1. DATA WE MAY COLLECT
We may collect and process the following data about you:
▪ Personal data including, for example, your name, e-mail address, password, and in certain instances, telephone number, data about your usage of the Products, data you provide in connection with your usage of the Products, and data collected by tracking technologies as further described in section 4 below that may identify you as an individual or allow online contact with you as an individual.
▪ If, as a primary account holder, you choose to invite additional members to become account holders, we will ask you for their name and email address. We will use this data to invite him or her to join the Products. We store this data for the sole purpose of sending invitations.
▪ wowe does not collect or process credit or debit card (“Payment Card”) data. Apple and Google collect Payment Card data with respect to in-app purchases made through the Apps. Such payment processors generally provide us with some limited data related to you, such as a unique, anonymous token that enables you to make additional purchases using the data they’ve stored, and your card’s type, expiration date, billing address, and the last four digits of your card number.
▪ For individuals using the Products in connection with a Community client account as described in section 6, business data such as your company name, and company email address to the extent that you or your Community provides such data.
▪ Social media profile information, such as name, email address, and ID, if you choose to link the Products to your social media accounts.
▪ Device information such as operating system version, device type, and system performance data.
▪ Data collected via tracking technologies, as fully described in section 4.
2. USES MADE OF THE DATA
We use information held about you in the following ways: To present our Website and its contents to you.
▪ To provide you with the Products.
To answer your questions or requests for information or handle your complaints.
▪ To ensure that content provided by the Products is presented in the most effective manner for you and for your computer or other device.
▪ To provide you with promotional communications, such as by email, to the extent that you have provided consent and/or consistent with notice and any opt-out rights to receive such communications under applicable law.
▪ To carry out our obligations arising from any agreements entered into between you and us.
▪ To allow you to participate in interactive features of the Products, when you choose to do so.
▪ To notify you about updates or changes to Product features and content.
▪ To understand your location and help us identify groups of users by general geographic market (such as zip code, state or country).
▪ To account for applicable sales taxes based on zip codes provided to our payment processors for purchases made through the Website.
▪ To inform Partners about your registration and use of the Products as described under Corporate and Other Community Sharing in section 6 above.
▪ To provide you with the SMS Service to the extent that you have provided consent for such practices under applicable law. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
▪ To manage your payments and orders.
3. CONFIDENTIALITY AND SECURITY
The security of your personal data is important to us. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal data, you can contact us at email@example.com. Except as described under the “Disclosure of Your Data” section below, we do not provide your personal data to any third party without your specific consent, as defined by applicable law. wowe maintains technical, administrative and physical safeguards to help protect the security of your personal information against unauthorized access, destruction, loss, alteration, misuse or disclosure. Your personal information is accessible to only a limited number of personnel who need access to the information to perform their duties. Please note, however, that no method of transmission over the Internet or method of electronic storage is 100% secure.
4. NEWSLETTERS OR OTHER ELECTRONIC COMMUNICATIONS
If you sign up to receive promotional materials from us via email and/or push notifications we will use the data you give us to provide the communications you have requested. If you inform us that you wish to cancel email promotional materials by selecting “unsubscribe” at the bottom of such communication or by emailing us at firstname.lastname@example.org, we will remove you from our mailing list. If you no longer wish to receive push notifications, you may turn them off at the device level. If you provide your phone number to us directly or through a third-party for the specific purpose of receiving an SMS message with a link to our Apps, you will receive such SMS message (the “SMS Service”). Standard text message rates will apply. We will endeavor to comply with these requests as soon as reasonably practicable. Please be advised that you may not be able to opt-out of receiving certain service or transactional email messages from us that are required to provide you with our Products.
5. TRACKING METHODS AND TECHNOLOGIES
wowe collects information you in a few ways. We collect information directly from you when you provide it to us, such as through filling out forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us and when you report a problem with our Website.
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: (i) details of your visits to our Website, including traffic data, location data, logs, and other communication data and resources that you can access and use on the Website, and (ii) information about your computer and internet connection, including your IP address, operating system, and browser type.
wowe uses technologies such as cookies, beacons, tags, and scripts to enable a service to recognize your device so you don't have to provide the same data several times during one task, to recognize that you may have already given a username and password so you don't need to do it for every web page requested, and to measure how people are using the Products.
We use local storage, such as HTML5, to store content data and preferences. Third parties with whom we partner to provide certain features on the Products also use HTML5 to collect and store data. Various browsers may offer their own management tools for removing HTML5.
