Last updated: March, 2021
Our Commitment to You
Wazimo Ltd. and its affiliated companies (“Wazimo” or "we") are dedicated to providing its users with transparency and control over the use of their data. In order for us to provide you with our services we may collect and process certain personal information about you and your activity.
By entrusting us with your information, we would like to assure you of our commitment to keep such information private. We have taken measurable steps to protect the confidentiality, security and integrity of this Information. We encourage you to review the following information carefully.
(1) Grounds for data collection
Your “Personal Data” (meaning any information which may potentially allow your identification with reasonable means) will be processed as necessary for the performance of our contractual obligations towards you and providing you with our services and products (including, without limitation, any content therein) and the operation of our websites and mobile apps and delivery of emails to you (collectively the “Services”, and the “Websites”), to protect our legitimate interests and for compliance with legal and regulatory obligations to which we are subject. When you use our Services, you consent to the collection, storage, use, disclosure and other uses of your Personal Data as described in this Policy.
(2) How do we receive data about you?
We receive your Personal Data from various sources:
- Registration information - When you voluntarily provide us your personal details in order to create an account or register to our Services (for example, your name and email address).
- When you communicate with us - For example when you send us a message, or apply to be a content provider/editor, we collect the Personal Data you provided us with.
- When you submit content to or through the Services.
- When you respond to or participate in one of our polls, surveys, votes, rankings, quizzes, contests, sweepstakes, games, forums or by otherwise expressing an opinion.
- When you click on links included in our Services that lead to third party products and/or services offered on third party sites by business partners we are affiliated with (“Affiliate Link/s”; please see our Terms for additional information in this respect).
- When you purchase, return, or exchange products offered through the Services.
- Third party information – We may receive your data from third party providers who help us with the provision and maintenance of our Services, such as social networks (for example your name and user name, when you register or log-in to our Services), traffic analytics vendors, fraud prevention agencies and others. We also receive your data from publishers and advertisers who use our platform and other services.
(3) What type of data we collect?
Personal Data In the course of using the Services, we may ask you to provide us with certain Personal Data to provide and improve the Services, to contact or identify you, to enable you to access certain parts of the Websites, and as otherwise indicated in this Policy. We may collect the following Personal Data about you: • Identifiers: o When you sign up to an event or receive our newsletter, when you send us a message (or submit a support ticket), or otherwise communicate with us in relation to the Services, we may receive certain identifiers, such as: your name, email address or other information included in such communications. o If you create an account or register to our Services, or connect your account and log-in to our Services via to a social network (for example: if you log in via Facebook), we may also collect certain identifiers, such as your associated credentials, profile name, email address, profile photo, age and country/state of residence. o Payment data such as your payment instrument number (such as a credit card number) and billing information, collected in order to process your payments for purchases, fulfill your requests for refunds, returns, or exchanges, and process the redemption of discounts. This data is usually processed by our relevant service providers, and not retained by us.o In the framework of one of our polls, surveys, votes, rankings, quizzes, contests, sweepstakes, games, forums, content publishing, and when you choose to provide it, we may also collect information about your personal or professional interests, favorites and opinions about various products, programs and services. o Internet or other electronic network activity information - our Services may use your IP-address and UDID and other information regarding your interaction with our Services and with advertisements displayed on our Services.o Geolocation data – our Services may use information regarding your general location. Non-Personal Data We also collect data about the use of our Services and the characteristics and activities of users, in order to operate it and improve it. We may collect the following non-Personal Data: Technical information – this includes data such as website visits, the browser you are using and its display settings, your operating system, device type, session start/stop time, time zone, network connection type (e.g., Wi-Fi, cellular), and non-identifiable cookie information. Information from third parties – this includes information we receive from our business partners. This may include pseudonymous advertiser identifiers that some advertisers or other third party ad platforms choose to share with us. This information is also used to enhance data points about a particular unique browser or device.
Voice Processing Technologies
(4) How do we use the data we collect?
(5) With whom do we share your Personal Data?
(6) How we protect your information
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. Your data is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees or partners on a “need to know” basis, in order to enable the carrying out of the agreement between us. While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the Services, and you do so at your own risk.
We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, trading information, account opening documents, communications and anything else as required by applicable laws and regulations.
(8) Rights and Information for Residents of Specific Jurisdictions
A. European Users' Rights If you reside within the European Union, you may request to: Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information. Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format. Request rectification of your Personal Data that is in our control. Request erasure of your Personal Data. Object to the processing of Personal Data by us. Request to restrict processing of your Personal Data by us. Lodge a complaint with a supervisory authority. However, please note that these rights pertain to EU residents only, are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
Transfer of data outside the EEA
EU users, please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.
B. California Residents
In the preceding 12 months, we have collected, disclosed, and/or sold the following categories of Personal Data:
We may share or transfer Personal Data to third parties as assets that are part of a merger, acquisition, bankruptcy or other transaction in which the third party assumes control of all or part of Wazimo. Such transfer will be handled according to the requirement of the CCPA and shall not be regarded as a sale of Personal Data under the CCPA.
Sources of Personal Data
* Consumer directly;
* Social media;
* Fraud prevention service providers;
* Analytics Providers;
* Ad networks.
In the 12 preceding months, we have collected the above-mentioned categories of Personal Data from either of the following categories of sources:
California Consumers' Rights
The CCPA provides consumers with specific rights regarding their Personal Data. This section describes your CCPA rights and explains how to exercise those rights.
Access to Personal Data You may request, up to two times in a 12 months period, that we disclose to you the categories and specific pieces of Personal Data that we have collected about you, the categories of sources from which your Personal Data is collected, the business or commercial purpose for collecting your Personal Data, the categories of Personal Data that we disclosed for a business purpose, any categories of Personal Data about you that we sold, the categories of third-parties with whom we have shared your Personal Data, and the business or commercial purpose for selling your Personal Data, if applicable.
