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More in our privacy policy

Privacy Policy

  • Version 1.6

for the website and plugin EZZE WCAG Pro

Controller
Patrick Helms
Neue Heimat 20
15848 Beeskow
Germany
Email: support@ezze-wcag-pro.com
Support: https://ezze-wcag-pro.com/support/
Website: https://ezze-wcag-pro.com

1. Overview

This Privacy Policy explains the processing of personal data in two separate contexts:

  1. when you use our website at https://ezze-wcag-pro.com, including contact requests, support area access, cookie/consent management, and web analytics; and
  2. when you use the EZZE WCAG Pro plugin, including licensing, Freemius-related processes, and optional cloud and AI features.

Depending on the processing activity, we act:

  • as an independent controller;
  • as a processor on behalf of our customers; or
  • alongside third parties that may act in their own role for parts of the processing.

Where we provide optional cloud-based features solely on behalf of a customer, the relevant customer or website operator remains responsible for the primary legal basis vis-à-vis its end users and website visitors. In those cases, our Data Processing Addendum also applies.

2. Contact details

Controller
Patrick Helms
Neue Heimat 20
15848 Beeskow
Germany
Email: support@ezze-wcag-pro.com
Support: https://ezze-wcag-pro.com/support/

No data protection officer is currently appointed. No EU or UK representative is currently appointed.

3. Categories of personal data

Depending on the context, we may process in particular the following categories of personal data:

  • account, billing, and contact data, such as name, email address, company, country, billing and order information;
  • website, plugin, and installation data, such as site URL, license or site identifiers, plan, subscription status, version information, language, and settings;
  • support and communication data, such as messages, attachments, screenshots, and ticket history;
  • diagnostic, device, and security data, such as IP address, technical logs, browser data, or error data;
  • cloud feature input data, such as URLs, image URLs, content fragments, technical metadata, accessibility findings, and AI-related inputs;
  • cloud feature output data, such as generated alt text, explanations, summaries, recommendations, or similar outputs;
  • usage and quota data, such as timestamps, event type, plan, provider/model information, token estimates, and estimated costs;
  • cookie, consent, and web analytics data, such as consent status, cookie identifiers, device identifiers, usage events, page views, and shortened or pseudonymous usage statistics.

4. Sources of personal data

Personal data may be collected in particular:

  • directly from you;
  • from your use of our website, the plugin, or optional cloud features;
  • from Freemius or payment-related partners where relevant for licensing, subscriptions, orders, or account administration;
  • through support channels and the support area;
  • from your browser, device, or hosting environment where technically necessary.

5. Privacy when using our website

5.1 Website operation and technical provision

Purpose: providing our website, maintaining stability and security, protecting against misuse, and troubleshooting technical issues.
Legal basis: Art. 6(1)(f) GDPR.
Legitimate interests: secure and stable website operation, IT security, misuse prevention, troubleshooting, and system integrity.

For technologies that are not strictly necessary, we ask for your consent through our own cookie banner. It is part of our website; no external consent service is used for it. You can choose “Accept all”, “Reject all”, or select individual categories under “Settings”. You can change or withdraw your choice at any time via “Cookie settings” in the website footer.

We store your choice in the ezze_consent cookie in your browser (consent version, selected categories, and time of the choice). Storage period: 6 months; after that we ask again. No other data about your choice is transmitted to us or to third parties.

Purpose: obtaining, storing, and managing consent choices and documenting the selected consent status.
Legal basis: Art. 6(1)(c) GDPR where documentation is legally required, supplemented by Art. 6(1)(f) GDPR. Storing the ezze_consent cookie is strictly necessary to respect your decision (Section 25(2) No. 2 of the German TDDDG).
Legitimate interests: legally compliant consent management and orderly technical control of technologies used on our website.

5.3 Google Analytics

Our website uses Google Analytics 4 for reach measurement and analytics. Google Analytics is loaded only if you have consented to the “Statistics” category in the cookie banner. Without your consent, no connection to Google is established. We use Google Consent Mode: until you decide, all storage and advertising signals are set to “denied”.

