Privacy Policy

• To process your personal data in accordance with the terms of this Privacy Policy.
• To use your personal data strictly for the purpose for which the data was collected. For example, when you sign up for a free trial, subscribe to newsletters, request support – we use your data only for that specific purpose.
• To share your personal data with the trusted third parties when it is necessary to provide you with the products and services you requested, or when we have a lawful basis. For example, when you sign up for a free trial we may share your email address with an email automation provider to immediately deliver you the download link. Under no circumstances do we sell, trade or rent your personal data with any third parties.
• To transfer and process your personal data internationally, including in Russia, which may not offer the same level of protection as required in your country. Wherever you reside or are located, we have appropriate safeguards in place to protect your data.

If you do not want your personal data processed, shared or transferred, please do not submit your information to us. In this case, however, you may not be able to use our software, certain features of the website, participate in events, and receive marketing communications.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR VIEWS AND PRACTICES REGARDING YOUR INFORMATION, INCLUDING PERSONAL DATA.

WaveAccess SL Private Limited (“WaveAccess Nordics ApS”, “we”) respects and protects your privacy and personal data. We only collect data necessary to provide you with better products and services. We believe that privacy is one of your basic rights and we want to make sure that our practices are transparent to you.

By accessing and using the Website and Software, you accept and agree to this Policy. If you do not agree to this Policy, do not use this Website and Software.

We collect information about visitors to the Website and users of Software, including potential and current customers, suppliers and partners.

We collect information about you when you provide it to us, when you use our Website and Software, and when other parties provide it to us, as described below.

We collect both personal data and non-personal data. Personal data refers to any information that can be used to uniquely identify you. This may include your name and email address among other things. Non-personal data refers to information that does not identify you individually, as well as anonymised data. For example, website traffic data and software usage statistics.

Under no circumstances do we collect or process special categories of personal data (sensitive data related to your race or ethnicity, political opinions, religious or philosophical beliefs, sex life, sexual orientation, trade union membership, information about your health, and genetic and biometric data).

We only collect personal data which you provide voluntarily. You agree to provide true, accurate and complete information. You are not required to provide us with any of your personal data, but in this case, you may not be able to receive the Software, use certain features of the Website, participate in events, or receive marketing communications.

When you take a free trial: When you sign up for a free trial or download the Software, we may request you to provide your First Name, Last Name, and Email Address.

When you place an order: When you become our customer, including when you download or purchase Software, we may request you to provide your First Name, Last Name, Email Address, Company Name, Billing and Shipping Address, Phone Number, and Payment Details. NOTE: we do not collect and have no access to your credit card details, bank account details or other payment details. Your payment-related information is collected and stored by a third-party payment provider that provides secure payment processing services on our behalf. We only have access to your selected payment method and the last four digits of your credit card number.

When you request support: When you send us a technical support request, we may request you to provide your First Name, Last Name, Email Address and other information relating to your issue.

When you subscribe to newsletters: When you subscribe to marketing communications, for example, newsletters about Software updates and new releases, special offers, blog updates or other news, we may request you to provide your First Name, Last Name, and Email Address.

When you agree to participate in events: When you register for an event, for example, a webinar, survey, contest, or agree to take part in user interviews or other events, we may request you to provide your First Name, Last Name, Email Address, Company Name, Job Title, Phone Number and other information relating to the event.

When you share your feedback: When you use interactive sections of the Website, for example, comments, we may request you to provide your Name or Nickname, Email Address and other information relating to your feedback. NOTE: your email will not be made public. But if you choose to share other information about yourself on public sections of the Website, you do it at your own risk: this information becomes public and is not subject to this Policy.

When we communicate directly: When we communicate directly, by email, phone or other means of communication, we may also obtain additional information you choose to provide. For example, a screenshot of an error during a technical support session, or your testimonial during a user interview.

When you access and use the Website and Software, we may collect certain information about you automatically.

When you use the Website: When you access and use the Website, we may automatically obtain information about how you interact with it. We use this information to analyze how people use our Website and improve your user experience.

The information we collect includes the pages you visit; URL clickstream to, through and from the Website, including date and time; errors; actions you take on the Website; information about your browser, operating system, internet service provider; location data and time zone through IP address, and other technical information.

When you use the Software: When you access and use the Software, we may automatically obtain information about how you interact with it. We use this information to analyze how people use our Software and improve your user experience.

The information we collect includes the features you use, time and number of installations, version of the installed Software, license information, unique identifiers, error logs, crash data and other usage statistics, information about your operating system, Microsoft Excel version you use, type of device, location data through IP address and other technical information. NOTE: under no circumstances do we collect or have access to your work files.

You can stop sharing anonymous usage statistics at any time by disabling this option in the Software settings.

