User registration. When you sign up to the Service, we will process your name (or nickname) and email address. If you sign-up through Facebook, Apple, or Google or other third party service, we will only obtain your name, nickname and email address from these services. Once you are signed up, we will use a unique user ID to identify your user account. We will call all of this data “User Onboarding Data”.
User active lifetime. Throughout your use of the Service, we will process the chat messages, posts, contributions, search phrases, and reactions to content that you provide. Depending on what you choose to provide, these may include special categories of data that you provided in your posts and contributions, such as data concerning health, data concerning a natural person’s sex life or sexual orientation, political opinions, religious or philosophical beliefs. We will also process your user notification preferences which indicate which notifications you wish to receive from the Service. This data We will call this “User Active Lifetime Data”.
User analytics. We process the user-interface clicks you’ve engaged in on the Service, the time-zone set on your mobile device, the time and date you last used the Service, as well as an indication of which content and user-notifications you viewed on the Service and when. We will call this “Analytics Data”.
User moderation. We will process the content of your user posts and chats, your unique user ID on the Service and your mobile device’s unique fingerprint. We will call this “User Moderation Data”.
You are not legally obligated to provide or give access to any personal data, but we do need this information to provide you the Service.
We process User Onboarding Data, User Active Lifetime Data, Payment Data and User Analytics to provide and manage the functionality and service that the Service offers.
We process the User Onboarding Data, User Active Lifetime Data and User Analytics in order to send notifications and updates about the Service and the content you may be interested in on the Service. You can control the notification and updates you receive through the designated menu of the Service.
We also process the User Onboarding Data and User Active Lifetime Data to contact you with administrative messages.
We process Onboarding Data, User Active Lifetime Data, Payment Data and User Analytics to obtain insights for our product development, optimize user notifications, research trends, for business development purposes as well as to improve and enhance the Service.
We will process User Moderation Data to detect and handle inappropriate user content. This may lead us to restrict the inappropriate user’s access to the Service, by way of issuing the user a warning, suspending the user temporarily, or banning the user from the Service altogether.
We may invite you to complete surveys to help assess the effectiveness of Wisdo and how we and others we cooperate with can further assist you. You are not legally obligated to accept the invitation and respond to the survey. You may do so at your own discretion.
If you choose to participate in a survey conducted by a company or organization other than Wisdo, the other company or organization will process the information you provide in connection with the survey. Note that their use of your information is their own responsibility, not Wisdo’s.
You are not legally obligated to accept the invitation and respond to the survey. You may do so at your own discretion. You may opt out of us processing your data to send you these invitations, at any time, by contacting us at firstname.lastname@example.org or by following the opt-out button in each invitation.
If you post content publicly on the Service, that content will be visible to all other users of the Service with a tag indicating that you posted it. Your messages in group chats will be visible to all users of that group chat.
We will share your personal information with our service providers who assist us with the internal operations of the Service and other aspects of our business. These include:
These companies are authorized to use your personal information only as necessary to provide these services to us and not for their own promotional purposes. We do not sell your personal information to third parties.
If you have seriously abused your rights to use the Service, or violated any applicable law, we will share your information with competent authorities and with third parties (such as legal counsels and advisors), for the purpose of handling of the violation or breach. If we are required to disclose your information by a judicial, governmental or regulatory authority. If the operation of Wisdo or the Service is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition, we will share your information to enable the structural change.
We retain personal data for the duration needed to support our ordinary business activities operating the Service. Thereafter, we will still retain your personal information as necessary to comply with our legal obligations, resolve disputes, establish and defend legal claims and enforce our agreements.
We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information, such as encrypted transmission of the data we communicate to and from users.
However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed, and you cannot expect that the Service will be immune from information security risks.
Wisdo Ltd. is the data controller for the purposes of the personal data processed on the Wisdo platform.
Wisdo is based in Israel.
Our European representative, for the purposes of this Policy, is GDPR-Rep.eu
If you are within the European Economic Area, you may contact our European representative the at the following address: gdpr-rep.eu
Our Data Protection Officer (DPO) is Eliran Chay. You may contact our DPO the at the following address: email@example.com.
The legal basis for collecting and processing User Onboarding Data, Payment Data, User Active Lifetime Data is the performance of our term of service contract in providing you the Service and our legitimate interests in administering and managing the Service.
The legal basis for processing User Active Lifetime Data that is considered special categories of data (sensitive information), is that this processing relates to personal data which you manifestly made public by posting it publicly on the Service.
The legal basis of collecting and processing User Analytics is our legitimate interests in developing and enhancing the Service and our business.
