Privacy policy

Last update: [12.07.2022]

This Partnerway`s Google Workspace Privacy Policy (“Privacy Policy”) is incorporated into the Google Workspace Terms Of Service [www.partner-way.com/terms] under which Partnerway, having a Google Reseller Status, has agreed to provide the Software Products and Online services to Customers (“Terms”). All definitions used in this Privacy Policy have the same meaning given to them in Terms.

This Privacy Policy provides details about the type of your personal data Partnerway, legal entity duly registered and organized under the legislation of Estonia, registration number 16379208, registered office in Harju maakond, Tallinn, Kesklinna linnaosa, Tornimäe tn 3//5//7, 10145 (“Partnerway”, “we”, “us” or “our”) processes after Customer (“you”, “your”) as a Controller trusts Google and Partnerway as processors, and how Partnerway supports your rights to your data.

In this Privacy Policy, “Personal Data” means any information relating to an identified or reasonably identifiable natural person.

This Privacy Policy is intended to meet our transparency obligations under, among other applicable laws, the EU General Data Protection Regulation or “GDPR”.

By filling in and submitting the Registration form to Partnerway you agree that you read, understand, and agree with all internal documents of Google including Data Processing Amendment available at: https://workspace.google.com/terms, Terms and this Privacy Policy.

1. HOW WE RECEIVE YOUR DATA?
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This Privacy Policy applies to you when:

You are visiting website of Partnerway [www.partner-way.com];
You fill in and submit the Registration form on website to use Partnerway`s Services;
You make a payments under provisions of Terms;
You provide the information in the Admin Console, or
You provided your personal details to us in another way.

2. LEGAL BASIS FOR PROCESSING

‍Partnerway processes personal information received from you where:

Partnerway has your consent,
where your personal information is necessary for Partnerway to provide a service under the agreement concluded between you and Partnerway (“Contractual Necessity”), or
where Partnerway has a legitimate interest to process your information and that legitimate interest is not overridden by your data protection interests or fundamental rights and freedoms (“Legitimate interest”).

In some cases, Partnerway may have a legal obligation to process your personal information, or to process your personal information in order to exercise, establish or defend legal claims.

3. TYPES OF PERSONAL DATA PARTNERWAY PROCESSES

Types of Personal Data processed

What this means

Identity Data

First name, last name, job title, company you represent, username or similar identifier.

Contact Data

First name, last name, job title, company, phone number, email address.

Behavioral Data

Pages visited, how long you stayed, how you entered, time of visit

Technical Data

Internet protocol (IP) address, your login data (including user identification and password), browser type and version, operating system and platform and other technology on the devices you use to access our website, location information.

Payment Data

Payment card type; payment card number; billing address, phone number, and email.

Partnerway processes information when you provide it directly to Partnerway when you fill in and submit the Registration form, accept Google Workspace Terms of Services, make a payment, or visit a website.

‍Collected from Third Parties: Partnerway may receive information about you from other sources, including publicly available databases or third parties, and combine this data with information Partnerway already has about you. This helps Partnerway to update, expand and analyze records, identify new customers, and provide information about services that may be of interest to you. If you provide Partnerway personal information about others, or if others give Partnerway your information, Partnerway will only use that information for the specific purpose for which it was provided to Partnerway.

‍Automated Processing Mechanisms: Partnerway and Partnerway’s service providers also use automated processing technologies to process information within some areas of the website. Partnerway uses cookies to store content and preferences which enables Partnerway to process standard information your browser sends to certain websites you visit such as your IP address, browser type and language, and the site you came from as well as pages you visit and links you click on within the Website. Having technical information like this helps Partnerway to improve the Website.

‍No Special Categories of Personal Data: We do not collect and/or process any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

4. YOUR RIGHTS RELATING TO PERSONAL DATA ABOUT YOU

‍Under certain circumstances, by law you have the right to:

Request access to Personal Data about you. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of Personal Data about you. This enables you to ask us to delete or remove Personal Data where there is no lawful basis for us to continue to process it. You also have the right to ask us to delete or remove Personal Data about you where you have exercised your right to object to processing (see below).
Object to processing of Personal Data about you. This right exists where we are relying on our legitimate interest as a legal basis for our processing and, you wish to object to processing on this ground.
Request the restriction of processing of Personal Data about you. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of Personal Data about you. We will provide to you, or a third party you have chosen, Personal Data about you in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent. This right only exists where we are relying on consent as a legal basis to process Personal Data about you (“Consent Withdrawal”).

You may have other rights as may be provided by the applicable legislation.

5. HOW TO EXERCISE YOUR RIGHTS

‍If you want to exercise any of the rights described above, please contact us using the contact details shown here hello@partner-way.com.
‍Typically, you will not have to pay a fee to access Personal Data about you (or to exercise any of the other rights outlined above). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access Personal Data about you (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one (1) month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

6. HOW WE USE PERSONAL DATA ABOUT YOU AND WHY

‍We will only use Personal Data about you for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use Personal Data about you for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.
The table below sets out the purposes for which we use Personal Data, as well as the legal bases we rely on in respect of the relevant purposes for which we use Personal Data about you.

