Website privacy policy

Version Date: August 03, 2018
GENERAL
we45
(“Company” or “we” or “us” or “our”) respects the privacy of its users (“user” or “you”) that use our website located at www.we45.com and/or www.orchestron.io, including other online forms (inquiry, workshop, and/or webinar forms, demo request forms), blogs, or open source software related or connected thereto (collectively, the “Website”). The following Company privacy policy (“Privacy Policy”) is designed to inform you, as a user of the Website, about the types of information that Company may gather about or collect from you in connection with your use of the Website. It also is intended to explain the conditions under which Company uses and discloses that information, and your rights in relation to that information. Changes to this Privacy Policy are discussed at the end of this document. Each time you use the Website, however, the current version of this Privacy Policy will apply. Accordingly, each time you use the Website you should check the date of this Privacy Policy (which appears at the beginning of this document) and review any changes since the last time you used the Website.

Our business is headquartered in India and is subject to the Indian Provincial & Federal Laws. We also, have a Subsidiary that is located in the United States of America. Both the entities work in concert with each other in order to provide security services to our clients. However, the website is hosted on servers located in the United States of America. Therefore, if you are accessing our Website from jurisdictions other than those mentioned above, please be advised that you are transferring your personal information to our Headquarters in India and to our Subsidiary in the United States of America for processing, and by using our Website, you consent to that transfer and use of your personal information in accordance with this Privacy Policy.

You also agree to abide by the applicable laws of applicable provinces and the Indian federal law concerning your use of the Website and your agreements with us. Any persons accessing our Website from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use and disclosure, different from those of the jurisdictions mentioned above may only use the Website in a manner lawful in their jurisdiction. If your use of the Website would be unlawful in your jurisdiction, please do not use the Website.

NOTE:  BY USING OR ACCESSING THE WEBSITE, YOU ARE ACCEPTING THE PRACTICES  DESCRIBED IN THIS PRIVACY POLICY.
GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION

Users of the Website Generally
“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operators, Company gathers from users of the Website Non-Personally-Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system, browser type and the locations of the websites the user views right before arriving at, while navigating and immediately after leaving the Website. Although such information is not Personally-Identifying Information, it may be possible for Company to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity as well as other statistical usage data. Company analyzes Non-Personally-Identifying Information gathered from users of the Website to help Company better understand how the Website is being used. By identifying patterns and trends in usage, Company is able to better design the Website to improve users’ experiences, both in terms of content and ease of use. From time to time, Company may also release the Non-Personally-Identifying Information gathered from Website users in the aggregate, such as by publishing a report on trends in the usage of the Website.

Web Cookies
A “Web Cookie” is a string of information which assigns you a unique identification that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the website. We use cookies on the Website to keep track of services you have used, to record registration information regarding your filling of the online forms (enquiry, workshop and/or webinar forms), to record your user preferences, and to facilitate purchase procedures. Company also uses Web Cookies to track the pages that users visit during each Website session, both to help Company improve users’ experiences and to help Company understand how the Website is being used. As with other Non-Personally-Identifying Information gathered from users of the Website, Company analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help Company, its partners and others better understand how the Website is being used.

Moreover, our entire website platform is hosted by HubSpot. HubSpot uses a range of different cookies that help them in maintaining the functionality of our website. Therefore, if any user or customer wants to know more about the cookies that are placed on their computers (with their express consent), they are requested to visit https://legal.hubspot.com/cookie-policy and go through their cookies policy.

WEBSITE USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.

AS PER THE NEW REGULATION OF GDPR OUR WEBSITE HAS PLACED A COOKIE CONSENT BANNER WHICH SEEKS THE EXPRESS CONSENT OF OUR USERS REGARDING THE PLACING OF COOKIES ON THEIR COMPUTERS. THE VISITORS OF OUR WEBSITE HAVE THE RIGHT TO DISALLOW THE PLACING OF COOKIES BUT AT THE EXPENSE OF LOST FUNCTIONALITY.

NOTE: SINCE THE CONSENT OF THE USERS OF OUR WEBSITE IS OUR UTMOST PRIORITY, WE WILL SEEK THE EXPRESS AND EXPLICIT CONSENT OF OUR USERS BEFORE PLACING ANY WEB COOKIES. ALTHOUGH, IT MUST BE UNDERSTOOD THAT THE SOLE PURPOSE OF PLACING WEB COOKIES IS TO MONITOR AND IMPROVE OUR WEBSITE, AND TO PROVIDE A CUSTOMISABLE USER EXPERIENCE (BASED ON THE USERS’ PREFERENCES).