The legal basis for processing User Moderation Data is our legitimate interests in maintaining an appropriate and safe environment on the Service, as well as protecting the vital interests of other users of the Service.
The legal basis under EU law for voluntarily sharing your data with competent authorities is our legitimate interests in defending and enforcing against violation and breaches that are harmful to our business.
The legal basis under EU law for sharing your data if we are legally required to do so by authorities, is our legitimate interests in complying with mandatory legal requirements imposed on us.
The legal basis under EU law for sharing your data in the event of a structural change of our business is our legitimate interests in our business continuity.
The legal basis under EU law for processing your information when you participate in surveys is your consent.
The legal basis under EU law for using your email address to send you updates to this Policy is its necessity for our compliance with the legal obligations of the GDPR.
Information we collect from you will be processed in Israel, which is recognized by the European Commission as having adequate protection for personal data.
If we transfer your information from within Europe to other jurisdictions outside Europe, we will always endeavor to do so using adequate safeguards determined by the EU Commission, such as Privacy-Shield certified companies in the United States.
If you are in the EU, you have the following rights under the GDPR subject to the limitations that the GDPR attaches to these rights:
Right to Access your personal data that we process and receive a copy of it.
Right to Rectify inaccurate personal data we have concerning you and to have incomplete personal data completed.
Right to Data Portability, that is, to receive the personal data that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this data to another service provider. Where technically feasible, you have the right that your personal data be transmitted directly from us to the service provider you designate.
Right to Object, based on your particular situation, to using your personal data on the basis of legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise of defense of legal claims. You may also object at any time to the use of your personal data for direct marketing purposes.
Right to Restrict processing your personal data (except for storing it) if you contest the accuracy of your personal data, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you opposes the erasure of the personal data and requests instead to restrict its use; if we no longer need the personal data for the purposes outlined in this Policy, but you require them to establish, exercise or defense relating to legal claims, or if you object to processing, pending the verification whether our legitimate grounds for processing override yours.
Right to be Forgotten. Under certain circumstances, such as when the personal data are no longer necessary for the purposes for which they were processed, you have the right to ask us to erase your personal data. However, we may still process your personal data if it is necessary to comply with a legal obligation we are subject to under laws in EU Member States or for the establishment, exercise or defense of legal claims.
If you wish to exercise any of these rights, contact us at firstname.lastname@example.org
We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason for this.
Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.
Notice of financial incentive. If you are a resident of California, you are entitled under the California Consumer Privacy Act (CCPA), to receive this notice about the financial incentive we offer in exchange for your personal information.
An ordinary subscription to the Service requires payment of a periodic subscription fee. During registration to the Service, we may, in our discretion, offer you a free subscription to the Service if you agree to provide us the name of your health insurance provider (the “Financial Incentive”).
If we offer the Financial Incentive, you can opt into it by choosing the free subscription option during registration and providing us the name of your health insurance provider. Opting into the Financial Incentive is completely voluntary, and we will not require you to provide any other personal information in exchange for the free subscription.
You may opt out of the Financial Incentive at any time, by contacting us at email@example.com. Once we process your opt-out request, we will delete from our records the information about who your health insurance provider is, and your free subscription to the Service will end. You can then enroll in one of our paid subscription plans in order to continue to access the Service.
We use the information about who your health insurance provider is to create statistical and aggregated data about the health insurance providers of our users.
Although we do not assign a monetary value to the information we collect from you as part of the Financial Incentive, we reasonably estimate that the value of this information is equal to or greater than the value that we obtain from using that information. Our estimation is based, among other things, on the portion of the revenues we expect to generate which we attribute to this information, and on the expenses we incur in its collection, storage, and use.
Below is a detailed description of the information we collect from you and the commercial purposes for which we use each category of personal information. This is also the information we have collected in the past 12 months.
Your rights under the CCPA
Disclosure of personal information we collect about you.
You have the right to know: the categories of personal information we have collected about you; the categories of sources from which the personal information is collected; our business or commercial purpose for collecting personal information; the categories of third parties with whom we share personal information, if any; the specific pieces of personal information we have collected about you.
Right to deletion.
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
Please note that we may not delete your personal information if it is necessary to:
Protection against discrimination
You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
Right to opt-out of the Financial Incentive
You may opt-out of the Financial Incentive you previously opted into, as explained above under the section titled Financial Incentive.
Exercising your CCPA rights
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you, by using a two or three points of data verification process, depending on the type of information you request.
From time to time, we may change this Policy, in which case we will post an updated version of the Policy. The latest version of the Policy will always be accessible through the Service.
Should you have any inquiries, complaints or suggestions, you may contact us at firstname.lastname@example.org. We will do our best to resolve your issue in a timely manner.