s privacy as appropriate.

Our privacy notice especially designed for children is aimed to explain to children and teachers, in clear and specific language, how we protect the children’s data collected through our application(s) (see our Child-Friendly Privacy Policy). We urge all educational teams introducing the use of our application(s) to their pupils, to draw pupils’ attention to the children’s privacy notice. We expect that teachers would be able to respond to children’s questions about how we use children’s data by referring to this Notice and the Children’s Privacy Notice. Although we cannot be held responsible for how you will present and explain the information provided in this Notice, we are always at your disposal to reply to any question or concern you or your pupils may have about this application, at: info@wooclap.com.

Please note that the following data protection authorities provide useful guidance and tips to parents, children and the teaching staff on children’s privacy while using the internet at:

• https://www.gov.uk/data-protection
• https://ico.org.uk/for-the-public/your-data-matters-blog/
• https://www.cnil.fr/fr
• https://www.jedecide.be/privacy
• https://www.ikbeslis.be/

Definitions

For the purpose of our Privacy Notice, the following definitions apply:

“Wooclap” or “we”

Wooclap SA with registered office at Rue des Pères Blancs 4, 1040 Etterbeek (Brussels), Belgium

GDPR

The General Data Protection Regulation, meaning EU Regulation 2016/679 of the European Union and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data

Personal data (herein also “personal information” or “information)

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 such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person

Processing

Processing 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

Controller means the natural or legal person which alone or jointly with others determines the purposes and means of the processing of personal data

Processor

Processor is the natural or legal person, which processes data on behalf of the controller

Data subject or “you”

Data subject means a natural person whose personal data is being processed

Wooclap Users

People using the service we provide in some capacity. They can be further classified into two categories: Wooclap Creators who create content on Wooclap and animate events, and Wooclap Participants who participate in events created by Wooclap Creators

How does Wooclap collect your personal data?

Wooclap collects your personal information in various ways:

• Information you provide us directly by creating an account

  You provide us directly with personal information when you create an account on the Wooclap platform. In order to successfully create an account and access our application and other features in a secure and confidential manner under your full control, you are required to provide us with certain types of information.

• Information you provide us directly by contacting us

  If you have any complaints or questions, it is possible to contact us through our online contact form. It is necessary for us to collect your personal data in order to answer these inquiries and resolve the issue you have addressed to us (e.g., complaint relating to the functioning of our application or a clarification request about how using the application). It is also possible to contact us through social media, in which case we will collect only the data that are relevant to answer your messages and questions.

• Information you provide us directly by subscribing to our newsletter

  If you wish to get information about our latest features, it is possible to subscribe to our newsletters. We will collect personal data directly from you in order to be able to send you our newsletters.

• Information we receive from third parties

  Instead of registering to the Wooclap platform with a new account, it is possible to connect to the platform using your credentials from a third party account (e.g. Facebook, Linkedin, Google + or the account from your university). If you decide to connect your Wooclap account to your pre-existing account from a third party service, we will import personal information from that partner to your Wooclap account. We may also collect personal data about you from publicly available sources and combine it with information that we are automatically collecting from you.

• Information we collect through the use of the platform or the website

  We collect information directly from your use of the platform. We collect information resulting from the events you have created or participated in, but also from your interactions with us through our Chatbox.

• Information we automatically collect through cookies

  When you use the Wooclap platform, we collect information about you through cookies. Cookies are small text files that are stored on your computer by your browser in order to track all movements within the website and ensure all functionalities of the platform are available to you. You can find more information about our use of cookies below.

In order to help you protect yourself and your information, we encourage you to provide only that information that is necessary for using our Platform. For example, to participate in an event, you may not necessarily need to provide us with a name / email address.

Our application(s) cannot in general be used by children under the age of 13 without the consent of their parents and/or their legal representatives, unless such use is introduced within an educational or recreational context under the guidance of teaching staff as explained above (see Special note for Teachers and Child-Friendly Privacy Policy).

Who collects your personal data?

