Simple Waterfall privacy policy

1. Who we are

1.1 Datanomy is the controller of the personal data that we process for the purposes described in this policy. Where we process personal data contained in support materials on behalf of a Simple Waterfall Pro customer, we act as the customer’s processor as described in section 4.3 and Schedule 1 of the Simple Waterfall Pro End User License Agreement. We are a company registered in England and Wales under number 14390520, with our registered office at 3rd Floor, 86–90 Paul Street, London EC2A 4NE. We are registered with the Information Commissioner’s Office under registration number ZB770476.

1.2 If you have any questions about this policy or how we use your personal data, please contact us at privacy@datanomytechnologies.com or write to us at the address above.

2. The visual itself

2.1 Simple Waterfall runs entirely inside Microsoft Power BI. It makes no network connections to Datanomy or to anyone else, and it does not send the data in your reports anywhere. Datanomy does not have access to, and does not receive or process, the data contained in your reports or Power BI datasets through Simple Waterfall. We cannot see your reports, your datasets or who views them.

2.2 Your Customer Data is processed by Microsoft when it runs Power BI, under your organisation’s agreement with Microsoft. That processing is not covered by this policy. Microsoft explains how it handles that data in the Microsoft Privacy Statement.

2.3 For Simple Waterfall Pro, Microsoft checks within Power BI whether a user holds a Pro licence. That check is carried out by Microsoft, and it does not send us any information about the person using the visual or the report they are working on.

3. Personal data we receive from Microsoft

3.1 Simple Waterfall is distributed through Microsoft AppSource and Microsoft Marketplace. When you acquire either edition, start or change a Simple Waterfall Pro subscription, or ask to be contacted through the marketplace, Microsoft shares some of your details with us. These can include:

• your first name and last name;
• your work email address and telephone number;
• your company name and job title;
• your country; and
• the action you took, such as acquiring the visual, purchasing a subscription or asking to be contacted.

3.2 For Simple Waterfall Pro subscriptions, Microsoft also shares information about the subscription, such as the plan, the number of licences purchased, the subscription status and the relevant dates. We process this information as a controller for the purposes described in section 5.

3.3 Not every item is available for every contact. Microsoft handles all billing and payment for Simple Waterfall Pro, and we never receive your payment card or bank details.

4. Personal data you give us

4.1 When you contact us, for example to ask for support, give feedback or ask about our services, we collect the details including personal data you provide. This usually includes your name, work email address, organisation and the content of your message. Where you send files or screenshots for support, these may contain additional personal data, as described below.

4.2 Support files. Report files, screenshots and sample data sent for support can contain personal data about other people, such as your colleagues, customers or suppliers. Please remove or anonymise that data before you send files to us wherever you can.

4.3 Where support files do contain personal data, we process that personal data only to the extent reasonably necessary to investigate and resolve your support request and in accordance with Schedule 1 of the Simple Waterfall Pro End User Licence Agreement. We delete Support Personal Data within 30 days after the request is closed, subject to the terms of Schedule 1. For Simple Waterfall Pro customers, we handle that data on your organisation’s behalf as its processor, under Schedule 1 of the Simple Waterfall Pro End User Licence Agreement. We may decline to accept, or may delete, files that contain special category data, such as health information.

5. How we use your personal data and why

5.1 We use your personal data for the purposes below. For each one, the table shows the lawful basis we rely on under UK data protection law.

5.2 Where we process Support Personal Data contained in support materials on behalf of a Simple Waterfall Pro customer, we process that data as the customer’s processor under Schedule 1 rather than relying on our own lawful basis as controller.

5.3 Where we rely on legitimate interests, we have considered your interests and rights and are satisfied that they are not overridden by ours. You can ask us for more information about this assessment, and you have the right to object (see section 10).

5.4 Marketing. Every marketing email we send includes a way to unsubscribe, and you can opt out at any time by emailing privacy@datanomytechnologies.com. Opting out of marketing does not stop service messages about a subscription you hold.