Purpose: reach measurement, statistical analysis of website use, and improvement of content, website structure, and user guidance. This includes analyzing which steps lead to a download, a beta request, or a purchase (for example clicks on plan buttons leading to checkout, download, beta, and contact links, switching the billing period, opened FAQ entries, and started videos).
Legal basis: Art. 6(1)(a) GDPR; for storing and accessing information on your device, Section 25(1) of the German TDDDG.

In this context, information about the use of the website, pseudonymous identifiers, device information, browser information, page views, interactions, and technically required online identifiers may be processed. Google Analytics 4 does not store IP addresses. Google signals and ad personalization features are disabled.

Cookies: _ga and _ga_<ID> (distinguishing visitors and sessions), stored for up to 2 years.
Retention of analytics data: 14 months, after which Google deletes it automatically.

The provider is generally Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. We have concluded a data processing agreement with Google. Processing by Google LLC, USA, cannot be excluded. Google LLC is certified under the EU-US Data Privacy Framework; the transfer is based on the European Commission’s adequacy decision (Art. 45 GDPR). Further information is available in Google’s Analytics privacy and contractual documentation.

Withdrawal: You can withdraw your consent at any time with effect for the future by switching off statistics under “Cookie settings” in the website footer or by choosing “Reject all”. The Google Analytics cookies in your browser are then deleted.

5.4 Contact form, support area, and email communication

If you contact us through a contact form, by email, or through our support area, we process the data you submit in order to handle your request.

Purpose: handling inquiries, support, troubleshooting, communication regarding contract performance, or pre-contractual communication.
Legal basis: Art. 6(1)(b) GDPR where the request relates to contract initiation or performance, supplemented by Art. 6(1)(f) GDPR.
Legitimate interests: efficient communication, support, documentation of matters, and misuse prevention.

5.5 No newsletter use at present

We do not currently operate a general website newsletter. If marketing or update emails are introduced in the future, this Privacy Policy will be updated accordingly.

5.6 Free Website Check

On our website, you can have a publicly accessible web page checked for common accessibility barriers free of charge (“Website Check”).

Data processed: the address (URL) you enter, the language of our website, and the time, status and result of the test. To protect against automated requests, your browser solves a short computational task (without third-party providers and without cookies). To limit the number of tests, we process your IP address only as a daily changing, encrypted hash value; we do not store the IP address itself.
Process: The test runs via our server in the European Union. For the check, we transmit the URL you entered to the Google PageSpeed Insights API, whose servers retrieve the specified page. Your IP address is not transmitted to Google. To detect cookie banners and WordPress, our web server additionally retrieves the specified page once itself.
Purpose: carrying out the test you requested and displaying the report, protection against misuse and overload, and further development of our offering based on the logged addresses.
Legal basis: Art. 6(1)(b) GDPR for carrying out the test; Art. 6(1)(f) GDPR for misuse prevention and logging.
Legitimate interests: secure and fair operation of the free offering, defense against automated requests, and improvement of our product.
Retention: report via the report link 7 days; cache per address 24 hours; log of entered addresses 14 months; hash values for rate limiting no longer than 3 days.

Please only enter addresses of publicly accessible pages and no URLs containing personal data, access keys or similar parameters.

6. Privacy when using the EZZE WCAG Pro plugin

6.1 Account, licensing, subscription, and product administration

Purpose: activating and managing licenses, subscriptions, plan entitlements, updates, and related account functions.
Legal basis: Art. 6(1)(b) GDPR; supplemented by Art. 6(1)(f) GDPR.
Legitimate interests: contract administration, misuse prevention, protection against unauthorized use, and economically operating the offering.

6.2 Freemius, checkout, and licensing

We use Freemius and related providers for licensing, subscriptions, checkout, product updates, customer management, and related functions.

Depending on the specific process, Freemius may act:

  • as our service provider;
  • as an independent controller for parts of its own platform operations;
  • as merchant of record or in a similar role where applicable under the relevant order flow.

Where relevant, you can also find additional legal information in the following documents:

6.3 Local-only functionality

Some functions of EZZE WCAG Pro may operate locally on your WordPress installation without transmitting data to us. In such cases, we receive no personal data or only technically necessary data from that functionality.

