EEA PRIVACY NOTICE
Wandergier offers its services in several different countries that each have their own privacy laws. This European Economic Area Privacy Notice (“Notice”) applies to our collection, use, sharing and other processing of personal data received from residents of the European Economic Area (“EEA”) and European Union (EU). EEA users must accept and agree to this Notice to access the Wandergier website and related services that we provide to you (“Wandergier services”).
Please read this entire Notice carefully. This Notice contains links that you can click on to get further information or exercise the options you have about your data. To make this Notice more reader-friendly, we use everyday words such as use, transfer and storage to describe what we do with your personal data – but this Notice covers processing of any kind that is subject to EEA data protection law.
Some of the key topics you may be interested in includes:
- Information You Share With Us
- Additional Information We Receive About You
- How We Use, Share, and Disclose Your Information
- Your Data Subject Rights
- Children’s Information
- How We Secure Your Information
- How Long We Keep Your Information
- Cross-border Transfers of Information
- This Notice May Change
1. Information You Share With Us
You don’t have to create an account to use some of our services, such as searching and viewing public Wandergier profiles, reading stories or watching videos. If you do choose to create an account, we collect personal data that you provide when you register for the Wandergier services and when you complete your user profile, so that we can provide the services to you. This information includes your name, age, location, gender, email address, and password. As noted in our Terms of Service, Wandergier currently makes all profiles of Members aged 18 and older public by default, and unless you change your profile to “restricted” all of your profile activity will be visible other users, including your connections, portfolio, posts, photos, and mixes you create. Any content you contribute to another Member’s public profile or content another Member provides that mentions you will also be public for as long as it remains on Wandergier.
You are responsible for the information you provide through our services, and you should think carefully about what you make public, especially if it is sensitive information (such as information revealing your race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or sexual orientation) because the special protections that your country’s laws may provide to this sensitive personal information will not apply if it is made public by you. If you post any sensitive information to the Site, you expressly consent to Wandergier’s processing of that information consistent with the terms of this Notice.
Contact Information and Account Linking
We use your contact information, such as your email address, to authenticate your account, to keep our services secure, and to help prevent fraud, abuse, and spam. We also use your contact information to personalize our services, enable certain account features (for example, for login verification/password recovery), and to send you information about our services, and to help others find your account if your settings permit, including through Facebook and Twitter. You can use your settings for email and notifications to control notifications you receive from Wandergier.
You can choose to upload and sync your address book from Facebook or Twitter so that we can help you find and connect with people you know and help others find and connect with you. We also use this information to better recommend content to you and others.
You can sign up for Wandergier with an account from Twitter or Facebook, or connect your Wandergier account to these other services. If you do, we will use information from that service, including your email address, friends, likes, and contacts list, to recommend other accounts or content to you or to recommend your account or content to others.
If you click on an external link or ad on our services, that advertiser or website operator might figure out that you came from Wandergier, along with other information associated with the ad you clicked such as characteristics of the audience it was intended to reach. They may also collect other personal data from you, such as cookie identifiers or your IP address.
If you email us, we will keep the content of your message, your email address, and your contact information to respond to your request.
2. Additional Information We Receive About You
Automatically Collected Information
We also collect data via automatic means (described below in “Cookies and other Web Technologies”) when you use the Wandergier services or click on links to third party websites from the websites that are part of the Wandergier services. Some of this information relates to the devices that you use to access the Wandergier services, such as a computer, mobile phone, tablet, smart TV or other electronic device. (We use the term “Device” in this Notice to refer to any of these.) The information we collect automatically includes:
- Technical information, including your Device location (including using GPS and longitude and latitude location information) and certain other Device usage data such as the time of day, the Internet protocol (IP) address used to connect your Device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, hardware (e.g., make and model of phone), and mobile network;
- Information about your visit to the Wandergier site and use of the Wandergier services, including where you came from and where you go on the Web, including date and time;
- Page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
- Ranking information about you with respect to other Users or content pages that you interact with (e.g., Wandergier records the links to content pages that you post and rank your association with that content compared to other Users).
Cookies and other Web Technologies
We also use web technologies to collect information to let us understand which Devices all belong to you, so we can offer a seamless cross-Device experience. For example, we gather information about your use of Wandergier on your mobile phone, tablet and laptop and associate all of those Devices for you so it doesn’t matter which device you use to access our services – the information and media that you see will all be up-to-date and you can pick up wherever you left off.
New technologies that perform similar functions may be developed. If we adopt new technologies that are not already described in this Notice, we will update it to let you know.
We receive information when you view content on or otherwise interact with our services, which we refer to as “Log Data.” For example, when you visit our website, sign into our services, sign into Facebook through your account, or interact with our email notifications, we may receive information about you. Log Data includes information such as your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information. We use Log Data to operate our services, personalize your content, and optimize the performance of our services.
