Privacy Policy

(Effective: March 1, 2019)

This Privacy Policy describes how Wexford Entrepreneurial Partners collects, uses and discloses information, and what choices you have with respect to the information.

This version of the Privacy Policy reflects and incorporates the requirements of applicable data protection law. In addition, we have worked to make the Privacy Policy clearer and more understandable by:

organizing it into the sections listed in the Table of Contents below,
providing a series of examples that help illustrate how the policies may be implemented by Wexford Entrepreneurial Partners and
defining and capitalizing a few terms that are used more than once for simplicity and brevity.

When we refer to “Wexford”, we mean the Wexford Entrepreneurial Partners entity that acts as the controller or processor of your information, as explained in more detail in the “Identifying the Data Controller and Processor” section below. When we refer to “You” we are referring to you as an Authorized User on an account controlled by you individually. When we refer to “Customer” we are referring to an organization or entity that has a Customer Agreement with Wexford.

Applicability of This Privacy Policy

This Privacy Policy applies to Wexford’s Services and platform, including the associated Wexford mobile and desktop web applications (collectively, the “Services”), wexfordepartners.com and other Wexford websites such as wexfordepartners.knack.com (collectively, the “Websites”) and other interactions (e.g., Customer service inquiries, user conferences, etc.) you may have with Wexford. If you do not agree with these terms, do not access or use the Services, Websites or any other aspect of Wexford’s business.

This Privacy Policy does not apply to any third party applications or software that integrate with the Services through the Wexford platform (“Third Party Services”), or any other third party products, services or businesses. In addition, a separate agreement governs delivery, access and use of the Services by a Customer (the “Customer Agreement”), including the processing of any messages, files or other content submitted through Services accounts (collectively, “Customer Data”). If you have any questions about specific Account settings and privacy practices, please contact the Wexford. If you have received an invitation to join a Customer Account but have not yet created an account, you should request assistance from the Customer that sent the invitation.

Information We Collect and Receive

Wexford may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:

Customer Data. Customers or individuals (including Customer employees) granted access to a Customer Account by a Customer (“Authorized Users”) routinely submit Customer Data to Wexford when using the Services.
Other Information. Wexford also collects, generates and/or receives Other Information:
- Customer Account and Account Information.
- Usage Information.
  - Services Metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users work. For example, Weford logs the Customer Accounts, groups, people, features, content and links you interact with, the types of files shared and what Third Party Services are used (if any).
  - Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
  - Device information. Wexford collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
  - Location information. We do not receive location information.
- Cookie Information. Wexford uses cookies and similar technologies in our Websites and Services that help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services.
- Third Party Services. Customer can choose to permit or restrict Third Party Services for their Customer Account. Typically, Third Party Services are software that integrate with our Services, and Customer can permit its Authorized Users to enable and disable these integrations for their Customer Account. Once enabled, the provider of a Third Party Service may share certain information with Wexford. For example, if a cloud storage application is enabled to permit files to be imported to a Customer Account, we may receive user name and email address of Authorized Users, along with additional information that the application has elected to make available to Wexford to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third Party Services to understand what data may be disclosed to Wexford. When a Third Party Service is enabled, Wexford is authorized to connect and access Other Information made available to Wexford in accordance with our agreement with the Third Party Provider. We do not, however, receive or store passwords for any of these Third Party Services when connecting them to the Services.
- Contact Information. In accordance with the consent process provided by your device, any contact information that an Authorized User chooses to import (such as an address book from a device) is collected when using the Services.
- Third Party Data. Wexford may receive data about organizations, companies, industries, markets, business and financial matters, Website visitors, marketing campaigns and other matters related to our business, including from parent corporation(s), affiliates and subsidiaries, our partners, our Customers or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
- Additional Information Provided to Wexford. We receive Other Information when submitted to our Websites or if you participate in and interact with our social media accounts or otherwise communicate with Wexford.

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as Customer Account setup details, is not provided, we may be unable to provide the Services.

How We Use Information

Customer Data will be used by Wexford in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Wexford is a processor of Customer Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to a Customer Account, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.

Wexford uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, Wexford uses Other Information:

To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at an Authorized User’s request.
As required by applicable law, legal process or regulation.
To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
To develop and provide search, learning and productivity tools and additional features. Wexford tries to make the Services as useful as possible for specific Customer Accounts and Authorized Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, channels or expertise to an Authorized User, make Services suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience or create new productivity features and products.
To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about Wexford. These are marketing messages so you can control whether you receive them.
For billing, account management and other administrative matters. Wexford may need to contact you for invoicing, account management and similar reasons and we use account data and Information to administer accounts and keep track of billing and payments.
To investigate and help prevent security issues and abuse.

