Last Updated: November 25, 2019
We, at The Whiz Ltd., are committed to respecting our customers’ privacy, protecting their personal information and making sure it is used properly by us.
The use of the Services constitutes consent to be bound by the terms of this Policy and you hereby agree and confirm that you will not have any claims or demands with respect to the Policy.
“Personal Information” means details which identify you or could be used to identify you, such as IP address etc.
“Non Personal Information” means information that does not personally identify you or your representative and does not reveal your specific identity as an individual and/or cannot be attributed to you, such as operation system name and version, browser name and version, device name and version and referring site.
“GDPR” means the General Data Protection Regulation (EU) 2016/679, as amended from time to time.
“Services” means use of our products or services.
This Policy was originally written in English. If you are reading a translation and it conflicts with the English version, please note that the English version prevails.
3. THE PERSONAL INFORMATION THAT WE COLLECT
4. NON PERSONAL INFORMATION
We may collect Non-Personal Information in the following ways:
By using the Services and when you provide us with Non Personal Information, you hereby agree and consent that Non Personal Information will be considered as non-confidential, non-proprietary, and unprotected.
5. HOW WE USE PERSONAL INFORMATION
Personal Information is used for the following primary purposes (as may be updated from time to time): to (i) deliver the products and services that you have requested; (ii) provide you with customer support; (iii) monitor and analyze use of the Services and study and analyze the functionality of the Services; (iv) to search for fraudulent traffic sources; (v) provide service announcements and market the Services; (vi) enforce our Terms of Service, policies and other contractual arrangements, to comply with court orders and warrants, and prevent misuse of the Services, and to take any action in any legal dispute and proceeding.; (vii) better understand your needs in order to improve and continue developing our Services; (viii) disclose to third party vendors, service providers, contractors or agents who perform functions on our behalf with respect to the Services; (x) perform functions as otherwise described to you at the time of collection.
6. HOW WE USE NON PERSONAL INFORMATION
We may use information that is Non Personal Information for the same purposes we use Personal Information (where applicable) and in addition in order to (i) compile anonymous or aggregate information, (ii) disclose to third party vendors, service providers, contractors or agents who perform tasks on our behalf in connection with the Services, (iii) monitor and analyze use of the Services and for the technical administration and troubleshooting of the Services, and (iv) provide us with statistical data.
We may use analytics tools. These tools help us understand users’ behaviour on our Website and the Services, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. The privacy practices of these tools are subject to their own policies and they may use their own cookies to provide their services. For further information about cookies, please see the ‘NON PERSONAL INFORMATION’ section in this Policy.
From time to time, we may use additional or alternative analytics services. We will provide a notice of these changes on our Website, and to you through email or other available electronic means.
We use anonymous, statistical or aggregated information, which may be based on extracts of your Personal Information, for legitimate business purposes including for testing, development, improvement, control and operation of the Services. We may share such information with third parties on our behalf. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that can be associated with you. We will share your Personal Information only subject to the terms of this Policy, or subject to your prior informed consent.
7. THE LEGAL BASIS FOR USE OF INFORMATION
We will only process your Personal Information where we have a legal basis to do so. The legal basis will depend on the reason or reasons we collected and need to use your Personal information. In almost all cases the legal basis will be:
More information on each legal basis is provided below.
More information on the basis of processing:
In cases where the legal basis for processing Personal Information is your consent, have the right at any time to withdraw the consent given to process Personal Information by sending an email to the following email address:firstname.lastname@example.org
It is hereby clarified that if you withdraw consent as noted, it is possible that we will not be able to provide you with some of the Services you ordered or to provide them in the manner intended, and you accept such outcome.
It is hereby clarified that the legal bases detailed above are the legal bases for actions to process Personal Information, carried out by us in accordance with the GDPR. If processing of Personal Information is subject to other applicable laws, then the legal basis for processing Personal Information may differ according to those applicable laws.
8. SHARING INFORMATION WITH OTHERS
We do not sell, rent or lease your Personal Information. We may share your Personal Information with service providers and other third parties, if necessary to fulfil the purposes for collecting the information, such as cloud vendors, subcontractors providing us processing services, etc., provided that any such third party will commit to protect your privacy as required under the applicable laws and this Policy.