Web Beacons
A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether or not a user has viewed a particular web page or an email. Company may use Web Beacons on the Website and in emails to count users who have visited particular pages and viewed emails. Web Beacons are not used to access users’ Personally-Identifying Information. They are a technique that the Company may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information, including a Web Cookie number, time and date of a page or email view and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered, permitting you to accept or decline Web Cookies on an individual basis.  

Analytics
We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to optimize your browsing experience based on your past activity on the Website. The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/) and/or opt out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings (www.google.com/settings/ads).

COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION

Service Acquisition & Inquiry
As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. Company may collect a range of Personally-Identifying Information from and about Website users. Much of the Personally-Identifying Information collected by Company about users is information provided by users themselves when (1) subscribing for our bi-weekly blogs, (2) filling in specific forms to download open source software, (3) filling in enquiry forms, (4) filling in workshop forms, (5) filling in webinar forms, (6) requesting a demo for Orchestron, (7) downloading the free version of Orchestron and (8) signing up for newsletters. That information may include each user’s name, address, email address and telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). Users of the Website are under no obligation to provide Company with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website features.
BY FILLING IN ANY OF OUR ONLINE FORMS, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.

Personal Data
While using our Website, we may ask you to provide us with certain Personally-Identifying Information that can be used to identify you (“Personal Data”). Personally-Identifying Information may include, but is not limited to the following:
- Email address
- First name and last name
- Phone Number
- Company Name
- Designation at Company
- Business Function (such as Dev, QA, Security, Finance etc)Billing Address (Address, State, Province, ZIP/Postal code, City)

The purpose of collecting the aforementioned information is to facilitate the service acquisition of the customer and to better understand their needs to be able to advise them regarding which service to acquire.
The above mentioned information is not collected from users that only visit the website; rather it is collected from users that acquire a service or fill one of the many online forms available on our website.
However, we respect the “right to privacy” of our users and if they wish to get their Personally-Identifying Information permanently deleted from our databases, they can contact us, and we shall delete their Personally-Identifying Information as early as practically possible.

Company Communications
We may occasionally use your name and email address to send you notifications regarding new services offered by the Website that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. Generally, you may opt out of such emails at the time of registration or by following the unsubscribe link that comes along with these company communications.

Company Disclosures
Company will disclose Personally-Identifying Information under the following circumstances:
- By Law or to Protect Rights.
When we believe disclosure is appropriate, we may disclose Personally-Identifying Information in connection with efforts to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of Company, our users, our employees or others; to comply with applicable law or cooperate with law enforcement; to enforce our Terms of Use or other agreements or policies, in response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.  
- Marketing Communications.
Unless users opt-out from receiving Company marketing materials upon registration, Company may email users about products and services that Company believes may be of interest to them. If you wish to opt-out of receiving marketing materials from Company, you may do so by following the unsubscribe link in the email communications, by going to your account settings (if applicable) or contacting us using the contact information mentioned at the end of this document.
- Third-Party Service Providers. We may share your Personally-Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include providing customer service, performing business and sales analysis, supporting the Website’s functionality and other features offered through the Website. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose whatsoever, as established in their respective privacy policies.
- Business Transfers; Bankruptcy. Company reserves the right to transfer all Personally-Identifying Information in its possession to a successor organization in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of Company’s assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personally-Identifying Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and are given an opportunity to affirmatively opt-out of it. Personally-Identifying Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor organization.

Changing or Removal of Personally-Identifying Information
You may at any time review or change your Personally-Identifying Information by going contacting us at the information given at the end of this document.  Upon your request, we will change or delete your Personally-Identifying Information from our active databases. Such information will be changed or deleted as soon as practicable. Moreover, we allow our users to amend or change or rectify any of their Personally-Identifying Information, and such a feature will be available to all users. Additionally, we keep a history of changed information to investigate suspected fraud with your account, but the users will have the option of having any such history to be permanently deleted from our active databases.

Access to Personal Data
The users of this Website have well-defined rights when it comes to having access to their Personally-Identifying Information. By submitting a User Access Request, our Website shall provide the following information free of charge to the user;
1. What personal information pertaining to the user is being processed;
2. Why this information is being processed;
3. Who has access to this personal information about the user;
4. How this personal information is being used in automated decisions; and (or)
5. What processes are using this information?

A User Access Request will be completed within a time period of 30 days and will include a copy of their personal information. In order to access their personal data the users are requested to send an email with the subject line saying. “User Access Request” and we shall return their email with the above mentioned details in the mentioned timeframe of 30 days. Moreover, this feature is only for the residents of the European Union. Any request made by users not residents of the European Union shall be entertained on a case by case basis, and the decision shall be at the sole discretion of the Company In event the user has any further questions regarding the use and the privacy of their Personally-Identifying Information; they can contact our Privacy Officer as indicated at the end of this document.