We receive information about you from other legitimate sources, for example, our business partners, service providers, public sources, and social media networks.

Business partners: We work a global network of resellers, affiliates and app stores who help us market, promote, sell, provide consulting, training, and other services relating to the Software.

Service providers: We receive information about you from third-party service providers, for example, payment processing providers, marketing and email automation services, and advertising networks.

We may receive information from these partners, including First Name, Last Name, Email Address, Company Name, Shipping Address, information about your engagement with our online advertisements and marketing emails, information about our Software you have purchased, downloaded or are interested in.

We collect and process your personal data on the following lawful bases:

To perform a contract: We may collect and process your personal data when it is necessary to perform a contract with you, or to take steps at your request to enter into a contract. For example, to provide you with the Software which you have bought or downloaded.

To pursue legitimate interest: We may collect and process personal data if it is considered to be of our legitimate interest, including to develop, market, promote and sell our Software, to operate our business, to protect our legal rights and interests. When we are relying on legitimate interest as a basis for processing your personal data, we will always ensure that your rights and interests do not override this interest.

Other legal bases: We may collect and process personal data if such processing is necessary to comply with the legal requirements or to protect someone’s vital interests.

We collect and process your personal data on the following principles:

• We process personal data on lawful and fair bases.
• We process personal data only to achieve specific purposes for which the data was originally collected.
• We only collect and process personal data that is relevant, sufficient and nonexcessive for such purposes.
• We do not discriminate against users if they choose to exercise their rights provided in this Policy.

The processing of personal data refers to any operation or set of operations which are performed on personal data, with or without automated means, including collection, recording, organisation, accumulation, storage, alteration, retrieval, use, disclosure by transmission, dissemination or otherwise making available, anonymisation, restriction, erasure or destruction. We do not use automated individual decision-making, including profiling.

Most commonly we use collected information for the following purposes:

To process orders: When you become our customer, including when you download or purchase the Software, we may use your data to process your orders, send you download links, license keys, Software updates and order-related information.

To provide support: When you send us a technical support request, we may use your data to receive, respond to, follow up and otherwise communicate with you about your support issues, as well as use it for further Software development.

To carry out events: When you register for events, we may use your data to remind you about, carry out and follow up on a webinar, survey, user interview, contest, or another event you have registered for or agreed to participate in.

To communicate with you: When you contact us with questions, share feedback through various channels (on the Website, during events, on public platforms like social networks) or whenever we communicate directly, by email, phone or other means of communication, we may use your data to respond and follow-up on your inquiry, to further develop our Website and Software, and to inform you about our products and services.

To improve the Website and Software: We use your feedback, suggestions, comments about our Software, as well as information about how you and other users collectively use the Website and Software, we may use this information in order to analyze the performance of the Website and Software, to carry out market and customer research, and to improve our Website and Software and your user experience.

To ensure safety and security: We may use your data and information about how you use the Website and Software to verify your license rights, monitor suspicious and fraudulent activity, and to identify violations of our policies. We may also use your data to contact you on security and privacy issues.

To operate our business: We may use information about you to operate our business, including developing our Software, accounting, auditing, protecting our legal rights and interests, reviewing the performance of our technical support and marketing communications, and other internal activities.

To comply with legal requirements: We may use your data when it is necessary to comply with applicable legal requirements.

For the purposes listed above, we may combine information collected from different sources, as well as combine your personal and non-personal data. This helps us update our records, understand better how you engage with the Website and Software, improve our products and services.

We retain your personal data no longer than it is necessary to fulfil the purposes for which the data was originally collected. After that, or if these purposes are no longer relevant, or if you withdraw your consent to our processing of your data, we will either delete or anonymize your personal data, unless a different period is required by applicable law.

Under no circumstances do we sell, trade or rent your personal data with any third parties.

We may share generic non-personal data and aggregated anonymized information that does not allow any direct association with you, for example, traffic data or software usage statistics, for any purpose.

We may share your personal data when you have given your consent; to perform a contract with you; when it is required by applicable law; in connection with audit requirements; to protect our legal rights and interests, or in connection with acquisition, merger or sale of a business.

You consent that in order to provide you with the Website and Software, we may share your personal data with our trusted third parties that help us operate our business, develop, market and promote the Website and Software. These companies provide us website and software development tools, hosting, secure payment processing, analytics services, marketing and email automation, advertising and other services, which may require them to access your data.

We require all third parties to respect the security of personal data, to process it in accordance with legal requirements, our instructions and principles provided in this Policy.

