=================================================================== --- 20251201_rev01 +++ 20260201_rev01 @@ -1,11 +1,11 @@ -v.11 - Updated November 10th, 2025 +v.12 - Updated November 27th, 2025 ## A. General Note -This Privacy Policy is aimed at worldwide users of WebPros websites and other online services (collectively the "Offerings"). To ensure a proper and secure handling of personal data handed over to us, WebPros has decided to make the principles of the **EU General Data Protection Regulation** **(GDPR)** applicable to all its global entities as a common standard in addition to local privacy laws in effect. E.g. for Europe, both, the provisions of the GDPR and the provisions of the **Swiss Data Protection Act (DSG)** and the**UK General Data Protection Regulation** (for WHMCS) apply, whereas in the USA, the applicable privacy regulations per state apply. If your locally applicable data protection law grants you a level of data protection that exceeds that of the GDPR, this stricter level will also apply in the relationship between you and WebPros. However, the level of data protection provided by the GDPR will never be undercut. +This Privacy Policy is aimed at worldwide users of WebPros websites and other online services (collectively the "Offerings"). To ensure a proper and secure handling of personal data handed over to us, WebPros has decided to make the principles of the **EU General Data Protection Regulation (GDPR)** applicable to all its global entities as a common standard in addition to local privacy laws in effect. E.g. for Europe, both, the provisions of the GDPR and the provisions of the **Swiss Data Protection Act (DSG)** and the **UK General Data Protection Regulation** (for WHMCS) apply, whereas in the USA, the applicable privacy regulations per state apply. If your locally applicable data protection law grants you a level of data protection that exceeds that of the GDPR, this stricter level will also apply in the relationship between you and WebPros. However, the level of data protection provided by the GDPR will never be undercut. Insofar as the terms of the GDPR are used (e.g. "processing" or "personal data"), these are to be understood as having the same meaning in the sense of the Swiss DSG and/or your local data protection laws, insofar as this is objectively possible. The aim of this Privacy Policy is to ensure the protection of your personal data in accordance with the fundamental requirements of the GDPR and the Swiss DSG. ## B. Third Country Transfer @@ -15,192 +15,199 @@ **Supplementary in accordance with Swiss data protection law**: Subjects resident in Switzerland or as far as the DSG applies, we comply with the requirements of Art. 16 et seq. DSG. Personal data is only transferred abroad if the country in question has an adequate level of data protection (e.g. the EU Member States, Japan, Canada and the USA for certain areas in accordance with the Swiss-U.S. Data Privacy Framework) or appropriate safeguards are in place to protect the data, for example by concluding standard data protection clauses, contractual agreements or other suitable protective measures. Unless an adequacy decision or appropriate safeguards are in place, data will only be transferred in exceptional cases, for example if it is necessary to fulfil a contract or if you have given your express consent. -## A. Joint Data Processing within the WebPros group +## C. Joint Data Processing within the WebPros group -## 1. Joint Data Processing +### 1\. Joint Data Processing As part of our business operations and the use of our website, we work closely within the WebPros group and jointly process certain personal data. The goal is to make our internal processes, IT systems, and administration efficient and secure. This may require us to share data within the WebPros group or process it in systems that we operate jointly. The following entities belong to the WebPros group of companies: -WebPros International GmbH, Vordergasse 59, 8200 Schaffhausen / Switzerland +• WebPros International GmbH, Vordergasse 59, 8200 Schaffhausen / Switzerland -WebPros Germany GmbH, Hohenzollernring 72, 50672 Cologne / Germany +• WebPros Germany GmbH, Hohenzollernring 72, 50672 Cologne / Germany -WebPros International L.L.C., 2550 North Loop W., Suite 4006, Houston, TX 77092 / USA +• WebPros International L.L.C., 1100 W 23rd St, Houston, TX 77008 / USA -WebPros Spain S.L.U., Carrer d'Aragó, 182, Àtic, 08011 Barcelona / Spain +• WebPros Spain S.L.U., Carrer d'Aragó, 182, Àtic, 08011 Barcelona / Spain -WebPros Bulgaria EOOD, ul. "San Stefano" 22, 1504 Sofia / Bulgaria +• WebPros Bulgaria EOOD, ul. "San Stefano" 22, 1504 Sofia / Bulgaria -WebPros Japan K.K., G1 Bldg. 7F-1221, 1-3-3 Ginza, Chuo-ku, Tokyo 104-0061 / Japan +• WebPros Japan K.K., G1 Bldg. 7F-1221, 1-3-3 Ginza, Chuo-ku, Tokyo 104-0061 / Japan -WebPros Netherlands B.V., Schiphol Boulevard 369, Tower F, 7th floor, 1118BJ Schiphol / NL +• WebPros Netherlands B.V (i.L.)