Last modified: 14 September 2022
This privacy notice (“Privacy Notice”) applies to all visitors and users of the Webiny hosted services and websites (collectively, the “Website” or “Websites”) and self-managed installations, which are offered by Webiny Inc. and/or any of its affiliates (“Webiny” or “we” or “us”). Please read this Privacy Notice carefully. By accessing or using any part of the Websites or self-managed installations, you acknowledge you have been informed of and consent to our practices with regard to your personal information and data.
Webiny is an open source project and collaborative community, as well as a company. This means that many portions of our Websites, including information you voluntarily provide, will be public-facing for the open sharing of innovative developments, ideas, and information that makes our collaborative community so great. While we are committed to open sharing, we strive to respect the privacy of individual community members and will minimize the information we collect and share. If you do not want to share your information, including personally identifiable information, with other community members and the public, please be thoughtful as to how you interact with our Websites and what information you provide through the Websites (for example, through creating a public profile, project contributions, comments, and blog posts).
Oversight of Data Security is handled by Webiny's respective Data Protection Officers. Should you wish to make modifications, deletions, or additions to any personal data you believe to be captured by Webiny, or if you have any general security concerns, please contact us at firstname.lastname@example.org.
What Information Webiny Collects and Why
Like most website operators, Webiny collects basic non-personally-identifying information from Website visitors of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. We collect this information to better understand how visitors use the Website, to improve our Websites and experience for visitors, and to monitor the security of the Websites. From time to time, Webiny may publicly release non-personally-identifying information collected from Website visitors in the aggregate, e.g., by publishing a report on trends in the usage of the Website.
Webiny also collects potentially personally-identifying information like Internet Protocol (IP) addresses from visitors. Webiny does not use such information to identify or track individual visitors, however. We collect this information to understand how visitors use the Websites, to improve performance and content, and to monitor the security of the Websites.
Webiny may collect statistics about the behavior of visitors to our Websites. For instance, Webiny may reveal how many downloads can be attributed to a particular software version using aggregated statistics that contain anonymous user information only.
Webiny collects anonymous application usage data from each self-managed Webiny instance (Open Source, Business & Enterprise Edition). It is possible to opt out of application telemetry being transferred, and for self-managed Webiny instances, we do not track end users.
Telemetry data that is being collected include:
The protocol used to interact with an instance API
The type of event used via this protocol
The time and frequency of these events
An anonymous identifier of the instance
The Class C network the telemetry data is sent from
Users of the Websites may choose to interact with Webiny in ways that provide us with their personally-identifying information. In some instances, a User ID is generated for form and url tracking, page views, page pings and usage counts in order to ascertain product performance and development. The amount and type of information that Webiny gathers depends on the nature of your interaction with us, as well as the amount of information you choose to share. For example, we ask visitors who use our community slack group to provide a username and email address. We will also collect the information you provide with us in connection with creating an account on the Website. Profile information is shared publicly, as well as activity under your profile. If you report a security vulnerability to Webiny and request public acknowledgment, then we may publicly disclose the personal information you provided to us in connection with the report, including your name to fulfill your request for acknowledgment. In each case, Webiny collects such personally-identifiable information only insofar as is necessary or appropriate to fulfill the purpose of the user’s interaction with or request of Webiny. We will not disclose personally-identifying information other than as described in this Privacy Notice.
Visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent you from engaging in certain Website-related activities or being able to access and use certain features and services.
For details about what information is collected and with whom it is shared, please go to What Information Webiny Collects and Why.
Where We Store Your Data
As part of the services offered to you, for example through our Website, the information you provide to us may be transferred to and stored in countries outside of the European Economic Area (EEA) as we use remote website server hosts to provide the website and some aspects of our service, which may be based outside of the EEA, or use servers based outside of the EEA - this is generally the nature of data stored in “the Cloud”. It may also be processed by staff operating outside the EEA who work for one of our suppliers, e.g. our website server host, or work for us when temporarily outside of the EEA.
We do not use or disclose sensitive personal data, such as race, religion, or political affiliations, without your explicit consent.
Otherwise, we will process, disclose or share your personal data only if required to do so by law or in the good faith belief that such action is necessary to comply with legal requirements or legal process served on us or the website. By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure. You have the right to opt out of our processing your personal data for marketing purposes by contacting us at email@example.com.
Although we try to provide protection, we cannot guarantee complete security for your data, and you take the risk that any sending of that data turns out to be not secure despite our efforts.
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for as described above in section 6, including for the purposes of satisfying any legal, accounting, or reporting requirements, and/or for as long as we have your permission to keep it. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In any event, we will conduct an annual review to ascertain whether we need to keep your personal data. Your personal data will be deleted if we no longer need it.
Information Webiny Does Not Collect
Webiny does not intentionally collect sensitive personal information, such as social security numbers, genetic data, health information, or religious information. Although Webiny does not request or intentionally collect any sensitive personal information, we realize that users might store this kind of information in a Webiny instance by pushing it to us through our libraries or API. If you store any sensitive personal information on Webiny’s servers, you are consenting to our storage of that information.
If you're a child under the age of 13, you may not have an account on the Website. Webiny does not knowingly collect information from or direct any of our Website or content specifically to children under 13. If we learn or have reason to suspect that a user is under the age of 13, we will close the child’s account.
Other countries may have different minimum age limits. If you are below the minimum age for providing consent for data collection in your country, you may not use Webiny.
Basis for Processing Your Information
Performance of a contract. The use of your information may be necessary to perform the contract that you have with us. For example, if you use our Websites to purchase Webiny product subscriptions or services, contribute to a project, create a profile, post and comment through our Websites, or request information through our Websites, we will use your information to carry out our obligation to complete and administer that contract or request.
