Privacy & cookie policy

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Article 1. Definitions

1.1. In this Privacy and Cookies Policy, the following capitalized terms are used in the following meanings unless expressly stated otherwise or the context indicates otherwise:

Account: The Customer’s account on the Website;

GDPR: General Data Protection Regulation;

Data Subject: The natural person whose Personal Data is processed;

Customer: The legal entity, organization or natural person acting in the exercise of its profession or business who has entered into an Agreement with wpMula;

Agreement: The agreement between the Customer and wpMula;

Personal Data: Data about an identified or identifiable natural person;

Website: The site;

Website Visitor: The natural person who visits the Website;

wpMula: The user of this privacy and cookie policy: Webatleten trading under the name “wpMula”, located at Prins Willem-Alexanderlaan 1427 in Apeldoorn, registered with the Chamber of Commerce under KvK number 77034120.

1.2. Unless the context indicates otherwise, defined terms in the singular also refer to the plural and vice versa.


Article 2. General, controller and contact details

2.1. This privacy and cookie policy describes how wpMula processes Personal Data in connection with the Agreements and which cookies the Website uses.

2.2. The data controller is: wpMula

Prins Willem-Alexanderlaan 1427 7312 GB Apeldoorn

Chamber of Commerce number: 77034120 email address:

Phone number: + 31 6 42677371

2.3. For wpMula, careful handling of Personal Data is of great importance. With regard to the processing of Personal

Data, wpMula acts in accordance with the GDPR.


Article 3. Data subjects and collection of Personal Data

3.1. WpMula processes Personal Data of contact persons of the Customer.

3.2. WpMula collects Personal Data at the time that:
a. The Client has placed an order with wpMula through the Website;
b. The Customer has created an Account.


Article 4. Personal Data

4.1. WpMula processes the following Personal Data:
a. First Name;
b. Last Name;
c. If the business address of the Customer’s company is the same as the Customer’s private address: Address, zip code, city and country;
d. E-mail address;
e. Telephone number;
f. Account login information;
g. IP address.

4.2. The Personal Data mentioned under sub. a. to e. are necessary for the establishment of the Agreement.

4.3. The Personal Data mentioned under sub. a. to f. are necessary for the creation of the Account.

4.4. WpMula does not process any special Personal Data.


Article 5. Purposes and bases

5.1. WpMula processes Personal Data for the following purposes:

a. Conclusion and performance of the Agreement, such as:
i. Sending a confirmation of the establishment of the Agreement;
ii. Creating an Account;
iii. Sending a confirmation that the Account has been created;
iv. Providing the purchased software;
v. Hosting.

The Personal Data mentioned in article 4.1 under a. to g. will be processed for this purpose.
The basis of this processing is the execution (mij lijkt het dat het woord ‘performance’ beter zou passen, klopt dit beter voor de betekenis van de zin? Execution betekend uitvoering maar ook executie, dus dat voelt wat gek) of the Agreement.

b. Communication purposes, such as:
i. Handling a question, comment, request or complaint;
ii. Informing on the progress of handling a question, comment, request or complaint.

The following Personal Data are processed for this purpose: First name, last name, e-mail address and telephone number.
The basis of this processing is the performance of the Agreement.

c. Administrative purposes, such as:
i. Preparing the invoice;
ii. Sending the invoice via e-mail;
iii. Maintaining a database of business relations.

For this purpose, the Personal Data mentioned in article 4.1 sub a. to sub. e. are processed. The basis of this processing is the performance of the Agreement.

d. Marketing purposes, being the sending of newsletters, see also article 6.
The following Personal Data are processed for this purpose: First name, last name and e-mail address. The basis of this processing is the consent of the Data Subject.

e. Being able to trace where the order comes from.
The following Personal Data is processed for this purpose: IP address. The basis of this processing is the consent of the Data Subject.

5.2. It is possible that wpMula is forced to process Personal Data on the basis of the basis of legal obligation, for example in the event of fraud or on the orders of the police.

5.3. WpMula only processes Personal Data that are minimally necessary for the existing purposes. WpMula strives for minimal data processing.

5.4. WpMula will not process Personal Data for purposes other than those described in this privacy and cookie policy. 5.5. WpMula does not use automatic decision-making.


Article 6. Newsletters

6.1. Newsletters will only be sent to the Data Subject if the Data Subject has signed up for newsletters and thereby granted the Data Subject permission to send these newsletters to the email address provided by the Data Subject. The Data Subject may unsubscribe from these newsletters at any time.

6.2. The Data Subject may unsubscribe from newsletters in the following ways:
a. By clicking on the link in the e-mail containing the newsletter that allows the Data Subject to unsubscribe from newsletters. An unsubscribe link is included in each newsletter;
b. By contacting wpMula, see article 2.2 for contact details.


Article 7. Third parties

7.1. In carrying out its business activities, WpMula engages third parties who process Personal Data. These include ICT service providers, such as a hosting company, accounting service providers and the payment provider Mollie. Engaged third parties only have access to Personal Data as necessary to provide the agreed services to wpMula and to the extent permitted by law.


Article 8. Security measures and storage

8.1. In order to prevent unauthorized access to Personal Data, loss, theft and unauthorized use of Personal Data, wpMula has implemented various security measures, including measures against unauthorized access, use, modification, unlawful and unintentional destruction and unintentional loss of the Personal Data. WpMula has implemented the following security measures, among others:

a. The Website has an SSL certificate;
b. No unknown/open Wifi is used;
c. Personal data is encrypted in transit;
d. WpMula uses two-factor or multi-factor authentication; e. WpMula maintains a data breach register;

f. Equipment and email is mandatorily secured with passwords and antivirus software; g. WpMula has rules for choosing, recording and renewing passwords.