., Schiphol Boulevard 369, Tower F, 7th floor, 1118BJ Schiphol / NL -Canada WebPros International, Ltd., 1055 Dunsmuir Street, Suite 3000, Vancouver, BC V7X 1K8 / Canada +• Canada WebPros International, Ltd., 1055 Dunsmuir Street, Suite 3000, Vancouver, BC V7X 1K8 / Canada -XOVI GmbH, Hohenzollernring 72, 50672 Cologne / Germany +• XOVI GmbH, Hohenzollernring 72, 50672 Cologne / Germany -SocialBee Labs Srl., Poet Grigore Alexandrescu Str, No 51, 400560, Cluj-Napoca / Romania +• SocialBee Labs Srl., Poet Grigore Alexandrescu Str, No 51, 400560, Cluj-Napoca / Romania -Comet Licensing, 329 Durham Street, Christchurch, 8013 / New Zealand +• Comet Licensing Ltd., 1/52 Acheron Drive, Upper Riccarton, Christchurch, 8041 / New Zealand -WHMCS Limited, C/O TMF Group, 13th Floor, One Angel Court, London, EC2R 7HJ / United Kingdom +• WHMCS Ltd., C/O TMF Group, 13th Floor, One Angel Court, London, EC2R 7HJ / United Kingdom For data subjects from the EU, this joint data processing is based on our legitimate interest in accordance with **Art. 6 para. 1 lit. f GDPR** in a well-functioning corporate organization and IT infrastructure. For persons from **Switzerland**, processing is also based on our overriding interest in accordance with **Art. 31 para. 1 DSG** in order to enable secure and efficient cooperation within the Webpros group. To ensure data protection is maintained, we have established binding agreements within the WebPros group that specify which company assumes which tasks and responsibilities. If you have any questions or wish to exercise your rights, the WebPros company you first contacted is usually your point of contact. -## 2. Contact +### 2\. Contact We have also internally assigned the fulfillment of data subject rights to WebPros International GmbH / Switzerland. You can contact the following point of contact at any time with inquiries or to exercise your data subject rights, and they will forward your request for processing, internally: WebPros International GmbH Vordergasse 59 8200 Schaffhausen / Switzerland -Email: [\[email protected\]](https://www.cpanel.net/cdn-cgi/l/email-protection#5424263d2235372d1403313604263b277a373b39). +Email: [\[email protected\]](https://www.cpanel.net/cdn-cgi/l/email-protection#99e9ebf0eff8fae0d9cefcfbc9ebf6eab7faf6f4). -## 3. Contact details of the data protection officer of WebPros International GmbH +### 3\. Contact details of the data protection officer of WebPros International GmbH -Email: [\[email protected\]](https://www.cpanel.net/cdn-cgi/l/email-protection#4b3b39223d2a28320b1c2e291b39243865282426) +Email: [\[email protected\]](https://www.cpanel.net/cdn-cgi/l/email-protection#98e8eaf1eef9fbe1d8cffdfac8eaf7ebb6fbf7f5) ## D. Data Processing The individual data affected by joint data processing, processing purposes, legal bases, recipients and, if applicable, transfers to third countries are listed below: -## 1. Contacting WebPros +### 1\. Contacting WebPros When you contact us, we process the data you provide to us - for example, your name, your contact details (if provided), and your message - to handle your request. The processing is based on our contractual or pre-contractual obligations (Art. 6 para. 1 b) GDPR) or because we have a legitimate interest in responding to your inquiry (Art. 6 para. 1 f) GDPR). Under Swiss data protection law, we rely on our overriding interest in communicating with you and handling your request (Art. 31 para. 1 DSG). -## 2. Contact in case of Job Applications +### 2\. Contact in case of Job Applications If you send us your application, for example, by email or via a contact form, we will process the data you provide (such as name, email address, desired location) as well as your message and application documents solely for the purpose of processing your application. For companies based in the EU, data processing is carried out on the basis of Art. 6 para. 1 b) GDPR, with § 26 BDSG (decision on an employment relationship) taking precedence in Germany. If further processing is required after the procedure is completed for legal prosecution, we base this on Art. 6 para. 1 f) GDPR (legitimate interests). For applications in Switzerland, Art. 328b OR applies. According to this, data may be processed as far as it concerns suitability for the employment relationship or is necessary for the execution of the employment