Last updated: March 23, 2022
We act as a controller in terms of the information we process concerning our customers. We may also act as a processor of personal data on behalf of our customers. Any and all data collected by us as a processor are handled in strict accordance with applicable privacy laws and the data processing agreement, where applicable.
What We Collect
Our guiding principle is to collect only what we need. Here’s what that means in practice:
Identity & Access
When you sign up for MOWS, we typically ask for identifying information such as your name, email address, and maybe a company name. That’s just so you can personalize your new account, and we can send you invoices, updates, or other essential information. We sometimes also give you the option to add a profile picture that displays in our products, but we do not normally look at or access that picture. We’ll never sell your personal info to third parties.
When you pay for MOWS, 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 and as-of billing address, for account history, invoicing, and billing support. We store your billing address to calculate any sales tax due in the United States or VAT in the EU, to detect fraudulent credit card transactions, and to print on your invoices.
We log all access to all accounts by full IP address so that we can always verify no unauthorized access has happened. We keep this login data for as long as your product account is active.
Web analytics data — described further in the Website Interactions section — are also tied temporarily to IP addresses to assist with troubleshooting cases.
When you browse our marketing pages or applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, page load timing, and which website referred you for statistical purposes like conversion rates and to test new designs. We sometimes track specific link clicks to help inform some design decisions. These web analytics data are tied to your IP address and user account if applicable and you are signed into our Services. For this we use third-party web analytics software.
Cookies and Do Not Track
We do use persistent first-party cookies to store certain preferences, make it easier for you to use our applications, and support some in-house analytics. A cookie is a piece of text stored by your browser to help it remember your login information, site preferences, and more. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to view which cookies have been set and how to manage and delete them, please visit: www.allaboutcookies.org.
At this time, our sites and applications do not respond to Do Not Track beacons sent by browser plugins.
When you write MOWS with a question or to ask for help, we keep that correspondence, including the email address, so that we have a history of past correspondences to reference if you reach out in the future.
We also store any information you volunteer like surveys. Sometimes when we do customer interviews, we may ask for your permission to record the conversation for future reference or use. We only do so if you give your express consent.
Information we do not collect
We don’t collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity, gender expression, or physical and mental abilities or disabilities. You may provide these data voluntarily, such as if you include a pronoun preference in your email signature when writing into our Support team.
We also do not collect any biometric data. You are given the option to add a picture to your user profile, which could be a real picture of you or a picture of something else that represents you best. We do not extract any information from profile pictures: they are for your use alone.
Processing of Personal Data
We process personal data of our customers to offer our services, including the processing and execution of demo requests relating to MOWS, and to contact and send marketing material to the visitors of our websites who submit their information in a form or otherwise with the intent to receive marketing or other information from MOWS. In this context, personal data may be processed for market and customer analysis, reporting and statistical purposes, marketing purposes such as customized marketing, administration notices, database management and maintenance, product suggestions and offers, interaction with external social networks or search engines, access to third party services’ accounts and platforms and newsletters. Personal data may be used for direct marketing, including, where applicable, by electronic means unless objected by the customer.
Further, personal data may be used for invoicing and to send important information to the customer e.g. regarding changes of applicable fees, price list and conditions, or to contact the customer and provide information customized services according to the interests of the customer.
Our databases and all customer data are located in Finland (European Union).
We process personal data on the following basis:
for the performance of the contract between us and the customer (Article 6.1(b) of the GDPR);
for the purposes of our legitimate interests related to the customer and business relationships between us and the customers (Article 6(f) of the GDPR);
to comply with legal obligations applicable to us (Article 6(c) of the GDPR, such as corporate and accounting).
Disclosure of Personal Data
Personal data may be transferred outside the European Union and the European Economic Area (“EU/EEA”), including but not limited to, the United States of America as well as other locations and jurisdictions in which we conduct our business. Such transfers outside the EU/EEA are performed subject to appropriate safeguards such as standard data protection clauses adopted or otherwise approved by the EU Commission in accordance with the GDPR (“Standard Data Protection Clauses”).
The applicable Standard Data Protection Clauses are made available for review to the customer upon request.
The following third parties will receive your personal data for the following purposes as part of the processing activities:
Google Analytics - Site analytics
Google Optimize - A/B testing
Hotjar - Product analytics (heatmaps, user behavior)
Amplitude - Product analytics (events, user behavior)
Sentry - Application performance monitoring
SendGrid - Email delivery and marketing
Stripe - Billing services
We retain our customers’ personal data for 1 year from the customer’s latest purchase or contact with us. Personal data may be, wholly or in part, retained for longer or shorter term if required by applicable law or if there is other justified reason to retain or delete them. In such a case, the customer’s personal data shall be erased with no further delay after there is no longer any need for such a retention.
We evaluate the necessity and accuracy of the Personal Data on a regular basis.
European Union Data Subjects’ Rights
If you are a European Union customer, you have additional rights. European Union customers have a right to request from us:
access to and rectification or erasure of personal data;
for restriction of processing concerning the customer or to object to processing;
to receive, under certain preconditions, customer’s personal data in a structured, commonly used and machine-readable format and to transmit those data to another controller;
objection of certain types of processing such as direct marketing;
objection to automated processing, including profiling — you also have the right to be subject to the legal effects of automated processing or profiling
The customer may exercise the aforementioned rights by sending a written request to us. Where the processing is based on consent, the customer has a right to withdraw such consent at any time. Please note that withdrawal of consent will not affect the lawfulness of processing based on previous consent.
In case the European Union Data Subject considers that its rights under the data protection laws are infringed, the customer may lodge a complaint with the supervisory authority of the customer’s residence in the EU.
We have taken adequate technical and organizational measures in order to keep any collected and stored data safe and to secure it against unauthorized access, loss, misuse or alteration by third parties. We use the latest technologies and methods available to secure the data, including but not limited to encryption, access controls, and firewalls.
All traffic between the customer’s browser and MOWS is encrypted with SSL/TLS.