6.4 Optional cloud features

If you enable optional cloud-based functionality, relevant input data may be transmitted to our infrastructure and/or selected service providers to provide the requested feature. Depending on the feature, this may include:

  • page URLs for accessibility tests;
  • image URLs for AI-generated alt text or image review;
  • accessibility findings, audit identifiers, content fragments, technical metadata, or language settings;
  • license, plan, or site identifiers where required for service delivery, abuse prevention, or support.

Purpose: providing optional cloud-based testing, AI-generated alt text, AI explanations, AI insights, image reviews, and other requested outputs.
Legal basis: typically Art. 6(1)(b) GDPR in relation to our customers; where we act solely on behalf of a customer, the processing is carried out under that customer’s instructions and legal basis.

6.5 AI-assisted features

Where AI-assisted features are enabled, submitted inputs may be processed by us and/or third-party AI providers used to deliver the functionality. Before submitting image data, image URLs, or related content for AI-generated alt text or similar functionality, you must ensure that you are authorized to use and submit such content and that a sufficient legal basis exists for the relevant processing. Activation and use of these features take place under the customer’s or user’s own responsibility.

Please do not submit special categories of personal data or confidential third-party information unless this is clearly supported and contractually covered.

6.6 Server-side storage in proxy operations

As part of the cloud features, our infrastructure may store certain data beyond the immediate request-response cycle, in particular:

  • usage and quota logs, such as timestamps, event type, plan, IP address, provider/model information, token estimates, estimated costs, and, depending on the feature, selected technical metadata such as a tested URL or image URL;
  • helper and mapping files, such as plan or domain mapping files;
  • technical logs and error logs; in support or error cases, enhanced debug logging may be activated temporarily.

Image files themselves are not routinely stored as a normal product feature in the described AI image workflows. Full prompts or full AI outputs are not routinely stored as a usage archive; however, more detailed log entries may temporarily occur in debugging or error contexts.

To ensure availability and recoverability, encrypted incremental technical backups of the proxy/cloud infrastructure are created. These backups may include personal data that was present in the backed-up systems at the time of backup. Backups are used solely for restoration, security, and emergency purposes, not for active product functionality or analysis. Access is restricted to administrative purposes. The offsite backup is currently stored in encrypted form with Hetzner Online GmbH on a Storage Box in Germany.

6.7 Fraud prevention, abuse detection, and service protection

Purpose: detecting, preventing, and investigating misuse, unauthorized access, fraudulent transactions, or harmful activity.
Legal basis: Art. 6(1)(f) GDPR.
Legitimate interests: IT security, misuse prevention, infrastructure protection, economically operating the services, and service integrity.

Purpose: complying with legal, tax, accounting, consumer protection, and regulatory obligations and establishing, exercising, or defending legal claims.
Legal basis: Art. 6(1)(c) GDPR and Art. 6(1)(f) GDPR.
Legitimate interests: documentation, legal defense, enforcement of claims, and proof of proper service delivery.

7. Recipients and categories of recipients

We may share personal data, where necessary, with the following categories of recipients:

  • hosting and infrastructure providers;
  • backup and recovery providers where required for encrypted technical backups;
  • Freemius and related commerce, subscription, licensing, or customer management providers;
  • payment-related service providers and tax/compliance vendors;
  • AI providers such as OpenAI, where used for enabled AI functionality;
  • external services for accessibility analysis, including the Google PageSpeed Insights API;
  • web analytics and consent service providers where used on the website;
  • professional advisors, auditors, insurers, or legal counsel;
  • courts, authorities, or regulators where legally required.

A current list of relevant subprocessors / major service providers is available at:
https://ezze-wcag-pro.com/subprocessors/

8. International transfers

Personal data may, where necessary for the provision of our services, be transferred to or processed in countries outside the EEA, the United Kingdom, or Switzerland.

Under the current setup, the proxy/cloud infrastructure hosted with IONOS Cloud GmbH is operated from a server location within the European Union. International transfers may still apply in particular to:

Encrypted offsite backups are currently stored with Hetzner Online GmbH on a Storage Box in Germany. Under the current setup, this backup storage does not involve a third-country transfer.

