Whiz Technologies Limited (hereinafter "Company"), has procedures founded on a personal data protection policy that is established in accordance with Regulation EU 2016/679 of the European Parliament and of the Council, of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, (hereinafter "Regulation"). In this regard, the Company provides you, in the capacity of User, with the following information:
- DEFINITIONS
The terms "personal data", "data subjects", "International Organisation", "Processing", "personal data breach", "Data Protection Officer", "Data Controller" and "Data Processor" included in this notification correspond to the definitions provided for in Article 4 of the Regulation.
Furthermore, please note that this Privacy and personal data security policy and notification ("Policy") should be read and interpreted together with the Terms and Conditions of Use of the Service. In all matters not otherwise expressly provided for in this notification, the definitions contained in the Terms and Conditions of Use of the Service shall be considered.
In particular, please note the following definitions:
- A) Contract – subscription to the Terms and Conditions of Use of the Service by the User, thus making you a Registered User;
- A) Service – a social network that allows social interaction between its users, specifically through the exchange of instant messages, sharing of content (photographs, videos, texts, audio and other), and that also acts as an aggregator of multiple digital platforms and IT providers, allowing users access to them through a single digital platform;
- B) Platform – the Website or the application (available from the Apple Store or Google Play for smartphones, tablets or any other smart devices compatible with it) which allow access to the Service.
- A) Content – all files, data, information, photographs, videos, texts, audio or other media that the user sends, uploads, forwards, publishes or, by any other means, transmits on the Platform.
- IDENTIFICATION OF THE DATA CONTROLLER:
The data controller is the Company, whose corporate name is Whiz Technologies Limited, an Irish Company, with headquarters at 2ND FLOOR, PALMERSTON HOUSE, FENIAN STREET, DUBLIN 2.
You may contact the Company through [email protected]
- IDENTIFICATION OF THE DATA PROTECTION OFFICER:
The Company has appointed a Data Protection Officer to guarantee the compliance by the Company of the matters provided for in the Regulation and any other related or applicable legislation with regard to the processing of personal data, and also to receive and handle all claims and exercise of rights in this regard that the Company may receive from Users. You can contact the Company's Data Protection Officer through [email protected]
- WHAT DATA DO WE PROCESS?
If you are a guest User, we will only process cookies as authorised by you by accessing our Policy on the Collection and Use of Cookies. In particular, and when you expressly authorise us, we can use data about your location.
If you are a registered User, besides the cookies in the terms described above, regarding your registration, we will necessarily process your name, surname, date of birth and mobile phone number.
You may optionally add additional information about yourself on your profile page. We recommend that you avoid sharing sensitive data on the Platform (e.g. personal data which reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data or data concerning health, data relating to your sexual life or orientation and also data on crimes or convictions with which you have been charged with).
We will also process all the Content that you share with us through the Platform.
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4.1 Basic account data
You must provide your mobile number and basic account data (which may include profile name, profile picture and about information) so we can validate and create your Whiz account.
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4.2 Phone Number and Contacts
Whiz uses phone numbers as unique user identifiers. We ask your permission before syncing your contacts.
We store your up-to-date contacts in our servers in order to sync your friends to your contact list and to notify you as soon as one of your contacts signs up for Whiz.
We only need the number. No other information is stored about your contacts.
You can always stop syncing contacts by removing permission to access your contacts.
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4.3 Posts
We store messages, photos, videos and documents that you share in post.
All information shared to a post is publicly available to other registered users and third parties to whom a post can be shared with.
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4.4 Chats
We store messages, photos, videos and documents that you send or receive in any individual or group chat.
Messages have a retention period of up to 120 days so that we can deliver messages sent from you and to you.
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4.5 Location Data
You may share your location in a post (publicly) or in a private chat.
We ask your permission before uploading your location data to our servers.
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4.6 Cross-Device Functionality
We may also store some aggregated metadata to sync functionalities and settings between all your devices.
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4.1 Basic account data
- FOR WHAT PURPOSES DO WE PROCESS YOUR DATA?
Performance and management of the contract with the Company
By subscribing to the Terms and Conditions of Use of the Service, the User is entering into a contract with the Company as a Registered User of the Platform. The Company therefore processes the Users’ personal data that are strictly necessary for the management of the contractual relationship between the User and the Company, so that the User can access the Platform and the service made available by the Company.
If you do not provide your data necessary for the conclusion and performance of your contract with the Company, it will not be possible to conclude it and, consequently, you will not be able to browse on the Platform as a Registered User or benefit from the advantages associated with such registration.
Compliance with legal obligations
Your data may be processed in order to comply with legal obligations, and also when the Company is notified by a court or administrative entity, for that purpose.
Consent
Based on your consent, the Company may send you communications on events, promotions and campaigns of the Company and/or of its business partners. The Company may, also through your consent, segment the advertising that is addressed to you through the Platform in accordance with your profile, interests and Content that you have published or commented on recently. Please note that you may revoke your consent at any time through the contacts identified above.
Consent may be obtained through the Policy on the Collection and Use of Cookies (in the case of the segmentation of advertising as described above) or through a specific script for the purpose which will be made available to you together with the Terms and Conditions of Use of the Service. Please note that you may revoke your consent at any time and without any need to give a reasoned justification for doing so. For this purpose, please contact our Data Protection Officer through the contacts provided above in the Policy.