We encourage you to read the privacy policies of our service providers:

• For secure payment processing: 2Checkout.com Inc
• For developer tools to fix bugs you report: Microsoft Visual Studio
• For email services: Yandex.Mail
• For email automation services: SendGrid
• For web analytics services: Google Analytics, Yandex.Metrica
• For occasional advertising: Google Ad, Yandex.Direct, Facebook
• For displaying globally recognized avatars in Website comments: Automattic Inc
• For online chat on our website: Jivosite Inc

If you do not want your information shared with third parties, please do not submit your information to us.

We take all appropriate legal, technical and organizational measures to protect personal data from unauthorized access, use, disclosure, copying, modification or destruction, and from unintentional loss, misuse and alteration.

We use a variety of secure techniques to protect your information, including SSL protocol to encrypt the information sent through the Website, secure servers, firewalls, antivirus programs, intrusion detection systems, and system penetration testing. Only authorized personnel can access your data.

While we take every step to protect your information, please note that no system can be 100% secure, and we cannot guarantee the security of your information transmitted through the Website. You provide your personal data at your own risk. You agree that we may communicate with you regarding security and privacy issues by the email you have provided to us.

The internet is a global environment and our customers and service providers are located in many countries around the world, so international data transfers may be necessary to provide you with the Website and Software.

Any information you provide or information we collect about you when you use the Website and Software, may be transferred outside the country where you reside or are located to Russian Federation or another country, wherever we or our third-party service providers operate.

You consent to the transfer of all such information internationally, including to Russian Federation, which may not offer the same level of protection as your country requires, and consent to the processing of that information by us and our trusted third-party service providers internationally as described in this Policy.

Wherever you reside or are located, we are committed to provide appropriate safeguards to protect the security of your personal data during the cross-border transfer and to ensure that your data is processed in accordance with this Policy.

If you do not want your information transferred or processed outside of your country, please do not submit your information to us.

Any information you provide or information we collect about you when you use the Website and Software, may be transferred outside of the European Union to Russian Federation or another country, which does not offer an equivalent level of protection as required in the European Union. Article 46 of the Regulation (EU) 2016/679 (General Data Protection Regulation, GDPR) allows transfers of personal data to a third country or to an international organization only if the receiving party has provided appropriate safeguards, and on condition that enforceable data subject rights and effective legal remedies for data subjects are available. We are committed to provide appropriate safeguards described in this Policy.

When you provide us with your personal data, you are guaranteed certain rights:

Right to request access: You may request details of personal data which we have about you, information about the legal basis and purposes for processing this data, how we have obtained it, who we may share it with, how long we retain it and other information about the processing of your personal data for the period of twelve (12) months prior to the request.

Right to request rectification: If you believe that any personal data we have about you is incorrect or incomplete, you may request us to correct it. We will review your request and make changes within seven (7) days. We may need to verify the accuracy of the new data you provide to us.

Right to request erasure: You may request us to delete your personal data when data is no longer necessary for the purposes for which it was originally collected for; there is no lawful basis for us to continue processing it and you have withdrawn your consent; when you have objected to processing (see below); when data has been processed unlawfully; or when we are required to comply with applicable law.

Right to object to processing: At any time you may object to the processing of your personal data if we are processing your data on the grounds of legitimate interest, or if we are processing your personal data for direct marketing purposes.

Right to request restriction of processing: You may request us to suspend the processing of your personal data when you want us to establish the data’s accuracy; when the processing is unlawful but you do not want us to erase it; when we no longer require your data but you need us to hold the data because you need it in order to establish, exercise or defend a legal claim; or when you have objected to the processing of your data and we need to verify whether we override our legitimate grounds.

Right to request transfer of your personal data to you or to a third party : You may request us to provide you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. NOTE: this right only applies to your personal data which you originally provided consent for us to use, or where we used your personal data to perform a contract with you.

Right to withdraw consent: If you have previously consented to our collection and processing of your personal data, you may withdraw your consent at any time. NOTE: this will not affect processing that has already taken place. If you withdraw your consent, you may not be able to use the Software, certain features of the Website, participate in events, or receive marketing communications.

You acknowledge and agree that before acting on any such request, we will need to verify your identity and you may have to provide us with your personal data to do so. If we do not have sufficient information about you or are unable to verify your identity, we may not be able to honor your request. Also, we may not always be able to comply with your request for specific legal reasons. For example, we may not be able to erase data on your request, if we need to keep processing it to comply with accounting regulations.

Like most websites, our Website uses cookies, web beacons and other similar technologies.

Cookies are small text files, which your web browser places on a hard-drive of the device. They contain a unique identifier that helps us identify your device. Cookies store information about your previous visits to the Website, your selected settings, and other information about your visit.

In conjunction with cookies, we also use web beacons, also known as pixel tags and clear GIFs. These are tiny transparent pixel images with a unique identifier. We use web beacons on the Website and in our marketing HTML-based emails to determine, for example, whether you have opened an email and acted upon it.