Deletion Requests You have the right to request that we delete any Personal Data collected from you and retained, unless an exception applies. Once we receive and confirm your verifiable consumer request, we will delete (and where necessary and relevant, direct our service providers, subcontractors, and consultants to delete) your Personal Data, unless an exception applies.
Right to Opt-Out of the Sale of Personal Data In the event that we sell your Personal Data, you have the right to submit a request to opt-out of the sale of your Personal Data. You may change your decision at any time and permit us to sell your Personal Data.
If you do not want us to sell your Personal Data to third parties, please click on the “Do Not Sell My Personal Information” link located in our homepage for residents located in California.
After you opt-out, we may continue to share some Personal Data with our partners (who will function as our service providers in such instance) to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services are working correctly and securely, providing aggregate statistics and analytics and/or preventing fraud. If you access this site (or app) from other devices or browsers, visit the links below from those devices or browsers to ensure your choice applies to the Personal Data collected when you use those devices or browsers.
Additionally, although clicking the “Do Not Sell My Personal Information” link will opt you out of the sale of your Personal Data for advertising purposes, it will not opt you out of the use of previously collected and sold Personal Data or all interest-based advertising. If you would like more information about how to opt-out of interest-based advertising in desktop and mobile browsers on a particular device, please visit https://optout.aboutads.info/ and https://optout.networkadvertising.org/. You may also download the AppChoices app at http://www.aboutads.info/appchoices to opt-out in connection with mobile apps, or use the platform controls on your mobile device to opt-out.
Exercising Your Rights You can exercise your rights to access to your Personal Data or request deletion of your Personal Data, by submitting a verifiable consumer request to our email address: [email protected] (please provide the required details as per Section 12 below).
In addition, you can exercise your rights (such as access and deletion) via our webform located at https://www.minutemedia.com/, where you can submit a verifiable user request.
Only you or a person legally authorized to act on your behalf may make a consumer request related to your Personal Data.
The request must:
Provide sufficient information to allow us to reasonably verify that you are the person about whom we collected Personal Data or an authorized representative. Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. We will only use Personal Data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. If you have any general questions about the Personal Data that we collect about you how we use it, please contact us at [email protected] (please provide the required details as per Section 12 below).
Response Timing and Format Our goal is to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing within the first 45 days period. We will deliver our written response, electronically. Any disclosures we provide will cover the 12-month period preceding the request. If reasonably possible, we will provide your Personal Data in a format that is readily useable and should allow you to transmit the information without hindrance.
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.
In case of rejection, the response we provide will explain the reasons for which we cannot comply with your request.
Please note that these CCPA rights are not absolute and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.
Designating Agents You can designate an authorized agent to make a request under the CCPA on your behalf if:
The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and You sign a written declaration that you authorize the authorized agent to act on your behalf. If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
Non-Discrimination Unless permitted by the CCPA, in connection with you exercising your aforementioned rights, 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. Requests Metrics We publish metrics regarding the number of requests we have received, complied with (in whole or in part) or denied, and also the median number of days in which we responded to such requests, in the previous year, as applicable to the time period in which the CCPA was in effect. As of the date of publishing this Policy, such yearly data has yet to have been received. Once such data is received, it will be published in a dedicated Consumer Requests Metrics page which will be available within this Policy
C. Brazilian Residents The following part of this Policy complements the general part of the Policy and addresses the specific disclosure requirements under the Brazilian Data Protection Law (Lei Geral de Proteção de Dados, "LGPD").
Processing of Personal Data The processing of your Personal Data is not a condition for the use our Services. However, parts of our Services may not be available without registration and/or payment, which involve the processing of Personal Data.
Brazilian Users' Rights: If you reside in Brazil, you have the following rights under LGPD:
Receive confirmation whether Personal Data concerning you is being processed; Access your Personal Data; Correct incomplete, inaccurate or outdated Personal Data; Request anonymization, blocking or deletion of unnecessary, excessive Personal Data; Request data portability to another service provider or product, upon express request, as may be provided by the appropriate law; Request deletion of Personal Data processed with your consent; Obtain information about the public or private entities with which we share your Personal Data; Request information on the possibility of you not providing consent, as well as being informed about the consequences should consent not be given; Revoke your consent. Contact information: [email protected] (please provide the required details as per Section 12 below).
(9) Other Jurisdictions
Under certain jurisdictions, some of the aforementioned rights may apply as well. Please contact us using the contact details provided below and we would make our best efforts to assist with any questions or requests.
(10) Our Policy toward Children
We understand the importance of protecting children’s privacy, especially in an online environment. The Services are not designed for or directed at children under the age of 16 years old (“Minors”). We do not knowingly collect Personal Data from Minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Data, he or she should contact us using the details provided below.
(11) Updates to this Policy
Notwithstanding the forgoing, as of January 1st 2020, this Policy will be updated at least once every 12 months.
(12) How to contact us?
If you wish to exercise any of the aforementioned rights, or receive more information, please contact our Data Protection Officer (“DPO”) using the details provided below.
Kindly specify: (a) the nature of your request, (b) your country of residence, and (c) the name of the Services (website/product/application) subject of your request
Email: [email protected]
Please be advised that [email protected] is designated solely for privacy related inquiries of our users, and we reserve the right not respond to any non-privacy inquiries that are sent via the DPO email address. For any non-privacy inquiries, please see the email addresses listed our Terms.
Upon receiving your request, and according to legal obligations to which we are subject, we will first need to verify your request and therefore we may ask you to provide us with additional verification details, as needed. Following our verification process, we will respond to your request within the timeframe required under applicable laws.