Privacy Notice

We care about your privacy. This notice explains what personal data we collect on our website, why we collect it, how we use it, and what rights you have under the GDPR.

1) Who we are (Data Controller)

Controller: Theridion IT (“we”, “us”)
Contact: gwilio.guide@gmail.com
Postal address: Landsheerstraat 34C, 9420 Erpe-Mere, Belgium
VAT number: BE0627.922.768
EU representative: Michaël Pynket

2) What we collect and why

We collect only what we need to provide our waitlist and to understand how our pages perform. We do not use cookies or similar tracking technologies on this website.

A. Waitlist sign ups

  • Data collected: Your name, and your email address.
  • Purpose: To register your interest in Gwilio and send you updates about our release, features, and related announcements.
  • Legal basis: Consent (GDPR Art. 6(1)(a))—you provide your email and opt in to receive updates. You can withdraw consent at any time (see §8).

B. Visit logs (no cookies)

  • Data collected:
    • The referrer URL (if your browser sends it),
    • An optional campaign token present in the page URL (when available),
    • A timestamp of your visit.
  • Purpose:
    • To measure basic page performance (e.g., which pages are being visited),
    • To attribute traffic to campaigns when you click a shared link that includes a token,
    • To maintain the security and integrity of our website (e.g., basic troubleshooting and abuse detection).
  • Legal basis: Legitimate interests (GDPR Art. 6(1)(f)) in running, securing, and improving our website and attributing campaign performance. We assess that the data collected is minimal and low impact, and we do not track users across websites, nor do we set cookies or use fingerprinting.

Important notes about the token and referrers:

  • The campaign token is only present if the link you follow contains it. We do not store it on your device and do not use it to build profiles.
  • The referrer URL is sent by your browser and may include query parameters from the previous page. We do not require it and we do not attempt to enrich it. If a referrer unintentionally contains sensitive data, we aim to avoid storing that by design (see §4—Security & data minimisation).

3) What we do not do

  • No cookies or local storage on your device.
  • No third party advertising pixels.
  • No cross site tracking or behavioural profiling.
  • No sale of personal data.

4) Security and data minimisation

We apply technical and organisational measures to protect your data, including access controls, encryption in transit, and least privilege access. We only collect data that is necessary for the stated purposes and retain it only as long as needed (see §6). We also take steps to minimise risk from referrer URLs by limiting what we store and avoiding the retention of unnecessary query parameters whenever feasible.

5) Who can access your data

We may share limited data with service providers (processors) who help us run the website and send waitlist emails. These providers may include: We only use processors that provide appropriate safeguards and process data under our instructions and a Data Processing Agreement (GDPR Art. 28).
We do not otherwise disclose personal data to third parties unless required by law or to establish, exercise, or defend legal claims.

6) Where we process and how long we keep data

International transfers
If our service providers are outside the EEA/UK, we rely on appropriate safeguards (e.g., adequacy decisions or Standard Contractual Clauses) to protect your data (GDPR Chapter V).
Retention
  • Waitlist data (email, name): Kept until you unsubscribe or for up to 24 months after our last interaction, whichever is sooner, unless we are required to keep it longer for legal reasons.
  • Visit logs (referrer URL, token when present, timestamp): Kept for up to 12 months for security, troubleshooting, and campaign performance insights, after which they are deleted or irreversibly anonymised.
We periodically review retention to ensure it remains appropriate.

7) Your rights (GDPR)

Depending on your situation, you have the right to:
  • Access your personal data (Art. 15)
  • Rectify inaccurate or incomplete data (Art. 16)
  • Erase your data (“right to be forgotten”, Art. 17)
  • Restrict processing (Art. 18)
  • Data portability where applicable (Art. 20)
  • Object to processing based on legitimate interests (Art. 21)
  • Withdraw consent at any time for email updates, without affecting the lawfulness of processing before withdrawal (Art. 7(3))
To exercise your rights, contact us at gwilio.guide@gmail.com. We may need to verify your identity before fulfilling your request.
You also have the right to lodge a complaint with your local supervisory authority.
For Belgium, this is the Data Protection Authority (GBA/APD): https://www.gegevensbeschermingsautoriteit.be/ (https://www.autoriteprotectiondonnees.be/).

8) How to unsubscribe and manage communications

You can email gwilio.guide@gmail.com to withdraw consent or request deletion of your waitlist data.

9) Children’s privacy

Our website and waitlist are not directed to children under 16, and we do not knowingly collect their data. If you believe a child has provided us personal data, please contact us and we will delete it.

10) Changes to this notice

We may update this Privacy Notice from time to time to reflect changes in our practices or legal requirements. We will post the updated version here with a new “Last updated” date.

Last Updated Date: Monday, 19 January 2026