This Privacy Policy has been prepared by the author and owner of WP Full Picture plugin. The document describes the extent of Personal Data processing of Users of the WP Full Picture plug-in in the Free and Pro versions, i.e.:

  • Data of the WP Full Picture Pro Subscribers – in connection with the purchase of a paid Subscription
  • Data of Users of the free or Pro version of the plugin – to the extent that they have voluntarily consented to.

This Privacy Policy contains all information specified in Art. 13-14 GDPR regarding the processing of Personal Data by the Administrator specified in this Privacy Policy. Other entities, in particular the Subscription Provider and PostHog, may be separate data controllers of your personal data, and you should read their privacy policies independently of this Privacy Policy.

If you have not found the information you are looking for or have any questions or doubts regarding the processing of your Personal Data, please contact us. We will be happy to help you exercise your rights specified in the GDPR.

Terms used in this Privacy Policy

Administrator – an entity that processes Personal Data in pursuit of its own purposes and is responsible for ensuring that the processing of Personal Data complies with the GDPR.

Personal Data – personal data, i.e. data of a natural person that makes it possible to identify that person. 

Subscription Provider – the entity from which Subscribers may purchase a paid Subscription – Freemius, Inc, 4023 Kennett Pike, Wilmington, 19807, DE, USA.

PostHog – product analytics tool, used by WP FP to assess what features of the plugin are used most often. PostHog collects data only after explicit consent from the User.

GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (Text with EEA relevance)

Freemius Account – an account on the Subscription Provider’s website, where the WP FP owner has access to data, including Personal Data of Subscribers, provided to him/her by the Subscription Provider.

Privacy Policy – this privacy policy of WP FP.

Subscriber – entity (natural or legal person) that purchased the Subscription.

Subscription – a licence to use the paid version of WP FP held by the Subscriber.

User – any person using WP FP (in any version) on a website administered by them.

WP FP – WP Full Picture, i.e. a plug-in for the WordPress system used, among other things, for managing tracking tools and obtaining cookie consents on websites.

WP FP Pro – the extended version of WP FP, for which the Subscription is paid.

Technical support – technical support provided by the Administrator for WP FP Pro Subscribers or their representatives.

Personal Data Administrator 

The administrator of the Personal Data is Krzysztof Planeta, 08015, Barcelona, Spain, registration number: ESY9743350N.

You can contact the Administrator via the contact form.

Categories of persons to whom the Personal Data concern and the source of the data

The administrator processes Personal Data of:

  1. Subscribers, i.e. entities that use WP FP Pro – if they are natural persons or sole proprietors. The Administrator receives this data from the Subscription Provider by accessing the Freemius Account;
  2. Users who have given voluntary consent to the processing of information for analytical and development purpose. The Administrator obtains Personal Data with PostHog product analytics tool after Users express separate consent in their WordPress panels;
  3. representatives, agents or employees of Users whose Personal Data the Administrator has obtained from the Subscription Provider or who personally contacted the Administrator to obtain Technical Support.

Purposes of processing Personal Data and the period of their processing

1. Personal Data regarding the purchase of a Subscription are necessary to verify the Subscriber’s right to obtain Technical Support;

2. Personal Data provided when reporting the need for Technical Support and obtained in the course of providing it are processed in order to provide appropriate, reliable and effective assistance. Personal Data is processed only in systems used for contacting the Administrator.

3. If a User gives separate, voluntary consent to the use of PostHog product analytics tool, the Administrator will also process Personal Data to verify the popularity and usability of WP FP features and functions; and later use this information for development purposes. This data is processed for up to 18 months.

The scope of Personal Data processed by the Administrator

The Administrator processes the following scope of Personal Data:

  1. Data about Subscribers of paid Subscriptions available on the Freemius Account:
    1. name and surname of the Subscriber, 
    2. Subscription type, 
    3. start date and duration of the Subscription, 
    4. website address where WP FP is/was activated, 
    5. server software version, 
    6. WordPress version, 
    7. information about extensions and themes installed on the website;
  2. Personal Data sent to the Administrator in the contact form, e-mail messages, chat application, data provided during telephone conversations, etc. This may include:
    1. e-mail address, 
    2. name of the contacting person, 
    3. telephone number (if applicable), 
    4. name of the Subscriber represented by the person, 
    5. description of the case, 
    6. content of the correspondence, etc. 
  3. Data collected via the PostHog product analytics tool, after users voluntarily consented to their collection:
    1. website address where WP FP is installed
    2. features and options enabled in WP FP

Telephone calls are not recorded.

The legal basis for processing Personal Data

Personal Data is processed by the Administrator in order to provide Technical Support in accordance with the information contained in the EULA of the Subscription purchased from the Subscription Provider, i.e. pursuant to Art. 6(1)(a) f GDPR. 

