Updated on 25th May 2018
This Policy explains how we protect and handle any information you provide to us, including via our websites, mobile apps, communications by email and through social media, by telephone and in person. It also covers information we receive from third parties. It also provides you with an overview of the rights you can exercise regarding what we do with your information.
By using our products and services, including browsing our websites, registering or logging in, we may use your information as outlined in this Policy.
1. The Information We Collect and Use
We collect and receive information about users in a few different ways:
A. Non-Personally Identifiable Information. When you use any of the Services, we may collect certain data that does not tell us specifically who you are. This is “Non-Personally Identifiable Information.” Non-Personally Identifiable Information includes things such as but not limited to your browser type and device information, App usage data, information that has been aggregated in a manner that it no longer reveals your specific identity, demographic information, IP addresses, and other information you provide that does not reveal your specific identity, and the last domain you visited before coming to our Service or the domain you go to when you leave. It also includes various statistical data such as which pages you visit by using our Services, how long you stay on them, and what you click.
What is a cookie and how we use it?
When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
We may collect the physical location of your device by, for example, using satellite, cell phone tower or Wi-Fi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
NOTE: Where you use our services, cookies and similar technologies are used for analytics. Such analytics do not personally identify you. It is not presently possible to opt-out of these cookies and similar technologies. If you do not want to be included in our analysis, please do not use our apps.
B. Personally Identifiable Information. We and our services providers also may collect information that can be used to identify you (“Personally Identifiable Information” ). We only collect Personally Identifiable Information when you specifically provide it to us. For example, in connection with your use of the Services, you may be asked to create a user account and provide certain information including your name, email addresses, address, and telephone number. When you create a user account with wroops.com website and sign in to your account using the Services or post user uploaded information, you are not anonymous to us. In addition, we may collect Personally Identifiable Information through our Social Media Pages, including your social media profile picture and account ID; and from other sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties. If you elect to connect your social media account to your Services account, certain Personally Identifiable Information from your social media account will be shared with us, which may include Personally Identifiable Information that is part of your profile or your friends’ profiles.
We may need to collect and process Personally Identifiable Information in order to fulfill your requests, respond to your inquiries and provide other services, to alert you to information, offers, or publications in which we think you may be interested, or because we are legally required to do so. If you do not provide the Personally Identifiable Information that we request, we may not be able to provide you with the requested services. The emails that we send contain links that enable you to “unsubscribe” from such mailings.
We do not sell Personally Identifiable Information or other information you make available via the Services, or share such information with third parties, except as described below.
From time to time, we and our service providers may use Personally Identifiable Information for our legitimate business interests, including the following:
- To respond to your inquiries and fulfill your requests, complete your transactions, and provide you with related customer service.
- To send administrative information to you, such as changes to our terms, conditions and policies, as well as marketing communications that we believe may be of interest.
- To personalize your experience using the Services by presenting products and offers tailored to you, and to facilitate social sharing functionality.
- To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules containing information about how we use and disclose your Personally Identifiable Information.
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying the Services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.
Your Personally Identifiable Information and Non-Personally Identifiable Information may be disclosed as follows:
- By you, on message boards, chat, profile pages and blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages).
- To unaffiliated companies or individuals for market research, product development or similar purposes. These companies or individuals may be provided with access to Personally Identifiable Information Non-Personally Identifiable Information, but we will require by contract that they agree to maintain the confidentiality, security and integrity of such information.
- To third-party sponsors of sweepstakes, contests and similar promotions.
- To third parties in connection with a corporate transaction where all or a portion of our business (e.g., a portion that includes our customer lists) is sold or transferred. We also may disclose your Personally Identifiable Information if disclosure is required by law, which may include laws outside your country of residence, or as part of a lawsuit or government investigation or proceeding, or in order to permit us to exercise or preserve our legal rights or take action regarding potentially illegal activities or to protect the safety of any person.
In addition to the uses otherwise set forth herein, we may use and disclose your Non-Personally Identifiable Information for any purpose, except where we are required to do otherwise under applicable law.
