1 Introduction
1.1 At WiseAmigo (herein ‘application’, ‘website’) we endeavour to safeguard the privacy of our users. Your privacy is important to us. In this policy we describe how we will treat your personal information/data. The policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the application, website and application/website owners. Furthermore the way the application and website processes, stores and endeavours to protect user data and information is also detailed within this policy.
2 Collecting personal information
2.1 We may collect, store and use the following kinds of personal information:
2.1.a mobile device information and data pertaining to the use of the application (this includes your IP address, geographical location, device type and version, operating system, referral source, length of visit, feature use and application navigation paths);
2.1.b information that you provide to us when registering with our application or website (including but not limited to your name, email address, or message to us);
2.1.c information that you provide upon completing your user profile on our application (including but not limited to your name, profile pictures, career history, education, job title, working location, date of birth, nationality and bio);
2.1.d information that you share with others via post to our application for publication (including but not limited to your user name, your profile pictures and the content of your posts, comments, interactions and other forms of data uploaded or inputted);
2.1.e information contained in or relating to any communication that you send to us or send through our application (including but not limited to the communication content and metadata associated with the communication);
2.1.f information that you provide to us when using the services on our application, or that is generated in the course of the use of those services (including but not limited to the timing, frequency and pattern of application or service use, your past, present & future use, noted spotlights, elements or material explored with the application, stated or implied preferences, users you follow and/or users that follow you);
2.1.g any other personal information that you choose to send to us; and
2.1.h information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including but not limited to your name and email address);
2.2 Before you disclose to us the personal information of another person, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with this policy.
3 Processing personal information
3.1 Personal information submitted to us through our application will be used for the purposes specified in this policy or on the relevant pages of the application.
3.2 We may use your personal information to:
3.2.a administer our application and business, including sending your in-app feedback to other users via the Spotlight/Notification Provide Feedback (‘Request for Help’) mechanism;
3.2.b enable your use of the social networking services available on our application;
3.2.c send you notifications;
3.2.d personalise our application for you, including suggesting users to follow;
3.2.e deal with enquiries and complaints made by or about you relating to our application;
3.2.f wherever possible to keep our application secure reducing the likelihood of fraud;
3.2.g verify compliance with the terms and conditions governing the use of our application (including monitoring private messages sent through our application private messaging service);
3.2.h send you non-marketing commercial communications;
3.2.i send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you (you can inform us at any time if you no longer require marketing communications);
3.2.j provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
3.2.k undertake advertising activities within the application including the recommendation of third-party services;
3.2.l facilitate indirect or direct booking of third-party services;
3.2.m offer you access to competitions, offers for third party services & rewards; and
3.3 If you submit personal information for publication on our application, we will publish and otherwise use that information in accordance with the licence you grant to us.
3.4 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party's direct marketing.
4 Disclosing personal information
4.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
4.2 We may disclose your personal information:
4.2.a to the extent that we are required to do so by law;
4.2.b in connection with any ongoing or prospective legal proceedings;
4.2.c in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
4.2.d to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
4.2.e to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
4.3 Except as provided in this policy, we will not provide your personal information to third parties.
5 International data transfers
5.1 Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy. This includes locations in which our servers are hosted.
5.2 Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: the United States of America, Russia, Japan, China and India.
5.3 Personal information that you publish on our application or submit for publication on our application may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
5.4 You expressly agree to the transfers of personal information described in this Section.
6 Retaining personal information
6.1 This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
6.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 Notwithstanding the other provisions of this Section, we will retain documents (including electronic documents) containing personal data:
6.3.a to the extent that we are required to do so by law;
6.3.b if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
6.3.c
in order to establish, exercise or defend our
legal rights (including providing information to others for the purposes of
fraud prevention and reducing credit risk).
7 Security of personal information
7.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
7.2 We will store all the personal information you provide on secure (password and firewall-protected) servers.
7.3 All electronic financial transactions entered into through our application will be protected by encryption technology.
7.4 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7.5 You are responsible for keeping the password you use for accessing our application confidential; we will not ask you for your password (except when you log in to our application).
8 Amendments
8.1 We may update this policy from time to time by publishing a new version on our application.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8.3 We may notify you of changes to this policy by email or through our application.
9 Your rights
9.1
You may instruct us to provide you with any personal information we hold
about you; provision of such information will be subject to:
9.1.a no fee; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. and
9.1.b the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
9.2 We may withhold personal information that you request to the extent permitted by law.
9.3 You may instruct us at any time not to process your personal information for marketing purposes.
9.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
9.5
Under
applicable data protection laws (such as the UK GDPR), you have the following rights:
- The right to access the personal data we hold about you
- The right to rectification of inaccurate or incomplete personal data
- The right to erasure (‘right to be forgotten’) in certain circumstances
- The right to restrict processing of your personal data
- The right to object to our processing of your personal data
- The right to data portability to another service provider
- The right to withdraw your consent at any time
- The right to lodge a complaint with a data protection authority
10 Third party applications
10.1
Our
application includes
hyperlinks to, and details of, third party applications & websites.
10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
10.3 We use third-party payment processors such as Stripe to handle payment transactions. These companies will collect and use your payment information in accordance with their own privacy policies. We do not store your full credit card details.
11 Data Breach Notification Procedure
11.1 In the event of a data breach, we will notify affected users without undue delay and within 72 hours of becoming aware of the breach, where feasible, in accordance with applicable data protection laws.
12
Children’s Data Handling
12.1
Our services are not directed to individuals
under the age of 13. We do not knowingly collect personal data from children.
If we become aware that we have collected data from a child without parental
consent, we will delete that information promptly.
13 Updating information
13.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
14 Analytics
14.1 From time to time we may use third-party services to analyse the use of our application & supporting website.
14.2 Our analytics service provider generates statistical and other information about application.
14.3 The information generated relating to our application is used to create reports about the use of our application.