The Products use Google Analytics code to gather statistical data. Google Analytics sets cookies to help us accurately estimate the number of visitors to the Products and the volumes of usage of the Products. This is done to ensure that the Products are available when you want them and are fast. For more data on how Google Analytics processes this data, visit www.google.com/analytics.
We will acquire consent from you in order to use such trackers or provide you with the opportunity to opt-out of such trackers, to the extent required by applicable law.
6. MOBILE ANALYTICS
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record data such as how often you engage with the Products, the events that occur within the Products, aggregated usage and performance data, and where the Applications were downloaded from. We may link the data we store within the analytics software to any personal data you submit within the mobile application.
7. LOG FILES
As is true of most websites, we gather certain data and automatically and store it in log files. This data may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
If you receive the HTML-formatted version of our email newsletter, your opening of the newsletter is notified to us and saved. Your clicks on links in the newsletter are also saved. These and the open statistics are used in aggregate form to give us an indication of the popularity of the content and to help us make decisions about future content and formatting.
8. WHERE WE STORE YOUR PERSONAL DATA
All data you provide to us through the Products is stored in our infrastructure hosted on AWS. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Products, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, and suggest that your change your password frequently.
Unfortunately, the transmission of data via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Products; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.
9. CORPORATE AND OTHER COMMUNITY SHARING
wowe is also offered through partnerships with organizations. Sometimes corporations, governments, hospitals, universities and other organizations and groups (“Partner(s)”) wish to make wowe available to their members, employees and their families, patients, customers, residents or others. For example, employers may offer their employees and their families access to wowe and brands that promote wellness may wish to and do offer wowe through their loyalty programs. When an entity provides access to wowe to others, we call those “Communities.” If you have registered to use the Products through a code, credential, or other means of registration furnished by a Partner (a “Community Subscription”), the Partner may have access to your name, email address, the date you registered to use the Products, and the date on which you last used the Products. The Partner may also have access to your Community's aggregated and anonymized general usage data (including aggregated and anonymized usage data with respect to your Community’s engagement).
10. SINGLE SIGN-ON
You may be able to log-in to our Products using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity, provide you the option to share certain personal data (such as your name and email address) with us, and to pre-populate our sign-up form. Services like Facebook Connect give you to the option to post data about your activities on our Products or to your profile page to share with others within your network.
11. YOUR DATA RIGHTS
As you may know, a European Union law called the General Data Protection Regulation (“GDPR”) gives certain rights to applicable individuals in relation to their personal data. Accordingly, we have implemented transparency and access controls to help such users, including residents of the EU, Switzerland, and the United Kingdom exercise those rights. As required under applicable law, the rights afforded to you are:
▪ A right of access: you have the right to obtain (i) confirmation as to whether personal data concerning you are processed or not and, if processed, to obtain (ii) access to such data and a copy thereof.
▪ A right to rectification: you have the right to obtain the rectification of any inaccurate personal data concerning you. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
▪ A right to erasure: in some cases, you have the right to obtain the erasure of personal data concerning you. Upon request, wowe will permanently and irrevocably anonymize your data such that it can never be reconstructed to identify you as an individual. However, this is not an absolute right and wowe may have legal or legitimate grounds for keeping such data.
▪ A right to restriction of processing: in some cases, you have the right to obtain restriction of the processing of your personal data.
▪ A right to data portability: you have the right to receive the personal data concerning you which you have provided to wowe, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from wowe. This right only applies when the processing of your personal data is based on your consent or on a contract and such processing is carried out by automated means.
▪ A right to object to processing: you have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you when such processing is based on the legitimate interest of wowe. wowe may, however, invoke compelling legitimate grounds for continued processing. When your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of such data. You may, in particular, exercise that right by clicking on the “unsubscribe” link provided at the bottom of any messages received, or by managing your privacy preferences by logging in to your wowe account.
▪ A right to lodge a complaint with the competent supervisory authority: you have the right to contact the supervisory authority to complain about wowe’s personal data protection practices.
▪ A right to give instructions concerning the use of your data after your death: as required by applicable law, you may have the right to give wowe instructions concerning the use of your personal data after your death. To exercise one or more of these rights, you can email email@example.com. You may access your personal data to modify or update at any time via an online account, or by emailing firstname.lastname@example.org. We will respond to your request in a reasonable timeframe in accordance with applicable law.