For the processing activities mentioned in this Privacy Notice, Wooclap is the responsible data processor:

Wooclap SA

Rue des Pères Blancs 4
1040 Etterbeek (Brussels)
Belgium
VAT: BE 0563.691.645

Any questions or remarks with regard to this Privacy Notice? Feel free to contact us via dpo@wooclap.com.

Which personal data does Wooclap collect?

Wooclap collects the following information about you when you create an account:

• First Name
• Last Name
• Email address
• Field (education, enterprise, event agency)
• Organization/University name
• Whether you are a student or a professor
• Country
• Language
• Payment information (only applicable for online subscriptions): if you purchase a premium version of Wooclap, our third-party payment processor (Stripe) will collect and store your billing address and credit card information. We only store the last four digits of your credit card number, card type and the expiration date, and your billing address information.
• Any additional information you decide to provide us with (e.g., phone number for support purpose, …)

Wooclap collects additional information about you when you decide to connect your Wooclap account with a third party account:

• Profile picture
• Current job and function
• Company
• University
• Additional information (Facebook public profile, …)

Wooclap Users may give us permission to access their information in other services. For example, with your consent, you may link your Wooclap account with your Google, Facebook or LinkedIn account, or other similar service, which allows us to obtain information from those accounts (like your basic profile or contacts). The information we get from those services often depends on your settings or their privacy policies, so be sure to check what those are.

Wooclap may also collect data in relation to your use of the Wooclap platform or any other feature on our website. These data are inadvertently collected by us as they are directly necessary to, or derive from the service(s) you request from us:

• Content data. This includes any content that you create or upload on Wooclap such as polls (title, choices, …), presentations and questionnaires.
• Events you have participated in
• Answers you have given to questions (derived properties such as your scores on the questions, rankings, …) and messages sent to professors
• Any information you are providing us through our Chatbox
• Any information you are providing us through our contact form
• Cookies and other tracking devices

For which purposes does Wooclap use your personal data?

Wooclap collects your personal data for the following purposes:

• To set up your Wooclap account and allow you to use our services and platform

  We will use your information to provide our Platform and services to you; to facilitate interactivity between Wooclap creators and Wooclap participants; to manage your account; to respond to your inquiries; and for other customer service and support purposes. For online subscriptions, we use the payment information you provide to us in order to alert you of past, current, and upcoming charges, to allow us to present the billing history to you on your billing page in the platform, and to perform internal financial processes, such as looking at the status of a credit card charge. In the event of a credit card dispute, we also share account information with your bank to verify the legitimacy of a charge.

• For technical purposes

  We will use your personal data to prevent, detect and solve any technical issues and IT incidents.

• To understand and improve our services

  We will perform research and analysis about your use of, or interest in, our products, services, or content, or products, services or content offered by others. We do this to help make our products better and to develop new products.

• To send you newsletters to which you have decided to subscribe

  Subject to your opt-out preferences, we may send you emails about new product features or other news about Wooclap or on topics we think would be relevant to you. You may opt out of receiving these communications at any time and at no cost.

  Please visit the Opt-out choices section below.

• To communicate with you

  We may process your personal data in order to:

  • communicate with you for administrative purposes. We may contact you to inform you about changes in our services, our service offering and other important service related notices, such as changes to the Notice or about security or fraud notices.
  • ensure the proper functioning of our services. We may send you service and administrative emails to ensure the service is working properly. We will also email you if an event report becomes available. These messages are considered part of our services and you may not opt out of these messages.
  • for general customer and support services. We will also use your information to respond to your questions, comments and inquiries.

• Protecting Rights and Interest

  We will use your information to protect our rights and interests as well as the rights and interests of our users and any other person, as well as to enforce this Notice or our Terms of Service.

• Legal Compliance

  We may use your information to comply with applicable legal or regulatory obligations, including formal requests from law enforcement or other governmental authorities.

• Other

  We also may use your information to manage our business or perform functions as otherwise described to you at the time of collection subject to your consent. Please read all online agreements carefully before accepting them.