The information we collect includes the pages you visit; URL clickstream to, through and from the Website, including date and time; errors; actions you take on the Website and in emails we send you. Through the device you use to access the Website, we collect information about your browser, operating system, internet service provider, location data and time zone through IP address, and other technical information.

This information helps us analyze and improve on how you interact with the Website and marketing communications.

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Cookies we use on this website

Strictly necessary cookies are essential for the Website to function properly, for example, to enable page navigation. Without these cookies the Website cannot function properly and some features of this Website might not be available.

Functional cookies remember the setting you select on the Website, for example, language. These cookies help us provide a customized experience of our Website.

Analytics cookies help us understand how users interact with our Website in order to improve your user experience. For example, cookies from Google Analytics and Yandex.Metrica help us collect statistical data about Website traffic in order to optimize navigation, content and marketing campaigns.

Social media cookies are used when you share Website content using social media “Share” or “Like” buttons. This information may be linked to advertising activities.

Advertising cookies, which we use from time to time, are provided by third-party services like Google Ad, Yandex.Direct, Facebook, and help us display remarketing or retargeting advertisements relevant to your interests across the internet.

Some cookies are deleted once you close your browser (“session” cookies), while other cookies are retained longer so we can recognize you when you return to the Website (“persistent” cookies).

Necessary cookies	Purpose	Expires	Set by domain
acceptCookie	Preserves visitor’s consent to cookies.	6 months	xltools.net

Analytics cookies	Purpose	Expires	Set by domain
_ga; _gat; _gid	Google Analytics cookies that register a unique ID to generate statistical data on how visitors use the website.	From session to 2 years	xltools.net
_ym _uid; _ym _isad; _ym _d; _ym _visorc	Yandex.Metrica cookies that register a unique ID to generate statistical data on how visitors use the website.	From session to 1 year	xltools.net
yabs-sid, yandexuid, i, ymex, yuidss	Yandex.Metrica cookies that register a unique ID to generate statistical data on how visitors use the website.	From session to 10 years	yandex.ru

Advertising cookies	Purpose	Expires	Set by domain
_fbp	Facebook cookie that tracks the visitor across devices and marketing channels.	3 months	xltools.net
fr	Facebook cookie that helps provide personalized advertisements.	3 months	facebook.com

Your options regarding cookies

You can block, delete or enable cookies in your browser settings. NOTE: if you block or delete cookies, you might not be able to use some features of this Website.

Learn more about cookies at www.allaboutcookies.org.

You can manage cookies through your browser:

• Chrome: httрs://support.google.com/chrome/answer/95647
• Internet Explorer: httрs://support.microsoft.com/help/278835/how-to-delete-cookie-files-in-internet-explorer
• Edge: httрs://support.microsoft.com/help/4468242/microsoft-edge-browsing-data-and-privacy-microsoft-privacy
• Firefox: httрs://support.mozilla.org/kb/clear-cookies-and-site-data-firefox
• Safari: httрs://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac

Learn more about advertising cookies at www.aboutads.info/choices/, www.networkadvertising.org/choices/, www.youronlinechoices.eu (in Europe), httрs://youradchoices.ca/choices/ (in Canada).

You can also manage specific advertising cookies at:

• Google Ad settings: httрs://adssettings.google.com/
• Facebook ad preferences: httрs://www.facebook.com/help/562973647153813/
• Google Analytics opt-out: httрs://support.google.com/analytics/answer/181881
• Yandex.Metrica opt-out: httрs://yandex.com/support/metrica/general/opt-out.html

Our Website currently does not respond to “Do Not Track” signals.

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For your convenience, we may provide links to third-party websites, products, services, software, widgets and social media features, which are not owned or controlled by us. If you follow these links, you will leave the Website and you will be subject to the applicable terms and policies of these third parties.

This Policy does not apply to external websites or services accessible from links offered on our Website, or to third-party websites, which may contain mentions or links to our Website. We disclaim all liability for the content, availability and privacy practices of third-party websites and services.

This Policy is a part of, and incorporated into, other terms which govern the use of the Website and Software:

• End-User License Agreement available at https://xltools.net/eula/
• Terms of Use available at https://xltools.net/terms-of-use/

If you have any questions about this Policy, or if you want to exercise your legal rights, please contact us at:

If you do not agree with the changes to this Policy, you must immediately cease all use of the Website and Software and destroy all Software copies available to you.

If we make significant modifications to the Policy, we will post a notice on the Website prior to the change or notify by email. We encourage you to check this Policy periodically for changes. Your continued use of the Website and Software after any changes to the Policy means that you irrevocably accept and agree to the changes.