Last Revised: May 25, 2018
The Policy is designed to tell you how we collect and use personal information (as defined below) so you can make an informed decision about using our Site and the Wayo service. Please read this statement before submitting any personal information to us. By using our Site and service, you represent that you:
– are 14 years old or older,
– you are using our app for lawful purposes,
– and you consent to the information collection, use and retention practices described
in this Policy.
Our services are not intended for-and we don’t direct them to-anyone under 13. And that’s why we do not knowingly collect personal information from anyone under 13.
Transfers outside the European Union
We would like to draw your attention to the fact that if your friends are outside the European Union, your information-including your location-will be available to them. Similar to our transfer of your data to third parties as described in How we share information, your data may be transferred and be accessible to third parties and users outside of the European Union, including to countries that may not have the same level of protection of your information as those within the European Union. Whenever we share your information outside the European Union with third parties we make sure adequate mechanisms are in place to protect your data, such as the Standard Contractual Clauses and the EU-US Privacy Shield. We have included more details in the table below.
|Purpose||Type of data||Country||Recipient||Transfer Mechanism|
|Data analytics||App usage data and user data||U.S.||Data analytics providers||Standard Contractual Clauses|
|Data storage||All user data||U.S.||Cloud storage provider||Standard Contractual Clauses|
|Internal communication||Chats, texts and images||U.S.||Chat provider||Privacy Shield|
|Support||Messages from users||U.S.||Support provider||Privacy Shield|
We have disclosed our data sharing practices to the CNIL and are always happy to answer any questions you may have about data sharing to countries outside the European Union. If you do have any questions simply let us know at firstname.lastname@example.org
TERMS AND CONDITIONS OF USE
Please refer to our TERMS AND CONDITIONS OF USE for information on how the company collects, uses and discloses personally identifiable information from its users.
EU-U.S. Privacy Shield
Wayo Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework (the “Framework”). Wayo is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the this Framework, to the Privacy Shield Framework’s applicable Principles. To learn more about the Framework, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list Under the Framework, Wayo is responsible for the processing of personal data it receives and subsequently transfers to a third party acting as an agent on its behalf. Wayo complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Wayo is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. Wayo may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
U.S. – Swiss Safe Harbor Framework
Wayo complies with the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from Switzerland. Wayo has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Wayo’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.
What is personal information?
As used herein, the term “personal information” means information that identifies an individual, or from which an individual could be identified (such as a name, address, telephone number, mobile number, e-mail address, credit card number or other account number), and information about that individual’s location or activities, such as information about his or her use of the Wayo service, when linked to personally identifiable information. Personal information also includes demographic information such as date of birth, gender, geographic area and preferences when such information is linked to other personal information that identifies you. Personal information does not include “aggregate” information, which is data we collect about the use of the Site or service or categories of Site and service users, from which any personal information has been removed. For example, information that forty-seven percent of the Site’s registered users identify themselves as male, is aggregate information. We collect aggregate data for a number of purposes, including to help us understand trends and user needs so that we can better consider new publications, products and services, and tailor existing publications, products and services to user desires. This Policy in no way limits or restricts our collection of aggregate information.
What personal information do we collect?
Personal information may be collected in a number of ways when you use the various services and activities available through the Wayo Site and service. At several places on our Site or within our mobile application, we may collect certain information you voluntarily provide to us which may contain personal information. When you use our app, you have the option to provide us with a username and profile picture, which will be sent along with any “Wayo” you send. If you register for the mobile application or service, send us an email, or submit content, we may collect your name, photo, demographic information that you provide. In addition, from time to time we may collect contact or other personal or demographic information you provide in connection with your participation in surveys or promotional offers.
We will never post to any social network or contact anyone on your behalf without your permission. We may provide the option of connecting to the Wayo service through Facebook, Twitter, Google+ or other social network as a faster, easier way for you to create a profile on the Wayo service.
When turned on and with an active Wayo, the Wayo app will automatically collect location information from your mobile device and/or your mobile carrier. When you use the service, via your mobile device, some information is also automatically collected, such as your Internet Protocol (IP) address, your operating system, the browser type, the address of a referring web site, and your activity on the application and through the service
We treat the information collected in conjunction with the app as personal information if we combine it with or link it to any of the identifying information mentioned above. Unless you direct us to act otherwise, your personal location information is only stored by Wayo for up to 48 hours after which location information is disassociated from personal information and anonymized. From this point onwards, it is used in the aggregate only. If you no longer wish to allow us to collect and use your location information, you may discontinue the use of the service.
As true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you.
We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and from where the application was downloaded. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.