Legitimate interest
The Company may also process your personal data based on the legitimate interests of the Company or of third parties.
Essential and functionality cookies, for example, are files which allow the Platform and all associated applications to function properly and, in this regard, are used considering the legitimate interest of the Company in keeping the Platform functioning properly.
Whenever the Company needs to make updates or improvements on the Platform, it may have to access it and, additionally, have access to your personal data, including cookies and registration data on the Platform.
When you are a Registered User, your personal details can also be processed within the scope of market surveys for the total or partial acquisition of the Company or of the Platform by third parties, by way of a capital increase or through the transfer of shareholdings.
- WITH WHOM WILL WE SHARE YOUR DATA?
Within the scope of some of the functionalities of the Service, and namely in redirecting the User to Partners’ services, the Company will have to share your personal data with the Partner.
The Company may also share your personal data with other companies, which will process the data only for the purposes identified above. In particular, the Company may have to share your personal data with partners in the accounting area, software supply and maintenance companies, as well as digital platform management companies, event promotion and management companies, financial consultants, attorneys, among others. The Company will seek, at all times, to ensure that its suppliers adopt the appropriate technical and organisational measures to protect your personal data.
It may also be necessary to share your personal data with potential purchasers or investors in the Company. However, the Company will always guarantee the principle of minimization of the processing of data and will subject any third parties that access your personal data to confidentiality obligations.
- WHERE DO WE PROCESS YOUR DATA?
The Company may transfer personal data outside of the European Economic Area ("EEA"), namely for the purpose of archiving information in the cloud. Where there is no adequacy decision in force in the country where the importer is based or in which the latter provides its service, the Company guarantees that it will adopt the appropriate or adequate mechanisms, namely the signing with the importing supplier of standard contractual clauses as approved, at any given time, by the European Commission.
- IS YOUR PERSONAL DATA SAFE WITH US?
We use a variety of security technologies and procedures in order to avoid losses, undue use, unauthorised access or disclosure of Information. For example, we use encryption technology (like SSL) to protect certain confidential information (like location data) provided by the User to the Company.
Please be aware that, in spite of our efforts, no data security measure can guarantee 100% security at all times.
- HOW LONG CAN YOUR DATA BE STORED?
All personal data will be stored in accordance with the legal requirements in force to guarantee the compliance with legal obligations by the Company or so that the latter can guarantee its rights of defence in any legal proceedings.
Cookies will be stored for the following periods:
- Essential Cookies: up to 12 (twelve) months after collection or until you withdraw your consent, whichever occurs first
- Functionality Cookies: up to 12 (twelve) months after collection or until you withdraw your consent, whichever occurs first
- Session Cookies: erased when the User closes the browser
- Analytical Cookies: up to 12 (twelve) months after collection or until you withdraw your consent, whichever occurs first
- Remarketing Cookies: up to 12 (twelve) months after collection or until you withdraw your consent, whichever occurs first.
In relation to registration data, and without prejudice to what is specifically provided in the applicable legislation, all personal data that the User provides us with, including content, publications and comments to publications, photographs, videos or audio may be kept while the User keeps its Contract active with the Company. However, the Company does not have any obligation to retain this data nor does it assume any obligation to retain them or to back them up. All registrations will be deleted if the User does not access the Platform for a period longer than 12 (twelve) months, except in cases where the Company considers that these are necessary for the exercise of a right or defence in any legal proceedings.
Data relating to content may be kept during the term of the Contract. After its termination, it may be kept for the maximum period of 6 months or until the User requires its erasure, within the law
- RIGHTS OF THE DATA SUBJECT
Right of Access
The User has the right to request information from the Company on the personal data we process about him/her.
Right to rectification
The User has the right to ask the Company to rectify his/her personal details, in case the Company is processing incorrect information, and also the right to complete those data, if and when incomplete.
Right to Data Portability
Whenever the Company processes personal data by automated means or based on his/her consent or on a contract, the User has the right to ask the Company for a copy of those personal data, in a structured, commonly used and machine-readable format, or to request its transfer to another data controller indicated by him/her.
Right to erasure
The User can ask the Company to erase his/her personal data. However, this erasure may not be immediate whenever and wherever the Company wishes to safeguard any right of defence to which it may be entitled. We will always retain evidence of your erasure request.
Right to object
The User has the right to object to the processing of his/her personal details whenever the Company bases the processing on its legitimate interest.
Right to restriction of processing
The User can request the restriction of the processing of their personal data, when he/she contests its accuracy, considers that the processing is illegal (and has not requested its erasure), considers that the data are no longer necessary for the purposes of processing described by the Company in this notification or when he/she has objected to its processing and until a decision is made on the legitimacy or otherwise of their processing by the Company.
How can you exercise your rights?
Please address your request to the Data Protection Officer through the contacts indicated above in this Policy.
You can lodge a complaint with the competent supervisory authority if you consider that the processing of your personal data by the Company infringes the applicable law. The contact details of all the EU supervisory authorities are available at https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.