LEGAL BASIS FOR PROCESSING INFORMATION:
The legal basis for these processing activities include consent, contractual necessity, and our legitimate interests or those of others, as further described below:
Contractual Necessity: We process the following categories of Personal Data because we need to process the data to perform under our User Agreement with you, which enables us to provide you with the Service. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Service that require such data as contact information, user account information, financial account information, transaction information and user content.
Legitimate Interest: We process data such as contact, financial, user account and transaction information, user content, partner information, when we believe that it furthers our or third parties legitimate interests. It could be for operations, improvement of user experience, improvement of our services or compliance with legal obligations.
Consent: As identified above, in some cases we may process personal data based on the consent you expressly grant to us at the time of sharing this information. When we process personal data based on your consent, it will be expressly indicated to you at the point and time of collection.
Other possible processing grounds: From time to time, we may also need to process personal data to comply with a legal obligation, or if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in public interest.
2. Third Party Services
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Google, Facebook or any other app developer, social media platform provider, operating system provider, wireless services provider, or device manufacturer, including with respect to any Personally Identifiable Information you disclose to other organizations through or in connection with the Services.
Following is the current list of third-party tracking services that we use currently along with their respective privacy policies and opt-out mechanisms, if you wish to do so. Please note we reserve the right to change this list at any time.
3. Internet Advertising
- Google – https://policies.google.com/technologies/ads
- Facebook – https://developers.facebook.com/docs/audience-network/policy
- Moneytizemore – https://www.monetizemore.com/privacy-policy/
Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of device identifiers. If you choose to reject cookies or block device identifiers, some features of the Services may not be available or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings. We do not currently respond to browser do-not-track signals.
4. Data Security
We seek to use reasonable organizational, technical and administrative measures to protect Personally Identifiable Information within our organization. No data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with Section 6 below.
5. Your Data Subject Rights
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personally Identifiable Information provided until after the completion of such purchase or promotion). There may also be residual information that will remain within our databases and other records, which will not be removed.
Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we violated any of the rights concerning your Personally Identifiable Information. We encourage you to first reach out to us at [email protected] so we have an opportunity to address your concerns directly before you do so.
6. Children & young people
Our websites, apps and other products and services are not aimed at children. We do not target, intend to collect, or knowingly collect or otherwise process information from anyone under the age of 13.
If you are under the age of 13, we request that you do not provide us with your information and do not use our websites and apps.
If you are a parent or guardian of a child under 13, please contact us if you are aware that your child has used our websites or apps or otherwise provided their information to us without your consent. We will delete or otherwise cease processing your child’s personal information within a reasonable time.
If you are aged 13, 14 or 15, we request that you seek your parent or guardian’s permission before providing us with your information or using our websites or apps.
In accordance with industry best practice guidelines, we may retain your information for a reasonable amount of time to make sure that we do not contact you in the future.
7. Updates to this Policy
We reserve the right to make changes to this Policy. Where changes are made, we will post the revised Policy here with an updated effective date. Please check regularly for any changes to this Policy.
8. Details of transfers to third countries and safeguards
Any organisation who has access to your information in the course of providing services on our behalf will be governed by contractual restrictions to make sure they protect your information and comply with applicable data protection legislation.
Where these organisations are based outside of the EEA in a jurisdiction that has not been deemed adequate by the EU, we enter into EU approved model clauses with them to ensure appropriate safeguards are in place.
9. User rights under GDPR
Under the General Data Protection Regulation, you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal data and to certain other supplementary information that this Policy is already designed to address
- require Us to correct any mistakes in your information which We hold
- require the erasure of personal data concerning you in certain situations
- receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal data concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal data
- otherwise restrict our processing of your personal data in certain circumstances
- claim compensation for damages caused by our breach of any data protection laws.
If you would like to exercise any of those rights, please:
- contact us using our Contact details below
- let us have enough information to identify you,
- let Us have proof of your identity and address. Where you are a user of our Services you should email us from the email address that you used to register with us. Receipt of an email from this address will usually be sufficient to confirm your identity.
10. Contact Us