We may send you push notifications from time-to-time in order to update you about any updates, events or promotions that we may be running. If you do not wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
Usage and Disclosure
In general, we use personal information we may collect (such as your name, location or social network information) to facilitate your use of the mobile application and Wayo service, to provide you with information, products and services you request, to administer and assist us with the operation of the Site, our app, and for any other purpose for which the information was provided. For example, we may use the information we collect:
– to respond to your emails, submissions, comments, requests or complaints;
– to ensure that the application is working correctly and that you are being served the most recent version;
– to allow other users of the service that you designate to temporarily view your whereabouts in real-time;
– to request feedback and to enable us to develop, customize and improve the Site and our information and services; and
– for the specific purpose for which the information was provided.
In addition, if you so indicate in the event of sharing your contact information with us, we may use the information we collect to send you news and product and service updates, including contacting you about our services, products, activities, special events or offers and for other marketing, informational, product development and promotional purposes, including notifications about new features and or improvements to the Site or our products and services;
We may also receive information from third parties with whom we have business relationships, and may combine this information with the other personal information we have about you. In such cases, this Policy governs our use and disclosure of such information.
What personal information do we share with third parties?
You should only share your location with people you know and trust not to convey your location to others. You should also note that personal information you share with others may be forwarded, and any information you post to public areas of the Site or in connection with third party sites (including social media sites such as Facebook) may become publicly available. For example, information you display online or post to social media groups (including any interactive or public forums offered within the Site) may be made publicly available and can potentially be viewed by anyone. Your posting to such public areas of the Site constitutes your consent to share such information publicly.
Where is your information stored?
Wayo Inc. is based in the United States of America, and any information which we collect about you or which you provide to us may therefore be transferred to the United States. Some of our Service Providers may also be located in the United States or in other countries. If you are using the Site and the app in the European Economic Area (EEA), you consent to your personal information being transferred outside the EEA, including to countries where you may have fewer legal rights. However, we will take steps to ensure that your personal information is treated securely and in accordance with this Policy, wherever it is handled.
What steps do we take to protect your information online?
Wayo endeavors to secure your personal information from unauthorized access, use or disclosure by putting into place measures to safeguard the information we collect. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable, and that we cannot guarantee that the Site or services will be free of any defects or flaws that affect your use of it or the security of your information.
When you enter sensitive information or we automatically collect sensitive information on our forms, we encrypt the transmission of that information using secure socket layer technology (SSL).
What choices do you have regarding the retention and use of your information?
When you use the application to send an invitation to a third party to view your location, the invitation remains in your user history as a “sent” request. Such invitation will remain in your user history regardless of whether it is accepted or rejected by the invitee. You may delete your user history, and each sent invitation, at your discretion within the “user history” section of the app.
If you use the features within the app that allow you to designate a particular individual as a “favorite,” the app will associate the designation with the selected individual(s) within the app. It is not necessary to use the “favorites” feature to use the app. You may change your designated “favorites” or otherwise delete a “favorite” within the app at your discretion.
If you provide us with your contact details as part of your use of the Site or the app, we may send you news and product updates relating to Wayo. You may “opt out” of receiving marketing or promotional email from Wayo by following unsubscribe instructions or using unsubscribe links within communications we send. Please note, however, that as long as you receive the Wayo service, you may not “opt out” of receiving service-related emails from Wayo.
Unless you have requested us to do otherwise, we do not keep your personal Wayo location data for longer than 48 hours after which we anonymize it for future aggregate use. If you wish to discontinue use of the Wayo service and would like to have your account permanently deleted, you may send us an email at deletemyaccount@Wayo.com. Once your account is deleted, you will no longer have access to your Wayo history, preferences or any other information associated with your use of the Wayo service.
How can you correct and update your personal information or obtain additional information?
Upon request, we will provide you with information about whether we hold any of your personal information. If you have any questions or comments about this Policy or the practices relating to this Site or our service, please contact us at email@example.com. If you wish to verify, correct or delete any of your personal information that may be collected by Wayo, please e-mail your request to firstname.lastname@example.org. All requests sent to email@example.com will be processed within a reasonable timeframe.
If you created a user account with Wayo for your mobile device and you wish to delete it, you can click the “delete my account” button within the application or email us at firstname.lastname@example.org.
Any information supplied by you in connection with a Wayo user account will be retained as long as your account is active or as needed to provide you services. If you wish to cancel your account, change information within your account or request that we no longer use your information to provide you services, contact us at email@example.com. We will respond accordingly within a reasonable timeframe.
We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Facebook Connect or other OpenID provider
You can log in to our mobile application using sign-in services such as Facebook Connect or an OpenID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities and locations on this Web site to your profile page to share with others within your network.
Social Media Features
Changes in this Privacy Statement
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