The Subscription Provider’s EULA for WP FP is available at: https://freemius.com/plugin/5405/full-picture-analytics-cookie-notice/legal/eula/

In addition, Personal Data of Users who have consented to the use of analytical tracking tools for analytical purposes and improving the functionality of WP FP, based on a separate, voluntary consent expressed in the WordPress panel are used for analytical purposes and improving the functionality of WP FP (Article 6(1)(a) of the GDPR). The User may withdraw his/her consent at any time with effect from the moment of withdrawal, without affecting the previous legality of processing.

Automated processing of Personal Data

The Administrator does not process Personal Data in an automated manner, including profiling.

Transfer of Personal Data to third countries

The Administrator processes Personal Data only within the territory of the European Union. However, the administrator does not decide on the location of personal data:

  • contained in the Freemius Account to which he has access;
  • processed by communication service providers (e.g. Chat, CRM, Email) selected by Subscribers’ employees to contact the Administrator in order to use the Technical Support service. 

For more information regarding the location of personal data provided by during the contact via systems and methods independent of the Administrator, please read their privacy policies.

Data collected by PostHog is stored and processed on servers located within the territory of the European Union.

Disclosure of Personal Information

The Administrator does not share Personal Data with other entities that are separate administrators, processing Personal Data for their own purposes, independently of the Administrator.

The Administrator may be obliged to provide Personal Data by law. In such a case, before making it available, the Administrator will verify the legal basis for requesting the disclosure of Personal Data of the authorities requesting it.

As part of the implementation of Technical Support, people who contact the Administrator choose the method of contact, e.g.:

  • via the contact form;
  • by e-mail;
  • by telephone;
  • using another means of communication indicated by the Administrator

Then, Personal Data is processed by entities providing these services to the Administrator.

Depending on the chosen means of communication, these entities may also be separate administrators.

The Administrator is not responsible for the contact method chosen by the contacting person if it is not indicated by the Administrator. To meet the needs of Subscribers, the Administrator may accept a different method of communication, but then he or she is its user on general terms.

In addition, within the Administrator’s enterprise, employees or associates perform certain tasks, including processing Personal Data. These persons are duly authorized to process Personal Data by the Administrator and are obliged to maintain confidentiality. Such persons may process Personal Data only within the scope of the authorization granted to them by the Administrator and are not entitled to process such Personal Data for their own purposes. The Administrator shall provide an appropriate legal basis for this processing, including, if required by GDPR regulations, entering into an appropriate Personal Data processing entrustment agreement.

Rights of persons to whom Personal Data relates

Any person whose Personal Data is processed by the Administrator has rights set forth in the GDPR and may request their exercise. If you wish to make a request for the exercise of your GDPR rights, please contact the Administrator directly, so that he can provide you with all the necessary assistance.

Under GDPR you have the following rights:

  1. the right to receive information about the processing of Personal Data – we implement this right in this Privacy Policy. Regardless of this, you may submit any inquiry regarding the processing of your Personal Data by the Administrator;
  2. the right to receive a copy of your Personal Data processed by the Administrator – this right applies to Personal Data whose Administrator is the owner of WP FP;
  3. the right to rectify Personal Data – if the person to whom the Personal Data concerns thinks that the Personal Data processed by the Administrator is incorrect or outdated, he has the right to request their update. However, the Administrator has no right to change Personal Data provided by other entities, in particular by the Subscription Provider;
  4. the right to object to the processing of Personal Data – then the Administrator will conduct an appropriate examination of interests in accordance with GDPR;
  5. the right to limit the processing of Personal Data – for the duration of the processing proceedings by the Administrator;
  6. the right to delete Personal Data – to the extent that the Administrator does not have a current legal basis for their processing; The Administrator has no right to delete Personal Data from locations belonging to other entities to the extent that he is not the personal data administrator, in particular he has no right to delete Personal Data from the Subscription Provider’s servers and telecommunications operator.

The detailed scope of rights specified in the GDPR can be found in the text of the GDPR (Articles 12-22 of the GDPR), located at the link: https://eur-lex.europa.eu/eli/reg/2016/679/oj  

If a Personal Data subject believes that the Administrator is violating his or her right to the protection of Personal Data, he or she also has the right to file a complaint with a supervisory authority. The supervisory authority with jurisdiction over the Administrator’s headquarters is the Spanish supervisory authority: Agencia Espaola de Proteccion de Datos, website: https://www.aepd.es/, telephone number: +34 900 293 183.

The Personal Data subject may file a complaint with the supervisory authority having jurisdiction over his/her location / of his/her choice. A list of data protection authorities can be found at https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm .

Before you complain to the supervisory authority, please contact the Administrator. We place great importance on ensuring compliance with the GDPR and will make every effort to clarify any doubts. 

Thank you for reading this Privacy Policy.
Krzysztof Planeta