If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, Wexford may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”

Data Retention

Wexford will retain Your Data and Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. The deletion of Customer Data and other use of the Services by Customer may result in the deletion and/or de-identification of certain associated Other Information. Wexford may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for Wexford to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

How We Share and Disclose Information

This section describes how Wexford may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and Wexford does not control how they or any other third parties choose to share or disclose Information.

Customer’s Instructions. Wexford will solely share and disclose Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and in compliance with applicable law and legal process.
Displaying the Services. When an Authorized User submits Other Information, it may be displayed to other Authorized Users in the same or connected Customer Accounts. For example, an Authorized User’s email address may be displayed with their Customer Account profile.
Collaborating with Others. The Services provide different ways for Authorized Users working in independent Customer Accounts to collaborate, such as shared groups. Other Information, such as an Authorized User’s profile Information, may be shared, subject to the policies and practices of the other Customer Account(s).
Customer Access. Owners, administrators, Authorized Users and other Customer representatives and personnel may be able to access, modify or restrict access to Other Information. This may include, for example, our Customer using Service features to export logs of Customer Account activity, or accessing your profile details.
Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business and Services. These third parties may, for example, provide virtual computing and storage services. Additional information about the subprocessors we use to support delivery of our Services is set forth at Wexford Subprocessors.
Third Party Services. Customer may enable or permit Authorized Users to enable Third Party Services. When enabled, Wexford may share Other Information with Third Party Services. Third Party Services are not owned or controlled by Wexford and third parties that have been granted access to Other Information may have their own policies and practices for its collection and use. Please check the privacy settings and notices in these Third Party Services or contact the Third Party Services provider directly with any questions.
Corporate Affiliates. Wexford may share Other Information with its corporate affiliates, parents, partners and/or subsidiaries.
During a Change to Wexford’s Business. If Wexford engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Wexford’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business, in marketing the Services, or research purposes, such as telling a prospective Wexford customer the average amount of time spent within a typical Customer Account.
To Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process.
To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of Wexford or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
With Consent. Wexford may share Other Information with third parties when we have consent to do so.

Security

Wexford takes security of data very seriously. Wexford works hard to protect Other Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process and store, and the current state of technology. Given the nature of communications and information processing technology, Wexford cannot guarantee that Information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from unauthorized access or intrusion by others.

Age Limitations

To the extent prohibited by applicable law, Wexford does not knowingly allow or authorize the use of our Services and Websites by minors (e.g. anyone younger than 16 years old or other applicable legal age). If you learn that any minor has used our Services or Website, or unlawfully provided us with personal data, please contact us immediately and we will takes steps to delete such information.

Changes To This Privacy Policy

Wexford may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business, Services and delivery or Services that involve a change to our Privacy Policy. We will post the changes to this Privacy Policy page of our Website and encourage you to review our Privacy Policy on a regular basis to stay informed. If we make changes that materially alter your privacy rights, Wexford will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. And again, you must contact the Wexford if you wish to request the removal of Personal Data under the Customer’s control.

Identifying the Data Controller and Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Customer Data. In general, Wexford is the processor of Customer Data and the controller of Other Information.

Your Rights

Individuals located in certain countries, including the European Union Economic Area, have certain statutory rights in relation to their Personal Data, including under the General Data Protection Regulation (“GDPR”). Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact Customer for additional access and assistance.

To the extent that Wexford’s processing of your Personal Data is subject to the GDPR, Wexford relies on its legitimate business interests, described above, to process and use your Personal Data. Wexford may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Wexford’s use of your Personal Data for this purpose at any time.

It is intended that this Privacy Policy be in compliance with GDPR. To the extent that any of the provisions of this Privacy Policy create any ambiguity or potential conflict with GDPR, then this Privacy Policy shall be construed and interpreted to be in compliance with GDPR and any such provisions shall be deemed modified in accordance with such intent.

Contacting Wexford Entrepreneurial Partners

Please also feel free to contact Wexford if you have any questions about this Privacy Policy or Wexford’s practices, or if you are seeking to exercise any of your legal or statutory rights. You may contact us at info@wexfordepartners.com.