contract. Your application data will be stored for the duration of the application process. After the procedure is completed, we will delete your data within 6 months, unless there are legal retention obligations, consent for longer storage (e.g., for an applicant pool), or further retention is required to protect legitimate interests (e.g., to defend against claims). -## 3. Contract fulfilment and data management in the context of service provision +### 3\. Contract fulfilment and data management in the context of service provision For the establishment, execution, and processing of contracts, we process the necessary data (e.g., name, contact details, address, email address, phone number, access data) as well as all information required for fulfilling the contract. The processing is carried out - where applicable - in accordance with Art. 6 para. 1 b) and c) GDPR and the corresponding provisions of the Swiss Data Protection Act (DSG) for contract fulfillment and compliance with legal obligations. If necessary for contract processing, we transmit data to third parties, e.g., to supervisory authorities for correspondence or to enforce your rights. Additionally, data may be shared with our affiliated companies within the scope of order processing if they are involved in service provision. -## 4. Log files of Website Visits +### 4\. Log files of Website Visits We log your website visit. In doing so, we process: -- The name(s) of our accessed website(s) -- The date and time of access -- The amount of data transferred -- The browser type and version -- The operating system you use -- The referrer URL (the previously visited website) -- Your IP address -- The requesting provider. +• The name(s) of our accessed website(s) +• The date and time of access + +• The amount of data transferred + +• The browser type and version + +• The operating system you use + +• The referrer URL (the previously visited website) + +• Your IP address + +• The requesting provider + The legal basis for data processing is our overriding legitimate interest in the continuous provision and security of our website in accordance with Art. 6 para. 1 f) GDPR. The log file is deleted after seven days unless it is needed to prove or clarify specific legal violations that have become known within the retention period. -## 5. Newsletter and Customer Information +### 5\. Newsletter and Customer Information To keep you regularly informed about our company and our offers, we offer several email newsletters. For this purpose, we process the data you provide during registration (email address and any voluntary information). To prevent misuse, we use the double opt-in procedure: After registration, you confirm it through a confirmation email. The registration process is logged to prove its legality (time of registration and confirmation as well as IP address). The legal basis is your consent - for the EU according to Art. 6 para. 1 a) GDPR, for Switzerland according to Art. 31 para. 1 DSG. The logging and confirmation email are based on our legitimate interest in proving proper registration (Art. 6 para. 1 f) GDPR or Art. 31 para. 1 DSG). The data is transmitted to HubSpot, Inc. (USA) as part of order processing. HubSpot is certified under the EU-U.S. and Swiss-U.S. Data Privacy Framework, ensuring an adequate level of data protection under both EU and Swiss law. Additionally, an EU standard contractual clause exists. European branch: HubSpot Ireland Ltd., 30 North Wall Quay, Dublin 1, Ireland. Based on WebPros' legitimate interest in accordance with Art.6 para. 1 f GDPR and the existing customer relationship with WebPros, customers may be provided with information relating to other WebPros products, which may be of interest to them. At any time, customers have the option to opt out of the receipt of such information by using the unsubscribe option in any communication received. -## 6. Use of Cookies +### 6\. Use of Cookies -### **6.1.** **Our Cookie Consent Management Platform** +#### **6.1. Our Cookie Consent Management Platform** To document your selection of cookies and similar technologies and to comply with our legal obligations, we use a consent management platform (Usercentrics). When you visit our website, we ask for your cookie preferences. Your decision is stored in a special cookie. The legal basis for this is Art. 6 para. 1 lit. c GDPR and Art. 7 para. 1 DSG (Switzerland), as we are legally required to prove and manage your consent. For managing your consents, we use the consent management platform "Usercentrics", provided by Usercentrics GmbH, Sendlinger Straße 7, 80331 Munich / Germany. The following data is processed and transmitted