Waxwing privacy policy

Last updated: March 9, 2020

This document describes how and why your data is collected and used in Waxwing. In short, we collect only what is necessar. We don't look at your data unless you explicitly ask us to do so, and we don't share your information with third parties unless there's a specific and inevitable reason to do so.

The register

When someone collection personal information, it creates – in legal terms – a register.

When you sign up for Waxwing, your information will be collected in a register called Waxwing customer register.

The register is operated by Laukka Solutions Oy, a software company based in Tampere, Finland. The full address for the company is as follows:

Laukka Solutions Oy
℅‎ Haulo
Teekkarinkatu 19 A 9
33720 Tampere
Finland

The person in charge for maintaining the register is mr Mika Haulo. You may contact him by email: mika@laukkasolutions.com.

What information is collected and why

When you sign up for Waxwing, we ask for your name, company name, and email address. You'll also choose a password. This is to create an account for you and us to comminicate with you. We'll also record when your account was created and when it was last updated. These are technical details used by the Ruby on Rails software framework on which Waxwing is built.

When you choose to start paying for Waxwing, we ask for your credit card and billing address. That's so we can charge you for service, calculate taxes due, and send you invoices. Your credit card is passed directly to our payment processor and doesn't ever go through our servers. We store a record of the payment transaction, including the last 4 digits of the credit card number, for account history, invoicing, and billing support. We store your billing address to fulfill the requirements of Finnish law, to detect fraudulent credit card transactions, and to print on your invoices.

When you write Waxwing with a question or to ask for help, we'll keep that correspondence, and the email address, for future reference.

Also, when you use Waxwing and its features, you enter data to the system. From the legal point of view, that also counts as collecting data.

In short, we only collect necessary data to provide you with the service and to comply with Finnish laws.

Sharing data with third parties

In general, we don't share any of your data.

The only times we’ll ever share your data:

  • To provide products or services you've requested, with your permission. List of third-party services we use.
  • To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service, or as otherwise required by law.
  • If Waxwing or the companyt it's operated by is acquired by or merged with another company — we don’t plan on that, but if it happens — we’ll notify you well before any info about you is transferred and becomes subject to a different privacy policy.

Your Rights With Respect to Your Information

You may have heard about the General Data Protection Regulation (“GDPR”) in Europe. GDPR gives people under its protection certain rights with respect to their personal information collected by us on the Site. Accordingly, Waxwing recognizes and will comply with GDPR and those rights, except as limited by applicable law. The rights under GDPR include:

  • Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
  • Right to Correction. This is your right to request correction of your personal information.
  • Right to Erasure. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession (also known as the “Right to be forgotten”). However, if applicable law requires us to comply with your request to delete your information, fulfillment of your request may prevent you from using Waxwing services and may result in closing your account.
  • Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority.
  • Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed.
  • Right to Object. This is your right, in certain situations, to object to how or why your personal information is processed.
  • Right to Portability. This is your right to receive the personal information we have about you and the right to transmit it to another party.
  • Right to not be subject to Automated Decision-Making. This is your right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable European law, or is based on your explicit consent.

Many of these rights can be exercised by signing in and directly updating your account information. If you have questions about exercising these rights or need assistance, please contact us at mika@laukkasolutions.com.

Processors we use

As part of the services we provide, and only to the extent necessary, we may use certain third party processors to process some or all of your personal information. For identification of these processors, and where they are located, please see our Subprocessor listing. We have signed appropriate data processing contracts that comply with GDPR with each processor.

Law enforcement

Waxwing won’t hand your data over to law enforcement unless a court order says we have to. We flat-out reject requests from authorities when they seek data without a court order. And unless we're legally prevented from it, we’ll always inform you when such requests are made.

Security & Encryption

All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted. Data isn’t encrypted while it's live in our database (since it needs to be ready to send to you when you need it), but we go to great lengths to secure your data at rest—you can read more about that on our security page.

Cookies

Waxwing uses cookies that are necessary to provide the service. Additional cookies may be used for site analytic services.

Third Parties

You understand that Waxwing uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to provide you with our services. A current list of vendors is available upon request.

Data retention

When you cancel your account, we'll delete all data related to your account. Backup data will be retained for up to 60 days. However, information about payments will be retained according to the Finnish law.

Location of Site and Data

This Site is operated in Finland. Our data centers are located in EU countries.

However, we reserve the right to transfer the Site and its data to service providers outside EU/ETA, if we see that as necessary.

Changes & questions

Waxwing may update this policy once in a blue moon — we’ll notify you about significant changes by emailing the account owner or by placing a prominent notice on our site. You can access, change or delete your personal information at any time via the profile page in the application.

This document is adapted from Basecamp's policy documents, licenced under CC BY 4.0.