Legitimate interests. We use your information for our legitimate interests, such as to provide you with the best content through our Websites and communications with users and the public, to improve and promote our products and services, and for administrative, security, fraud prevention and legal purposes.
Consent. We may rely on your consent to use your personal information for certain direct marketing purposes, such as sending you newsletter updates about Webiny products. You may withdraw your consent at any time through the unsubscribe feature provided with each marketing email or by contacting us at the addresses given at the end of this Privacy Notice.
How Webiny Uses and Protects Personally-Identifying Information
Sharing Your Information
Webiny only discloses potentially personally-identifying and personally-identifying information to those of its employees, contractors, and affiliated organizations that (i) need to know that information in order to process it on Webiny's behalf or to provide services available on the Website, and (ii) that have agreed not to disclose it to others.
Please note, email and IP addresses of users of a Webiny deployment may be shared with the respective users of that deployment.
Webiny will not rent or sell potentially personally-identifying and personally-identifying information to anyone. Other than to its employees, contractors, and affiliated organizations, as described above, Webiny discloses potentially personally-identifying and personally-identifying information only when required to do so by law, or when Webiny believes in good faith that disclosure is reasonably necessary to protect the property or rights of Webiny, third parties, or the public at large.
Webiny takes measures reasonably necessary to protect against the unauthorized access, use, alteration, or destruction of potentially personally-identifying and personally-identifying information.
Webiny at its sole discretion may make use of company logos where those companies are using the software that we provide. If you have concerns over the use of your logo, please email firstname.lastname@example.org.
Sharing Your Information
Our employees, contractors and affiliated organizations that process information for us as described above may be located in regions other than your home country; by using the Website, you consent to the international transfer of your information by Webiny. Webiny will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests.
Third Party Processors
Our carefully selected partners and service providers may process personal information about you on our behalf as described below:
Digital Marketing Service Providers
Webiny Communications with You
If you are a registered user of the Websites and have supplied your email address, Webiny may occasionally send you an email to inform you about security, system information, new features, solicit your feedback, or send Webiny product updates. We primarily use our blog to communicate this information, so we aim to keep this type of email communication to a minimum. An unsubscribe link is located at the bottom of each marketing email to allow recipients to update their email preferences and to opt out of such emails.
If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish your request in order to help us clarify or respond to your request or to help us support other users. We will not publish your personally-identifiable information in connection with your request.
Cookies, Tracking Technologies and Do Not Track
We may use third party tracking services, but we don’t use these services to track you individually or collect your personally identifiable-information. We may use these services to collect information about how the Website performs and how users navigate through and use the Website so we can monitor and improve our content and Website performance.
Third party tracking services gather certain simple, non-personally identifying information over time, such as your IP address, browser type, internet service provider, referring and exit pages, timestamp, and similar data about your use of the Website. We do not link this information to any of your personal information such as your user name.
Do Not Track
"Do Not Track" is a privacy preference you can set in your browser if you do not want online services to collect and share certain kinds of information about your online activity from third party tracking services. Webiny does not track your online browsing activity on other online services over time and we do not permit third-party services to track your activity on our site beyond our basic tracking, which you may opt out of. Because we do not share this kind of data with third party services or permit this kind of third party data collection for any of our users, and we do not track our users on third-party websites ourselves, we do not need to respond differently to an individual browser's Do Not Track setting.
Global Privacy Practices
We understand that users from other countries may have different expectations and rights with regard to their privacy. For all Website visitors and users, no matter their country of location, we will:
provide clear methods of unambiguous, informed consent when we do collect your personal information;
only collect the minimum amount of personal data necessary for the purpose it is collected for, unless you choose to provide us more;
offer you simple methods of accessing, correcting, or deleting your information that we have collected, with the exception of information you voluntarily provide that is necessary to retain as is for the integrity of our project code as described further below; and
provide Website users notice, choice, accountability, security, and access, and we limit the purpose for processing. We also provide our users a method of recourse and enforcement.
If you are located in the European Union, you are entitled to the following rights with regard to your personal information and data:
Right of access to your personal data, to know what information about you we hold
Right to correct any incorrect or incomplete personal data about yourself that we hold
Right to restrict/suspend our processing of your personal data
Right to complain to a supervisory authority if you believe your privacy rights are being violated
Additional rights that may apply to you in certain instances:
Right of data portability (if our processing is based on consent and automated means)
Right to withdraw consent at any time (if processing is based on consent)
Right to object to processing (if processing is based on legitimate interests)
Right to object to processing of personal data for direct marketing purposes
Right of erasure of your personal data from our system (“right to be forgotten”) if certain grounds are met
To exercise your privacy rights, you can email us at the address given below in the ‘Contacting Webiny About Your Privacy’ section of this Privacy Notice.
Data Retention and Deletion
If you already have an account on the Websites, you may access, update, alter, or delete your basic user profile information by logging into your account and updating profile settings.
Webiny will retain your information for as long as your account is active or as needed to perform our contractual obligations, provide you services through the Website, to comply with legal obligations, resolve disputes, preserve legal rights, or enforce our agreements.
Data Retention and Contacting Webiny About Your Privacy
If you have questions or concerns about the way we are handling your information, or would like to exercise your privacy rights, please email us with the subject line "Privacy Concern" at email@example.com where we will respond within 30 days of receiving your message.
Privacy Notice Changes
Although most changes are likely to be minor, Webiny may change its privacy notice from time to time, and in Webiny's sole discretion.
We may also provide notification to users who have provided us email addresses of material changes to this Privacy Notice through our Website. Webiny encourages visitors to frequently check this page for any minor changes to its Privacy Notice. Your continued use of this site after any change in this Privacy Notice will constitute your acceptance of such change.
Credit to GitLab for the initial version of the above terms.