to Usercentrics: - Your consent or rejection (including date, time, language, consent ID) + - Device data (such as browser information and anonymized IP address) The processing of this data is also carried out to fulfill our legal obligations according to Art. 6 para. 1 lit. c GDPR and Art. 7 para. 1 DSG (Switzerland). -### **6.2. Cookie categories in use by WebPros (Essential, Functional, Analytics, Marketing)** +#### **6.2. Cookie categories in use by WebPros (Essential, Functional, Analytics, Marketing)** -| **Cookie types** | **Description** | -| --- | --- | -| Essential | Essential Cookies help make an Offering usable by enabling basic functions like page navigation and access to secure areas of the Offering. The Offering cannot function properly without these cookies. | -| Functional | Functional Cookies allow the Offering to remember the user's website preferences and choices they make on the Offering including login details, geo-location, language, and enhanced content. This allows the Offering to provide personalized features for users. Functional Cookies are used to enhance the performance of Offerings, as without them, certain functions of the Offerings may not be available. Functional Cookies are helping to provide services that a user requests. | -| Analytics | Analytic Cookies collect information about your use of the Offering and enable us to improve the way it works. These cookies give us aggregated information that we use to monitor site performance, count page visits, spot technical errors, see how users reach the site, and measure the effectiveness of advertising (including emails we send to you). | -| Marketing | Marketing Cookies allow us and other trusted advertisers to select advertisements that are based on your interests, including those expressed or inferred by visits to our Site or apps or across other Offerings, online services, and apps over time. Others help prevent the same advertisement from continuously reappearing for you. These types of cookies also help us provide you with content on the Site that is tailored to your interests and needs. Some Marketing Cookies and other technologies are used in part to also facilitate advertising. Please be aware that Marketing Cookies in some cases have a direct relation to Social Cookies. These Social Cookies are used to enable you to share content, which is a matter of your own interest as well as may participate in the process of authorization via social media services to gain access to 3rd party apps/websites, if you choose to do so. Social cookies may also be used for advertising/analytics purposes. | +

Cookie types	Description
Essential	Essential Cookies help make an Offering usable by enabling basic functions like page navigation and access to secure areas of the Offering. The Offering cannot function properly without these cookies.
Functional	Functional Cookies allow the Offering to remember the user's website preferences and choices they make on the Offering including login details, geo-location, language, and enhanced content. This allows the Offering to provide personalized features for users. Functional Cookies are used to enhance the performance of Offerings, as without them, certain functions of the Offerings may not be available. Functional Cookies are helping to provide services that a user requests.
Analytics	Analytic Cookies collect information about your use of the Offering and enable us to improve the way it works. These cookies give us aggregated information that we use to monitor site performance, count page visits, spot technical errors, see how users reach the site, and measure the effectiveness of advertising (including emails we send to you).
Marketing	Marketing Cookies allow us and other trusted advertisers to select advertisements that are based on your interests, including those expressed or inferred by visits to our Site or apps or across other Offerings, online services, and apps over time. Others help prevent the same advertisement from continuously reappearing for you. These types of cookies also help us provide you with content on the Site that is tailored to your interests and needs. Some Marketing Cookies and other technologies are used in part to also facilitate advertising. Please be aware that Marketing Cookies in some cases have a direct relation to Social Cookies. These Social Cookies are used to enable you to share content, which is a matter of your own interest as well as may participate in the process of authorization via social media services to gain access to 3rd party apps/websites, if you choose to do so. Social cookies may also be used for advertising/analytics purposes.