General Use
Company uses the Personally-Identifying Information in the file we maintain about you, and other information we obtain from your current and past activities on the Website (1) to deliver the products and services that you have requested; (2) to manage your account and provide you with customer support; (3) to communicate with you by email, about products or services that may be of interest to you from us; (4) to develop and display content tailored to your interests on the Website; (5) to resolve disputes and troubleshoot problems; (6) to measure consumer interest in our services; (7) to inform you of updates; (8) to customize your experience; (9) to detect and protect us against error, fraud and other criminal activity; (10) to enforce our Terms of Use; and (11) to do as otherwise described to you at the time of collection. At times, we may look across multiple users to identify problems. In particular, we may examine your Personally-Identifying Information to identify users using multiple user IDs or aliases. We may compare and review your Personally-Identifying Information for accuracy and to detect errors and omissions. We may use financial information or payment method to process payment for any purchases made on the Website, enroll you in the discount, rebate, and other programs in which you elect to participate, to protect against or identify possible fraudulent transactions and otherwise as needed to manage our business.

COLLECTION AND USE OF INFORMATION BY THIRD PARTIES GENERALLY
Company contractually prohibits its contractors, affiliates, vendors and suppliers from disclosing Personally-Identifying Information received from Company, other than in accordance with this Privacy Policy. However, third parties are under no obligation to comply with this Privacy Policy with respect to Personally-Identifying Information that users provide directly to those third parties, or that those third parties collect for themselves. These third parties include providers of utilities, widgets, payment processors (i.e. PayPal), CRM (Customer Relationship Management) service providers (i.e. HubSpot) and a variety of other third-party applications accessible through the Website. Company neither owns nor controls the third-party websites and applications accessible through the Website. Thus, this Privacy Policy does not apply to information provided to or gathered by the third parties that operate them. Before visiting a third party, or using a third-party application, whether by means of a link on the Website, directly through the Website or otherwise, and before providing any Personally-Identifying Information to any such third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for that website or application, and should take those steps necessary to, in those users’ discretion, protect their privacy.

SERVICE PROVIDERS
We may employ third party companies and individuals to facilitate our Website (“Service Providers”), to provide the Service on our behalf, to perform services or to assist us in analyzing how our Service is used.Currently, the following third party companies are used to facilitate the functionality of our website;
- Google Analytics (to help us analyze the user-activity and their demographics on our website)
- PayPal (to help us process payments on our Website)
- Zoom (to help us store customer email addresses and to help us in Teleconferencing and hosting Webinars)
- Shopify (to help us sign up customers and facilitate payments for our online or remote training programs
- Amazon Web Services (to help us deliver training programs and hands on lab exercises)

All the aforementioned third party companies do not have any access whatsoever, to the Personally-Identifying Information of our users. All the user data that includes the Personally-Identifying Information is stored on our secure servers.

Moreover, we also we use third-party service providers like HubSpot to help us fulfill our CRM (Customer Relationship Management), and Sales & Marketing needs. Although, the aforesaid service providers do have access to our customers’ email addresses, but they are obligated to use them only for the aforesaid purpose and not anything else.

INTERNATIONAL TRANSFER
Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside India and the United States of America and choose to provide information to us, please note that we may transfer the information, including Personal Information, to our Headquarters in India or to our Subsidiary based in the United States of America, and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer

SECURITY
We take the security of your Personally-Identifying Information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse.  However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures.
We are dedicated to protect all information on the Website as is necessary. However, you are responsible for maintaining the confidentiality of your Personally-Identifying Information by keeping your password and other personal details confidential.
Moreover, we emphasize that protecting your Personally-Identifying Information is our top-priority and that this Website is focused to protect your privacy by design. As previously stated, even the best security measures cannot eliminate all the risks. However, we consider it our utmost responsibility to notify you, as immediately as practically possible, of any data breach that might have occurred on our Website.

PRIVACY POLICY CHANGES
Company may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to Company’s Privacy Policy will be reflected on this page and the date new versions are posted will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you. Users should regularly check this page for any changes to this Privacy Policy. Company will always post new versions of the Privacy Policy on the Website. However, Company may, as determined in its discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact information.

DO-NOT-TRACK POLICY
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.NOTE: we45 (www.we45.com) does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. \

CONTACT US
If you have any questions regarding our Privacy Policy, please contact our Privacy Officer at:
we45 Inc
6017,Snell Ave, #945, San Jose, CA 95123
we45 Solutions India Pvt Ltd
1439, 22nd Main , Banashankari 2nd Stage, Bangalore, India.
Phone Number: +91 80 4212 4067
Email: info@we45.com