We rely on the following legal grounds to process your personal information:

• Consent

  We may use your personal information as described in this Notice subject to your consent. To withdraw your consent, please contact us at dpo@wooclap.com or fill out this simple form. You may also refrain from providing, or withdraw, your consent for cookies. Please visit the Opt-out choices section below for more information on opt-outs.

• Performance of a contract

  We may need to collect and use the personal information of Wooclap Users, as applicable, to perform our contractual obligations.

• Legitimate Interests

  We may use your personal information for our legitimate interests to provide our application and services while ensuring that we process your data securely, as well as with a view to improving our services and the content on our application. We process information on behalf of our customers who have legitimate interests in operating their businesses. We may use technical information as described in this Notice and use personal information for our marketing purposes consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable law.

About Cookies

When you are using our website, we collect personal data you passively provide to us in the form of cookies and other similar technologies. A cookie is a unique text file that a website sends to your browser and is stored on your computer’s hard drive. It is used to store a website user’s configuration and preferences (e.g., language). Cookies further enable us to collect information, such as your browser type and version, your internet service provider, your IP address, the various pages you are visiting on our website or other websites you may have visited. This information is of value to us as we use it to improve your visit and provide you with a personalized experience when you visit our website. Cookies may contain unique identifiers, which may be considered personal data. Cookies comportments and uses are different on Wooclap Website and Wooclap user application.

More information in the Wooclap Cookie Policy.

We use different types of cookies:

• Strictly necessary cookies

  These cookies are necessary for a correct functioning of our website and for the use of the services contained therein. In their absence, our website or at least some sections, may not work properly. Therefore these cookies are always used regardless of the users’ preferences. This category of cookies is always sent from our domain. Users may delete these cookies via their browser settings.

• Analytics cookies

  These cookies are used to collect information on the use of our website, such as, for instance, the pages visited more frequently. These cookies are sent from our domain or from third party’s domains.

• Google AdWords Remarketing Cookies

  These cookies allow us to help us deliver targeted online adverts based on past visits to our website on various third party websites across the internet.

• Cookies for the integration of third parties’ functionalities

  These cookies are used in relation to the functionalities of the website (e.g. icons of social media networks for sharing of content or for the use of the services provided by third parties). These cookies are sent from our domain or from a third party’s domain.

We advise to allow the use of cookies in order for your browser to work properly and to optimise the use of our website. However, if you do not feel comfortable with the use of cookies, it is possible to opt out and prevent your browser from recording them. How you can manage your cookies depends on the browser you use:

With which parties does Wooclap share your personal data and why?

We do not share your personal information with others except as indicated within this Notice or when we inform you and give you an opportunity to opt out of having your personal information shared.

• Third party service providers, agents or contractors

  We use other companies, agents or contractors ("Service Providers") to perform services on our behalf or to assist us with providing services to you. For example, we may engage Service Providers to provide services such as marketing, advertising, communications, infrastructure and IT services, to provide customer service, and to analyze and enhance data (including data about users' interactions with our service). These Service Providers may have access to your personal or other information in order to provide these functions. In addition, some of the information we request may be collected by third party providers on our behalf. We require our Service Providers to agree to take reasonable steps to keep the personal information that we provide to them secure. We do not authorize them to use or disclose your personal information except in connection with providing their services. The data transfers are limited to what is strictly necessary for providing the service, and we pay a great deal of attention to supplementary security measures (legal, technical and organizational) implemented by our Service Providers.

• Authorised Third Parties

  We share data with third parties when the transfer has been authorised directly and explicitly by you, the user.

• Affiliates

  We may disclose your information to current or future affiliates or subsidiaries for research, marketing, and other purposes consistent with this Privacy Notice.

• Business Transfers

  We may engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this Notice. In such transactions, customer information is typically one of the business assets that is transferred or acquired by a third party. If we are acquired by or merged with another company, if we sell or transfer a business unit or assets to another company, in the unlikely event of a bankruptcy proceeding, or as part of any other similar business transfer, you acknowledge that such transfers may occur.