  • OpenAI for certain AI features;
  • Google Analytics and possibly other Google services;
  • Google PageSpeed Insights API for accessibility testing of URLs submitted by the customer or entered in the Website Check.

Where required, we use appropriate transfer mechanisms such as:

  • an adequacy decision;
  • Standard Contractual Clauses;
  • other lawful safeguards or contractual protections.

Further information about relevant safeguards can be provided on request, subject to confidentiality and security constraints.

9. Retention periods

We retain personal data only as long as necessary for the purposes described in this Privacy Policy.

As a rule, the following periods or criteria currently apply:

  • contact requests, support area, and support communications: up to 24 months;
  • security and technical website logs: generally up to 14 days;
  • Website Check: report 7 days, cache 24 hours, log of entered addresses 14 months, rate-limiting hash values no longer than 3 days;
  • consent/cookie records: for as long as legally or organizationally required for documentation;
  • web analytics data (Google Analytics): 14 months, after which Google deletes it automatically; only on the basis of your consent;
  • ezze_consent cookie (your cookie choice): 6 months;
  • usage and quota logs / cloud-related usage data: generally up to 180 days;
  • debug or error logs with enhanced contents: activated only when needed and usually retained only briefly, typically up to 7 to 14 days;
  • technical backups of the proxy/cloud infrastructure: encrypted backups with limited rotating retention;
  • image files from AI image workflows: no routine persistent storage as a product feature;
  • account, license, and subscription data: for the duration of the user or contractual relationship and beyond where legally required or necessary for legal claims.

Where statutory retention obligations apply or longer retention is required for legal defense, data may be stored beyond these periods to the extent necessary. Data contained in backups is not actively processed and remains there only until automatic rotation; after a restoration, the regular deletion and retention rules are applied again.

10. Requirement to provide data

The provision of certain personal data is necessary for the use of individual functions or for carrying out pre-contractual or contractual measures.

This applies in particular to:

  • contact and communication data for inquiries;
  • account, license, and subscription data for activation and administration of the plugin;
  • technical input data such as URLs, image URLs, or site identifiers where required for the requested cloud feature;
  • billing or order-related data in the context of checkout and licensing processes.

If such data is not provided, we may not be able to process the relevant request or provide the relevant function, license, support service, or contractual performance in full.

11. Automated decision-making and profiling

No automated decision-making within the meaning of Art. 22 GDPR takes place that produces legal effects concerning you or similarly significantly affects you.

Technical workflows, automated checks, AI outputs, misuse detection, or other automated processes are used to provide and secure our services but, under our current setup, do not constitute automated decision-making within the meaning of Art. 22 GDPR.

12. Your rights

Where provided by law, you may in particular have the following rights:

  • access to your personal data;
  • rectification of inaccurate data;
  • erasure of your data;
  • restriction of processing;
  • objection to processing;
  • data portability;
  • withdrawal of consent with future effect where processing is based on consent;
  • complaint to a competent data protection supervisory authority.

To exercise your rights, please contact us at:
support@ezze-wcag-pro.com

Where we process data solely as a processor on behalf of a customer, we may refer your request to the relevant customer.

13. Children

Our services are not directed to children below the minimum age required under applicable law unless explicitly stated otherwise. We do not knowingly collect personal data from children in violation of applicable law.

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The current version will be published on this page, and the last updated date will be adjusted accordingly. Where required by law, we will provide additional notice of material changes.

15. Short notices for product pages or settings screens

Short privacy notice

When optional cloud features of EZZE WCAG Pro are used, relevant technical, licensing, usage, and feature input data may be processed by us and selected service providers to provide the requested functionality. See details in this Privacy Policy: https://ezze-wcag-pro.com/privacy-policy/

Short AI notice

If AI features are enabled, submitted inputs and generated outputs may be processed by third-party AI providers used to deliver those features. See details in this Privacy Policy and our DPA: https://ezze-wcag-pro.com/data-processing-addendum/

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