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 your name, email address, or message to us);
2.1.c information that you provide upon completing your user profile on our application (including your name, username, profile images, 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 your username and the content of your posts, comments, interactions and any other forms of data uploaded or inputted e.g. images or URLs);
2.1.e information contained in or relating to any communication that you send to us or send through our application (including 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 the timing, frequency and pattern of application or service use, noted spotlights, actions created, elements or material explored within the application, 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 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 With respect to your data, WiseAmigo is a data controller. We determine how data is used and for what purposes. Data is processed by third party data processors (listed in section 5). 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 functions within the app e.g. suggesting users you may like to follow, elements to focus on, actions to take, etc;
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;
3.3 Your data may at times be anonymised and aggregated with other data for research or commercial purposes and provided to third parties. This includes for example aggregating data with other users belonging to the same organisation, where the specific organisation has provided you and other employees with Premium accounts (by implication of paying for Premium upgrades). Any third parties will not be able to see individual user data or identify any individual user from that information. We do not share your individual data with any other third parties beyond those included for purposes of data processing (listed in data processing);
3.4 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 (e.g. displaying your username, work history, work location for other users to see);
3.5 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.
5.1a Data is stored and processed on Cloud Servers located in Virginia, US;
5.1b Email and subscriber services data is processed and stored on servers in the US;
5.1d We transfer data outside of the EU/EEA in accordance with the EU-US Privacy Shield;
5.2 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.
5.3 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).
7.6 For all security breaches we will alert users and the ICO within 72 hours of identifying the breach.
8.1 We may update this policy from time to time by publishing a new version on our application.
8.2 In the event the policy is updated we will make an announcement through our application and/or through email communications. At this time you have the option to withdraw your consent to any further data processing.
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 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.
10 Access and your right to be forgotten
10.1 You may make a request to delete your account and withdraw your consent to any further data processing by emailing firstname.lastname@example.org and providing your name, email provided for the purposes of logging into WiseAmigo and your username. All requests will be answered within one month of receiving the request.
10.2 You may make a request to access all of your data entered into the WiseAmigo application by you in the form of a data export for portability, by emailing email@example.com and providing your name, email provided for the purposes of logging into WiseAmigo and your username. Requests will be actioned within one month of receiving the request.
10.3 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.
11 Third party applications
11.1 Our application includes hyperlinks to, and details of, third party applications & websites.
11.2 We have no control over, and are not responsible for, the privacy policies, content and practices of third parties.
12 Updating information
12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
13 About cookies
13.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
13.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
13.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
13.4 Cookies can be used by web servers to identify and track users as they navigate different pages on an application and identify users returning to an application.
14 Our cookies
14.1 We may use both session and persistent cookies on our supporting website.
15.1 From time to time we may use third-party services to analyse the use of our application & supporting website.
15.2 Our analytics service provider generates statistical and other information about application.
15.3 The information generated relating to our application is used to create reports about the use of our application.
16 Our details
16.1 This application is owned and operated by WiseAmigo Ltd.
16.2 We are registered in England and Wales under registration number 9978108, and our registered office is at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, England.
16.3 You can contact us by writing to the business address given above, by using our application feedback function or by email to firstname.lastname@example.org.