We may also share Personal Information with companies or organizations affiliated with us, such as subsidiaries and parent companies, with the express provision that their use of such Personal Information must comply with this Policy.
Additionally, a merger, acquisition or any other structural change may require us to transfer your Personal Information to another entity, provided that the receiving entity will comply with this Policy.
9. SHARING INFORMATION WITH AUTHORITIES
We may need to disclose Personal Information in response to lawful requests by public authorities or law enforcement officials, including meeting national security or law enforcement requirements. We cooperate with government and law enforcement officials to enforce and comply with the law.
10. TRANSFER OF DATA OUTSIDE YOUR TERRITORY
We may store, process or maintain information in various sites worldwide, including through cloud based service providers worldwide. Where the GDPR applies and we transfer Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of the EEA, for example, this may be done in one of the following ways:
You can obtain more details of the protection given to your Personal Data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described the Section “CONTACT US” below.
If you are located in a jurisdiction where transfer of your Personal Data to another jurisdiction requires your consent, then you provide us your express and unambiguous consent to such transfer or the storage, processing or maintenance of the information in other jurisdictions by using the Website.
11. YOUR RIGHTS
In all of the above cases in which we collect, use or store your Personal Information, you may have the following rights and, in most cases, you can exercise them free of charge.
At any time, you may contact us at: email@example.com and request to know what Personal Data we keep about you. We will make good-faith efforts to locate the data that you request to access.
Under your right of access, you may obtain confirmation from us of whether we are processing Personal Data related to you, receive a copy of that data, so that you could verify its accuracy and the lawfulness of its processing, request the correction, amendment or deletion of the data if it is inaccurate, incomplete, outdated or processed in violation of applicable law.
However, we may retain certain information as deemed required by us in accordance with applicable laws, or for legitimate business reasons, for the duration as required under applicable laws.
In addition, we may delete any Personal Data pursuant to our policies, as in effect from time to time.
12. RESPONSE TO REQUESTS
When you ask us to exercise any of your rights under this Policy and the applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Information related to others and to ask you questions to better understand the nature and scope of data that you request to access.
We may redact from the data which we will make available to you, any Personal Information related to others.
13. INFORMATION SECURITY
We take the safeguarding of the Personal and Non Personal Information very seriously, and use a variety of systems, applications and procedures to protect the information from loss, theft, damage or unauthorized use or access when it is in our possession or control, including reasonable physical, technical and organizational measures which restrict access to the information. These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
You should take steps to protect against unauthorized access to Personal Information stored on your premises as well as defining limited access rights to such information on a need to know basis.
If you receive an e-mail asking you to update your information with respect to the Services, do not reply and please contact us at firstname.lastname@example.org
14. DATA RETENTION
We retain different types of information for different periods, depending on the purposes for processing the information, our legitimate business purposes as well as pursuant to legal requirements under the applicable law. We may retain Personal Information for as long as necessary to support the collection and the use purposes of this Policy and for other legitimate business purposes, For example, for storing information for documentation, for managing internet security for legal proceeding and for text purposes. We may store non-personal aggregate information without time limit. In any event as long as you use the services, we will retain information about you and your users, unless we are legally required to delete it, or if you seek to exercise your rights to delete the information.
15. OUR POLICY TOWARD CHILDREN
Our Site is intended for general audiences over the age of 13 years old. We do not knowingly collect Personal Information from children under the age of 13 years old. If you are not over 13 years old, DO NOT DOWNLOAD OR USE THE SITE AND MUST LEAVE IMMEDIATELY.
If we need to adapt the Policy to legal requirements, the amended Policy will become effective immediately or as required.
Your continued use of the Services following such notice shall constitute your consent to any changes made and a waiver of any claim or demand in relation to such changes. If you do not agree to the new or different terms, you should not use and are free to discontinue using the Services.
17. CONTACT US
We work hard to handle your information responsibly. If you are unhappy about the way we do this, please contact us and we will make good-faith efforts to address your concerns.
Copyright © 2019, The Whiz, Ltd. All rights reserved.
Last Updated: November, 2019