5.5 We do not sell your personal data, and we do not make decisions about you based solely on automated processing.

6. Who we share your personal data with

6.1 We share personal data only where necessary, with:

• HubSpot, which we use to manage our contacts and send emails, acting as our processor;
• Microsoft, which provides our email and document storage as our processor, and which operates AppSource and Microsoft Marketplace as an independent controller under its own privacy statement;
• our professional advisers, such as lawyers, accountants and insurers, where needed for their services;
• regulators, law enforcement or other authorities, where the law requires it; and
• a buyer or successor of all or part of our business, if that business is sold or reorganised.

6.2 Our processors may use personal data only on our instructions and must keep it secure. For Support Personal Data processed on behalf of Simple Waterfall Pro customers, Datanomy uses the sub-processors listed at datanomytechnologies.com/simple-waterfall-sub-processors in accordance with Schedule 1 of the Simple Waterfall Pro End User Licence Agreement. A current list of the providers we use to process support materials is available at datanomytechnologies.com/simple-waterfall-sub-processors.

7. International transfers

7.1 HubSpot hosts our contact and marketing records in the European Union (Germany). HubSpot and Microsoft may also process some personal data in the United States, for example to provide support, keep their services secure and analyse how their services are used. Where we process Support Personal Data as a processor under Schedule 1, any international transfer of that data will be carried out in accordance with the international transfer requirements set out in Schedule 1.

7.2 Where personal data is transferred outside the United Kingdom, we make sure it is protected, either because the destination is covered by UK adequacy regulations, including the UK Extension to the EU-US Data Privacy Framework where the recipient is certified under it, or by using the International Data Transfer Agreement or Addendum approved under UK law. You can ask us for details of the safeguards we use.

8. How long we keep your personal data

8.1 We keep personal data only for as long as we need it for the purposes in section 5, as set out below.

8.2 At the end of these periods we delete personal data or anonymise it so that it can no longer identify you.

9. How we protect your personal data

9.1 We use appropriate technical and organisational measures to protect personal data, including access controls, multi-factor authentication, encryption provided by our systems, and limiting access to support files to the people handling the request. These measures apply to personal data processed by Datanomy and do not apply to Customer Data processed within Microsoft Power BI, which is subject to the Customer’s arrangements with Microsoft.

10. Your rights

10.1 Under UK data protection law you have the right to:

• ask for a copy of the personal data we hold about you;
• ask us to correct personal data that is inaccurate or incomplete;
• ask us to delete your personal data;
• ask us to restrict how we use your personal data;
• object to our use of your personal data where we rely on legitimate interests, and object at any time to direct marketing;
• ask us to transfer personal data you have given us to another organisation, where the law allows; and
• withdraw any consent you have given, at any time, without affecting what we did before you withdrew it.

10.2 Some of these rights apply only in certain circumstances. To exercise any of them, email privacy@datanomytechnologies.com. We will respond within one month, and we may need to confirm your identity first. Where we process personal data as a processor on behalf of a Simple Waterfall Pro customer, requests relating to that data may need to be directed to the relevant customer as controller, and we will assist the customer in accordance with Schedule 1 where required.

10.3 If Microsoft holds personal data about you in connection with AppSource or Microsoft Marketplace, you can also exercise your rights directly with Microsoft.

10.4 If you are unhappy with how we have handled your personal data, please contact us first so that we can try to put it right. You also have the right to complain to the Information Commissioner’s Office at ico.org.uk or on 0303 123 1113.

11. Children

11.1 Simple Waterfall is a business product. It is not intended for, and we do not knowingly collect personal data from, anyone under the age of 18.

12. Changes to this policy

12.1 We may update this policy from time to time. The current version is published at datanomytechnologies.com/simple-waterfall-privacy-policy, with the date it was last updated. Where we make a significant change, we will let Simple Waterfall Pro subscribers know by email or through Microsoft Marketplace.