• Law enforcement, government and regulatory agencies or to other third parties as required by, and in accordance with applicable law or regulation

  Within the limits of the applicable laws, we share your personal data to authorities, law enforcement and government agencies upon their request in order to prevent criminal activities, meet national security requirements or respect law enforcement injunctions. Such requests will be fulfilled only where we are permitted to do so in accordance with applicable law or regulation.

We may transfer your data to third parties in countries outside the European Economic Area. Such transfer will only occur if:

• the country to which the personal data is sent to falls under a Commission adequacy decision; or
• in absence of such decision, under an agreement compliant with EU requirements regarding the transfer of personal data to data controllers or data processors outside the EEA (e.g., standard contractual clauses approved by the Commission). For those transfers, a Transfer Impact Assessment (TIA) is made by Wooclap. In order for this data transfer to occur, this assessment should demonstrate that the data transfers are limited to what is strictly necessary, and protected by appropriate supplementary measures (legal, technical and organizational) as described by the European Data Protection Board.

Subprocessors

In order to comply with the provisions set forth by the General Data Protection Regulation (GDPR), we require our subprocessor to have in place a Data Processing Agreement with us. Here is a table summarizing our subprocessors involving personal data transfers as defined in GDPR.

Which rights do you have and how can you exercise them?

Wooclap respects to the fullest extent the rights you have as a data subject. These rights include:

• Right to access

  Within the limitations of the applicable law, if you can prove your identity, you have the right to access the personal data Wooclap has on you. This includes confirmation as to whether or not we have any data on you, the purposes for which we process your data, the types of personal data concerned, the recipients to whom your personal data are disclosed and the rights you have under the GDPR.

• Right to rectification

  You have the right to rectify inaccurate, incorrect or outdated personal data we may have on you. Where personal data is incomplete, you have the right to complete it, including by means of providing a supplementary statement.

• Right to erasure

  You have the right to have your personal data erased without undue delay if one of the following conditions applies:

  • The personal data is no longer necessary for the purpose for which it was collected
  • You withdraw your consent, if the legal basis for processing is consent
  • You exercise your right to object and we have no overriding legitimate grounds to continue the processing
  • The personal data has been unlawfully processed
  • We have to erase your personal data in order to be in compliance with a legal obligation under EU or Member State law.

• Right to restriction of processing

  You have the right to obtain from us restriction to processing your personal data if one of the following conditions applies:

  • For the period enabling us to verify the accuracy of your personal data, if you have contested the accuracy of the personal data
  • The processing is unlawful and you request the restriction of processing instead of the erasure of the data concerned
  • We no longer need the personal data for the purposes for which it was collected but you need it for the establishment, exercise or defence of legal claims
  • When you exercised your right to object, for the period we need to verify whether the legitimate grounds we rely upon override yours

• Right to data portability

  You have the right to ask us to send you the personal data you directly provided to us in a structured, commonly used and machine-readable format and transfer it to another data controller.

• Right to object & not be subject to automated individual decision making (including profiling)

  Within the limits of the applicable law, you have the right to object, at any time and on grounds specifically related to your particular situation, to the processing of your personal data, provided that we process the data concerned based on our legitimate interest. In such cases, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or the processing is necessary for the establishment, exercise or defence of legal claims.

  Furthermore you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you.

• The right to withdraw your consent

  You have the right to withdraw your consent at any time for the processing activities for which we requested your consent. Any processing of your personal data we may have performed before your withdrawal shall remain lawful.

• The right to lodge a complaint with the supervisory authority

  You have the right to lodge a complaint with the competent supervisory authority such as, but not limited to the Belgian Data Protection Authority (formerly known as the Privacy Commission, see https://www.privacycommission.be/).

You can exercise your data subject rights and submit your requests via dpo@wooclap.com or by filling out this simple form. We will duly address all your privacy related requests. Furthermore, within a period of one month, we will provide you either with a comprehensive answer or with clear reasons why answering to the request may take longer than anticipated.