12. LEGAL BASES OF PERSONAL DATA PROCESSING
In accordance with GDPR, wowe provides the following information regarding its Article 6 legal bases for personal data processing: The performance of the contract (the wowe Terms and Conditions) between you and wowe for the data processing relating to your use of wowe’s Products (including your orders and payments);wowe’s legitimate interest, more specifically:
Our business interest in providing you with emails and push notifications for timely introductory materials and information about your wowe account, our Product features and updates, and offers to upgrade your free account to a subscription account.
▪ Our business interest in offering you particularized or adapted content based on your usage of the Products.
▪ Our business interest in recognizing you when you return to our Website and allowing us to speed up your searches.
▪ Our business interest in collecting data regarding your general usage activities for the purpose of improving our wowe user experience.
▪ Our business interest in requesting that you partake in Product surveys in order to better understand your needs and expectations.
▪ Our financial interest in providing you the opportunity to purchase wowe subscriptions for the benefit of a third party through the wowe “gifting” program.
▪ Our business interest in providing you the opportunity to invite another friend/contact to wowe and share information about your wowe activities with your friends and contacts.
▪ Our business interest in providing you with customer service communications regarding your account, questions about our content offerings, or any other matters directed to customer service staff, in order to have clear and easy communication with you and to respond to all your requests.
▪ Our business interest in estimating our audience size and usage patterns.
▪ Our business interest in collecting data related to unplanned downtime or errors in the Products.
▪ Our business interest in complying with our legal obligations, such as maintaining accurate financial records.
▪ Our business interest in verifying your eligibility in a Community and providing limited reporting to Partners associated with such Community, as further described in section 6.
13. DISCLOSURE OF YOUR DATA
We may disclose your personal data to third parties as follows:
In some circumstances, we may need to disclose your personal data to our subsidiaries, affiliates, contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them.
In some circumstances, based on your specific requests, we may need to disclose your personal data to a third party so that it can provide a service you have requested from such party, or fulfill a request for data from such party. An example of this is the SMS Service.
In some limited circumstances, we may disclose the personal data that you have provided to wowe to a third party that offers and/or provides goods or services complementary to our own for the purpose of enhancing our users’ experiences by offering you integrated or complementary functionality, complementary services or bundled pricing options.
In some limited circumstances, our email service provider may receive certain information you share in-app to provide you with personalized email communications.
If wowe’s service providers (like hosting, IT maintenance, market analytics, and payment service providers) require this data to provide services to wowe, wowe may disclose your personal data to such service providers, provided that each of such service provider to agree to maintain the confidentiality and security of your personal data in accordance with applicable law.
If we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets, provided that the prospective seller or buyer agrees to maintain the confidentiality and security of your personal data in accordance with applicable law.
If wowe is acquired by a third party, personal data held by us about our customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, such as to comply with a subpoena, bankruptcy proceedings, similar legal process, or in order to enforce or apply our agreements with you, or to protect the rights, property, or safety of wowe, our customers, or others, we may disclose such personal data in accordance with such obligation. This includes exchanging data with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We may disclose your personal data to enforce or apply our Terms & Conditions, at https://wowe.app/terms-and-conditions, and other agreements, including for billing and collection purposes.
We may disclose your personal data with your Community, if your subscription is a Community Subscription, as described under Corporate and Other Community Sharing above.
We may disclose your personal data with third parties, such as Facebook, in order to serve wowe advertisements on such third-party platforms, to the extent that you have consented to or have been provided with notice of, and an opportunity to opt-out of, such practices under applicable law.
We may disclose your personal data to fulfill the purposes for which you provide it, for any other purpose disclosed by us when you provide the information or for any purpose with your consent.
14. DATA RETENTION
The retention periods applied by wowe comply with applicable legislation in effect on the date hereof, namely:
For data relating to your account: such data will be permanently and irrevocably anonymized in the event that your account is: (i) inactive for a period of two (2) years; and (2) not subscribed to wowe. Moreover, we will permanently and irrevocably anonymize your account data within thirty (30) days of your written request to do so via email to email@example.com.
For transactional data relating to your purchases: such data is kept for the entire period of the contractual relationship, then in accordance with legal obligations and applicable statute of limitation periods. Please note that this data does not include Payment Card information, which is processed by our third-party payment processors, and not by wowe.
For data collected based on your consent to receive our marketing communications: we will use such data until you opt out, withdraw consent or applicable law requires that such data is no longer used.
When your data are collected in the context of requests/queries: such data are kept for the period necessary to process and reply to such requests or queries.