-### 6.3. Note on Google Services +#### **6.3. Note on Google Services** We use various services from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google") on our website. This may also involve data transfers to Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. For data subjects in the EU, the transfer is based on the EU-U.S. Data Privacy Framework. Google is certified for this and is subject to the EU Commission's adequacy decision for the USA. For Switzerland, the transfer is based on the Swiss-U.S. Data Privacy Framework (Swiss DPF). Google is also certified for this, so Switzerland recognizes an adequate level of data protection for transfers to the USA. If, in exceptional cases, there is no certification or adequate protection, we additionally ensure the protection of your data through standard contractual clauses (SCC) or other suitable measures. -### 6.4. This specific Offering uses the following cookies and other technologies +Search Function and Google Analytics +When you use the search function on our websites, the terms you enter may be shared with Google Analytics. This helps us understand how visitors interact with our site and improve its functionality and content. The data shared is used solely for analytical purposes and can not include personally identifiable information. By using the search feature, you consent to this processing and sharing of data with Google Analytics. This practice is consistent with applicable privacy laws and does not constitute a violation of the California Invasion of Privacy Act (CIPA), as it is limited to operational analytics and does not involve unlawful interception of communications. Furthermore, you agree that the information you enter is not a "private communication" under CIPA. For more details on how Google processes data, please review Google's Privacy Policy. + +#### 6.4. This specific Offering uses the following cookies and other technologies + ## E. Duration of Data Processing We store personal data only as long as it is necessary to achieve the respective purpose or until you revoke your consent. If there are legal retention obligations - for example, under commercial, tax, or social security law in Switzerland or the EU - the retention of certain data may be required for up to 10 years or longer, regardless of the processing purpose. To ensure that no data is stored longer than necessary, we conduct regular reviews and delete personal data as soon as the purpose of storage ceases to exist and there are no legal obligations or legitimate interests remaining. ## F. Your rights as a Data Subject -## 1. Request for Information +#### 1\. Request for Information Upon request, you can receive information about all personal data we have stored about you at any time, free of charge. -## 2. Rectification, Erasure, Restriction of Processing (Blocking), Objection +#### 2\. Rectification, Erasure, Restriction of Processing (Blocking), Objection If you no longer agree with the storage of your personal data or if it has become incorrect, we will delete or block your data upon your instruction or make the necessary corrections (as far as this is possible under applicable law). The same applies if we should only process data in a restricted manner in the future. You have the right to object, particularly in cases where your data is required for the performance of a task carried out in the public interest or based on our legitimate interest, including profiling based on these grounds. You also have the right to object to data processing for direct marketing purposes. -## 3. Right to withdraw consent with effect for the future +#### 3\. Right to withdraw consent with effect for the future You can withdraw your consent at any time with effect for the future. Your withdrawal will not affect the lawfulness of the processing up to the time of withdrawal. -## 4. Data Portability +#### 4\. Data Portability If data processing is based on a contract, pre-contractual negotiations, consent, or automated procedures, you have the right to data portability. Upon request, we will provide your data in a common, structured, and machine-readable format, so that you can transfer the data to another controller if desired. -## 5. Restriction of Processing +#### 5\. Restriction of Processing Data for which we are unable to identify the data subject, for example, if it has been anonymized for analysis purposes, is not covered by the aforementioned rights. Information, deletion, blocking, correction, or transfer to another company may be possible for such data if you provide us with additional information that allows us to identify you. -## 6. No Automated Decision-making or Profiling +#### 6\. No Automated Decision-making or Profiling Your data is not used by us for automated decisions which have legal consequences for you or significantly affect you in a similar way - as described in Art. 22 GDPR (EU) or Art. 21 DSG (Switzerland). We also do not conduct so-called profiling. This means that we do not create automated evaluations of your data to analyze or predict personal characteristics such as interests, behavior, or preferences. Should we exceptionally use automated decisions or profiling, we will inform you transparently in advance and obtain your explicit consent where necessary. -## 7. For WebPros companies domiciled in Switzerland: Inspection of the data collection register +#### 7\. For WebPros companies domiciled in Switzerland: Inspection of the data collection register If the data processing is carried out by a WebPros company based in Switzerland, you have the right to inspect the register of data collections at any time. This contains information on which federal bodies and private persons process which kinds of personal data. With the help of the register you can find out who is processing your data and how, and on the basis of this information you can decide which data collection you wish to request information about. -## 8. Exercising your rights as a Data Subject and right to lodge a complaint +#### 8\. Exercising your rights as a Data Subject and right to lodge a complaint -If you have any questions regarding the processing of your personal data, information, rectification, blocking, objection or deletion of data, or if you wish to transfer your data to another enterprise, please contact [\[email protected\].](https://www.cpanel.net/cdn-cgi/l/email-protection#8cfcfee5faedeff5ccdbe9eedcfee3ffa2efe3e1) +If you have any questions regarding the processing of your personal data, information, rectification, blocking, objection or deletion of data, or if you wish to transfer your data to another enterprise, please contact [\[email protected\].](https://www.cpanel.net/cdn-cgi/l/email-protection#50202239263133291007353200223f237e333f3d) You also have the option of complaining to a supervisory authority about your rights as a data subject. In the case of a WebPros company based in Switzerland, you have the right to lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC). This policy is subject to periodic revisions and may be amended by WebPros from time to time if necessary. Please come back periodically and check for updates.

Privacy Policy

Full text changes — 20251201_rev01 to 20260201_rev01