Purpose

Our legal basis for this use of data

Category(ies) of Personal Data involved

Registering of Account

• Identity Data
• Contact Data
• Technical Data
• Payment data

Contractual Necessity

Protection of rights of Partnerway and Google (to ensure that those people who use and access Software Products and Online Services are properly entitled to do so)

• Identity Data
• Contact Data
• Technical Data

Necessary for legitimate interests in ensuring that Partnerways` and Googles` rights are properly protected and contractual agreements are being complied with

Security

• Identity Data
• Contact Data
• Technical Data

Necessary for legitimate interests in ensuring the ongoing security and proper operation of website, Online Services provision, and access to Software Products, together with associated IT services and networks.

Responding to Requests

• Identity Data
• Contact Data
• Technical Data

Contractual Necessity

Provision of Online Services and Access to Software Products

• Identity Data
• Contact Data
• Technical Data
• Payment data

Contractual Necessity

Provision of Technical Support

• Identity Data
• Contact Data
• Technical Data
• Payment data
• Behaviour Data

Contractual Necessity

Billing

• Identity Data
• Contact Data
• Technical Data
• Payment data
• Behaviour Data

Contractual Necessity

Product-related communications and notifications (provide information and updates regarding Software Products and Onlibe Services)

• Identity Data
• Contact Data
• Technical Data
• Payment data

Contractual Necessity

Services-related communications and notifications

• Identity Data
• Contact Data
• Technical Data
• Payment data

Necessary for legitimate interests in communicating with relevant individuals about our Services to ensure that they are used and/or are able to be used appropriately and in accordance with our relevant contractual commitments.

7. WHAT HAPPENS WHEN YOU DO NOT PROVIDE NECESSARY PERSONAL DATA?

‍Where we need to process Personal Data about you either to comply with law, or to perform the terms of the agreement we have with you and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you. For example, we may not be able to provide you with the functionalities of the Website (e.g., register your Account) or we may not be able to respond to or fulfil a request you make of us (e.g., accept new Order).
In this case, we may have to stop you from using our Site or Products but we will notify you if this is the case at the time.

8. LEGAL DISCLOSURES

‍In certain situations, Partnerway may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Partnerway reserves the right to disclose your personal information as required by law and when Partnerway believes in good faith that disclosure is necessary to protect Partnerway’s rights and/or comply with a judicial proceeding, court order, or legal process served on to Partnerway.

9. OBLIGATIONS OF PARTNERWAY

‍The Partnerway undertakes to:

process personal data in relation to which the Customer is the data controller in accordance with written instructions from or on behalf of the Customer, unless applicable law requires other processing of that personal data, in which case Partnerway will inform the Customer (unless that law prohibits Partner from doing so on important grounds of public interest)
ensure that appropriate technical and organizational measures are taken to avoid unauthorized or unlawful processing of that data and against loss or destruction of, or damage to, that personal data;
ensure all of Partnerway’s employees, agents, and contractors who will have access to that personal data have committed themselves to confidentiality or are otherwise under an appropriate obligation of confidentiality;
not by any act or omission place that Customer in breach of the European Data Protection Laws;
inform that Customer promptly and without undue delay of any data protection breaches or unauthorized or unlawful processing, loss, or destruction of, or damage to, that personal data;
obtain prior consent to engage any third party subcontractor to process that personal data on behalf of the Customer and ensure that such third party subcontractor only uses and accesses that data in accordance with the terms of the Customer Agreement and is bound by written obligations requiring it to provide at least the level of data protection required under this Agreement;
taking into account the nature of the processing, assist the Customer by appropriate technical and organizational measures, insofar as this is possible, for the fulfillment of the Customer's obligations under the European Data Protection Laws to respond to requests for exercising the data subject's rights;
assist the Customer in ensuring compliance with any applicable obligations under the European Data Protection Laws related to security, breach notification, data protection impact assessments, and prior consultation with the supervisory authorities, taking into account the nature of processing and the information available to Partner.

REPORTING ISSUES

‍You have a right to report grievances related to privacy with your local data privacy supervisory authority. In Estonia this is AKI and they can be reached at www.aki.ee which can also be contacted by email at info@aki.ee.

If you have questions about this Privacy Policy or if you receive any unwanted, unsolicited e-mail sent by Partnerway or purporting to be sent via Partnerway, please contact Partnerway directly at hello@partner-way.com.
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‍CHANGES TO THE PRIVACY POLICY

‍Partnerway keeps the Privacy Policy under regular review. Any material updates will be communicated to you in writing. This Privacy Policy was last updated on [12.07.2022].