When cookies or other trackers are placed on your terminal, they are kept for a period of 12 months. Other data will be kept as long as necessary for the purposes pursued and in compliance with our legal obligations, including the applicable statute of limitations.
15. WITHDRAWAL OF CONSENT FOR PROCESSING ACTIVITIES
To the extent that you have provided appropriate consent under applicable law to certain processing activities, such consent can be withdrawn at any time by emailing firstname.lastname@example.org.
16. LINKS TO THIRD PARTY SITES
The Products may, from time to time, contain links to and from the Products of our partner networks, advertisers and affiliates. If you follow a link to any of these external websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal data to these external websites.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative at it’s website.
17. SOCIAL MEDIA WIDGETS
Our Products include social media features, such as the Facebook Like button, and widgets, such as the “Share This” button, or interactive mini-programs. These features may collect your Internet protocol address, which page you are visiting on or Products, and may set a cookie to enable the feature to function properly. Social media features and widgets are hosted by a third party or hosted directly on our Products. Your interactions with these features are governed by the privacy statement of the company providing it.
19. USE OF wowe BY MINORS
You must be 18 years of age, or the age of majority in your province, territory or country, to sign up as a registered user of the Products. Individuals under the age of 18, or the applicable age of majority, may utilize the Products only with the involvement of a parent or legal guardian under such person's account.
21.1. INFORMATION WE MAY COLLECT FROM YOU
This California Consumer Privacy Act (“CCPA”) Our Products collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device, whether collected online or offline (“personal information”). In particular, the Products have collected the following categories of personal information from consumers within the last twelve (12) months:
|Identifiers||First and last name, email address, Internet Protocol address, online identifiers.||Yes|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||First and last name.||Yes|
|Internet or other similar network activity.||Browsing history or information on a consumer’s interaction with the Products or our advertisements on third-party platforms.||Yes|
We obtain the categories of personal information listed above from the following categories of sources:
▪ Directly from you. For example, from forms you complete when registering for the Products.
▪ Indirectly from you. For example, from observing your actions on our Products
21.2. USE OF PERSONAL INFORMATION
21.3. SHARING PERSONAL INFORMATION
We may disclose your personal information to third parties for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category 1: Identifiers
Category 2: Personal Information
Category 3: Internet activity
Category 1: Identifiers
Category 2: Personal Information
Category 3: Internet activity
21.4. YOUR RIGHTS AND CHOICES
Access to Specific Information and Data Portability Rights
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
▪ The categories of personal information we collected about you.
▪ The categories of sources for the personal information we collected about you.
▪ Our business or commercial purpose for collecting that personal information.
▪ The categories of third parties with whom we share that personal information.
▪ The categories of personal information we share with third parties.
▪ The specific pieces of personal information we collected about you (also called a data portability request).
Deletion Request Rights: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will permanently and irrevocably anonymize your personal information, unless an exception applies.
We may deny your deletion request if certain CCPA exemption apply, including but not limited to, if retaining the information is necessary for us or our service provider(s) to:
▪ Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
▪ Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
▪ Debug products to identify and repair errors that impair existing intended functionality.
▪ Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
▪ Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et.seq.).
▪ Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
▪ Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it. Exercising Access, Data Portability, and Deletion Rights to exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at email@example.com. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
Upon receiving a request for access, portability, or deletion, we will confirm receipt of the request within 10 business days and provide information about our verification process and how we will process the request.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response to the email address associated with the account for account holders, and to the email address provided with the request submission for non-account holders.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily readable and useable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We do NOT sell or rent your personal information to any third parties for their own advertising or marketing purposes.
21.5. NON-DISCRIMINATIONWe will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
21.6. CHANGES TO OUR CCPA
We reserve the right to amend this CCPA at our discretion and at any time. When we make changes to this CCPA, we will post the updated notice on the Website and update the effective date. Your continued use of our Products following the posting of changes constitutes your acceptance of such changes.
22. NEVADA REVISED STATUTES CHAPTER 603A
Nevada residents who wish to exercise their sale opt-out right under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: firstname.lastname@example.org. However, please know that we don’t currently sell data triggering that statute’s opt-out requirements.
23. ACCESSING AND CORRECTING YOUR INFORMATION
You can review and change your personal information by logging into the Website and visiting your account profile page.
You may also send us an email at email@example.com to request access to, correct or delete any personal information that you have provided to us. We may not be able to delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Proper access and use of information provided on the Website is governed by our Terms &Conditions, at https://wowe.app/terms-and-conditions.
24. DATA SECURITY
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
25. CONTACT US