8.2. WpMula will not retain Personal Data longer than strictly necessary to achieve the purposes as described in Article 5.1, for which the Personal Data are processed, unless there is a legal obligation that requires longer retention.

8.3. WpMula stores Personal Data within the European Economic Area (EEA). It is possible that a third party engaged by wpMula, see also Article 7.1, stores Personal Data outside the EEA. If Personal Data is processed in a country outside the EEA that does not have an adequate level of protection, wpMula will take appropriate measures to ensure that the Personal Data is properly protected, for example that the third party in question, through a (processor) agreement, such as a model contract approved by the European Commission, or in any other way, guarantees an adequate level of protection. If the Data Subject wishes more information regarding these guarantees and where they can be consulted, the Data Subject may contact wpMula, see article 2.2 for contact details.


Article 9. Deletion of Personal Data

9.1. WpMula will delete Personal Data from its systems without unreasonable delay if, among other things: a. The Personal Data is no longer needed for the purposes for which it was processed;
b. The Data Subject objects to the processing of their Personal Data and such objection is justified;
c. The Personal Data are inaccurate or out of date.

9.2. WpMula is not obliged to erase Personal Data if any of the situations defined by law where the “right to be forgotten” does not apply.


Article 10. Right of inspection, right of portability, rectification and deletion

10.1. Upon request, wpMula shall provide the Data Subject with access to the Personal Data that wpMula processes of the Data Subject and shall provide the Data Subject, free of charge, with a copy of such Personal Data in such form that the Data Subject may provide the Personal Data to a third party himself/herself.

10.2. WpMula offers the Data Subject the opportunity to correct or delete, free of charge, any inaccurate Data that wpMula processes about the Data Subject.


Article 11. Objections

11.1. The Data Subject may object to the processing of their Personal Data to wpMula if the Data Subject has good reason to do so in view of their specific situation. After wpMula receives the objection from the Data Subject, wpMula will stop processing the Personal Data of the Data Subject, unless wpMula has legitimate interests in processing Personal Data that outweigh the interest of the Data Subject.


Article 12. Right of Restriction

12.1. If a request has been made by the Data Subject regarding the modification, supplementation or erasure of his Personal Data or an objection has been filed regarding the processing of his Personal Data and the consideration, processing and implementation of this request or objection takes some time, the Data Subject may request wpMula to restrict the processing of his Personal Data.


Article 13. Consent

13.1. The Data Subject may withdraw a granted consent regarding the processing of his Personal Data at any time. The withdrawal of a consent shall not have retroactive effect.


Article 14. Questions, requests and complaints

14.1. For:
a. Questions about this privacy and cookie policy and/or how wpMula processes Personal Data; or
b. Withdrawing a granted consent; or
c. Exercising any of the rights described in Article 10, 11 or 12; or
d. Reporting (suspected) misuse made of the Personal Data that wpMula processes of the Data Subject, the Data Subject may contact wpMula via email,

14.2. If the Data Subject invokes one of the rights described in Article 10, 11 or 12, then:
a. If wpMula is in doubt as to whether it is dealing with the right person, wpMula may request additional information; b. Within 1 month of receiving the request, wpMula will inform the Data Subject of the action taken on the request.

14.3. If, at the request of the Data Subject, wpMula corrects, supplements or deletes Personal Data of the Data Subject or terminates or limits the processing of the Personal Data or has processed a revoked consent, wpMula shall inform the Data Subject.

14.4. If the Data Subject believes that the processing of Personal Data by wpMula is not in accordance with this privacy and cookie policy and/or with applicable laws and regulations, the Data Subject may file a complaint with the Personal Data Authority or with a supervisory authority in the country where the Data Subject resides.


Article 15. Cookie Policy. Explanation of cookies

15.1. The Website makes use of cookies. Cookies are text files that are stored on the Website visitor’s computer or mobile device when the Website visitor visits the Website.

15.2. If the Website visitor does not consent to the placement of cookies for which consent is required, only those cookies for which no consent is required will be placed.

15.3. The Website Visitor can disable the placing of cookies via his Internet browser. In addition, the Website Visitor can also delete all information previously stored with cookies via the settings of his Internet browser. More information regarding enabling, disabling and deleting cookies can be found by the Website Visitor in the instructions and/or using the Help function of his Internet browser. It is possible that by disabling certain cookies the Website may no longer function optimally, the Website visitor may no longer be able to log in to the Website and/or the Website visitor may not be able to place an order in his shopping basket.

Types of cookies

15.4 The Website uses the following cookies:
a. Functional cookies;
b. Analytical cookies.

15.5. The Website does not use tracking cookies.

Functional cookies.

15.6. The Website uses functional cookies to make the Website work optimally. With functional cookies:
a. Allow the Website to recognize the Website visitor when the Website visitor revisits the Website;
b. The Website remembers the Website visitor’s preferred settings, such as a language preference;
c. Will place, remember and store the order in his shopping cart and allow for checkout;
d. Adapts the layout of the Website, to the screen size with which the Website visitor consults the Website. 15.7. Functional cookies are necessary for the correct functioning of the Website.
Analytical cookies

15.8. Analytical cookies allow wpMula to collect and analyze information associated with how the Website is used. Analytical cookies are used to measure the use of the Website. Through the use of analytical cookies, wpMula processes data on the use of the Website such as the number of visitors, performance statistics and similar data.

15.9. Analytical cookies are placed by Google on behalf of wpMula. The information collected by Google is anonymized.

15.10. The IP address of the Website visitor is stored by means of a cookie only if the Website visitor has given his consent.


Article 16. Changes

16.1. WpMula reserves the right to make unilateral changes to this privacy and cookie policy, for example due to changes in laws or regulations. The Website contains the latest version of wpMula’s privacy and cookie policy.

Version February 2024