Your opt-out choices

• Account. In order to keep your personal information accurate and complete, you can log in to review and update your account information, including contact and billing information, via your account settings page. You may also contact us to request information about the personal data we have collected from you and to request the correction, modification or deletion of such personal information. We will do our best to honor your requests subject to any legal and contractual obligations. If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, contact us at dpo@wooclap.com, using our live chat widget (Intercom) the address set forth at the end of this Notice, or you may fill out this simple form. Subject to applicable law, we will retain and use your account information only as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
• E-mail. As described above, if you do not wish to receive promotional emails from us, you may opt out at any time by following the opt-out link contained in the email itself. Please note that it may take up to ten (10) days to process your request. Please also note that if you opt out of receiving marketing communications from us, we may continue to send to you service-related emails which are not available for opt-out. If you do not wish to receive any service-related emails from us, you have the option to deactivate your account.
• Cookies. You may also refrain from providing, or withdraw, your consent for cookies. Your browser’s help function should contain instructions on how to set your computer to accept all cookies, to notify you when a cookie is issued, or to not receive cookies at any time. Here, you may find instructions for your browser: https://www.cookiesandyou.com/disable-cookies/.
• Third Party Analytics Services. Some of the services used provide the ability to opt-out. You may opt-out of Google Analytics’, Hotjar’s and Mixpanel’s services using Opt-Out Features on their respective websites.
• The Google Analytics service is provided by Google Inc and only used on the Wooclap Website. You can opt-out from Google Analytics service from using your information by installing the Google Analytics Opt-out Browser tool: tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy.
• Mixpanel is provided by Mixpanel Inc. You can prevent Mixpanel from using your information for analytics purposes by opting out at www.mixpanel.com/optout. For more information on what type of information Mixpanel collects, please visit the Mixpanel’s Terms of Use page at https://mixpanel.com/legal/terms-of-use/.
• Additional Rights. Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority.
• Do Not Track. We do not currently recognize or respond to browser-initiated Do Not Track signals as there is no consistent industry standard for compliance. However, Google Analytics’, Hotjar’s and Mixpanel’s services do honor this signal.
• Wooclap do not use, nor intend to use, user-generated content or personal data to train AI models. Wooclap AI-related features can be disabled into your account settings or directly for an entire organisation by contacting your Customer Success Manager.

How long will Wooclap keep your personal data?

Wooclap will only retain your personal data for as long as is necessary to fulfill the purpose for which we collected it, and as long as the user account is active (see below). However, we may have to keep your data for longer if we have a legal obligation or a legitimate interest for doing so (e.g., obligation to retain your data in the framework of a criminal investigation or for tax purposes). Wooclap has a data retention policy where inactive accounts are deleted after some time. This retention period can be customised by the Wooclap Client.

Security and storage of information

We have taken reasonable steps to help protect the personal information we collect such as using SSL encryption everywhere. Unfortunately, no measures can be guaranteed to provide 100% security. Accordingly, we cannot guarantee the security of your information in all circumstances.

You should take steps to protect against unauthorized access to your device and account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

We retain the personal data we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected, to perform our contractual and legal obligations, and for any applicable statute of limitations periods for the purposes of bringing and defending claims.

Finally, if you have any questions about Wooclap's products security or if you discover any vulnerabilities, you can contact the Wooclap Security team directly at security@wooclap.com. We will do our best to provide you an answer or the asked update as soon as possible.

Third-party links

Our Platform may contain links to third-party websites and applications. Subject to your opt-out preferences (see Your Opt-out Choices), we may also use third-party advertisers, ad networks, and other advertising, marketing, and promotional companies, to serve advertisements on our websites. Any access to and use of such linked websites and applications is not governed by this Notice but instead is governed by the Privacy Notices of those third parties. We do not endorse these parties, their content, or any products and services they offer, and we are not responsible for the information practices of such third-party websites or applications.

GÉANT Data Protection Code of Conduct

Our platform adheres to the GÉANT Data Protection Code of Conduct as outlined here: https://www.geant.net/uri/dataprotection-code-of-conduct/v1.

Changes to the notice

This Notice is current as of Effective Date set forth above. We may change this Notice from time to time, and if we do we’ll post any changes, including any material changes, on this page, so please be sure to check back periodically. If you continue to use Wooclap after those changes are in effect, you agree to the revised Notice.