3. How We Use, Share, and Disclose Your Information
As noted above, Wandergier is predominantly a public community. In the limited circumstances where we disclose your personal data, we do so subject to your control, because it’s necessary to operate our services or our business, or because it’s required by law.
Sharing Your Control
We share your personal information with third parties with your consent or at your direction, such as where you authorize third party services like Facebook or Twitter to access your profile or where you voluntarily disclose sensitive personal information as part of your Wandergier profile. We also share your basic profile information with our third party partners so that they can send you email promotions and offers, if you have agreed to receive such offers. You can opt out of receiving promotional emails from our advertising partners, or from receiving email notifications from us about your profile activity. You may not opt out of receiving email notifications from us regarding your account or updates to this Notice or our Terms of Service. As noted above, if you post any sensitive information on Wandergier you consent to our processing of that information.
We share your data with our service providers, including our contractors and business partners, who we engage to help us provide and manage the services, ensure network and information security, and analyze your use of our services. Our service providers are located in the United States and other countries and we share your personal information with them subject to obligations consistent with this Notice and any other appropriate confidentiality and security measures, and on the condition that these third parties use your personal information only on our behalf and pursuant to our instructions. We share your information with our service providers to further our legitimate business interests of providing stable and reliable services to you, and only do so after considering the potential impact to your individual rights.
To Protect our Legal Interests
Additionally, we may preserve, use or disclose your personal information if we believe that it is reasonably necessary to comply with a law, regulation, legal process or governmental request. We may also preserve, use, or disclose your personal information if we have, in our discretion, a good faith belief that such use and/or disclosure is necessary in order to: (i) protect or defend our or your legal rights or property or those of our affiliates, employees, agents and contractors (including enforcement of our agreements); (ii) protect the safety and security of members of the public, including responding to emergencies where there appears to be a danger of death or injury to any person; (iii) to protect the integrity and security of our platform, including to help prevent spam, abuse, fraud, or malicious actors on our services.
Affiliates and Change of Ownership
We may share your data within our affiliates, if any, for uses consistent with this EEA Privacy Notice, such as to help operate the Wandergier services.
If we are involved in a business transaction that results in a change of who owns our company or our assets (for example, a bankruptcy, merger, stock sale, acquisition, reorganization, sale of the services, or sale of assets), your personal information may be disclosed, transferred, or sold as part of such transaction.
We may disclose your data in the event we file for bankruptcy, or in connection with certain types of business transactions that result in a change in who owns our company or our assets. We share your personal information with our affiliates and may share it connection with any future corporate transaction to further our legitimate business interests of operating our business, and only do so after considering the potential impact to your individual rights.
We may share, use, and disclose any personal information you share in connection with your public Wandergier profile. You can adjust your privacy settings to control whether your Wandergier profile information is public (everyone can see your Wandergier profile) or restricted (you will receive connection requests that you must approve in order for other profiles to connect to you, however, some of your information, like your profile image, name, gender, location, and cover image is viewable by anyone).
We share your non-personal information, such as aggregated information (a statistical or summary form that does not include any personal identifiers) with third parties in order to identify trending topics or report to our advertising partners about how many people saw or clicked on an ad. While we do not target EEA residents with advertisements based on your interests or behaviors. However, Wandergier is a free service that is supported by advertising revenues, so you will still see ads. They just will not be tailored to your interests.
4. Your Data Subject Rights
You control the personal data you share with us. You can object to our processing of your data, request that our processing be restricted, review or request changes to your personal data, or request that your account be deleted and we erase your data by contacting us at firstname.lastname@example.org. As noted above, you may opt out of receiving direct marketing emails from our partners.
You may also complain to a data protection authority about our collection and use of your information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Union are available at ec.europa.eu.
You may exercise any of these rights free of charge. However, we may charge a reasonable fee or refuse to act on a request if the request is manifestly unfounded or excessive, in particular because of its repetitive character.
Your privacy is important to us, so we will ask that you provide sufficient information to verify your identity before we respond to your requests. In some situations, we may refuse to act or impose limitations on your right if, for instance, it is likely to adversely affect the rights and freedoms of others, prejudice the execution or enforcement of the law, or interfere with pending or future litigation.
For more information on your rights, please contact email@example.com.
5. Children’s Information
We are very sensitive to the importance of children’s privacy. Our websites, products, and services are neither developed for, nor directed at, children. We do not knowingly employ or offer services to or collect information from children under the age of 16, and as a result of recent changes in European Data Protection Law will no longer be offering Memberships to EEA residents under 16 years of age. If you believe your child has provided us with personally identifiable information, or registered at our Site, please contact us at firstname.lastname@example.org to have the data provided by and associated with your child deleted.
6. How We Secure Your Information
Wandergier uses a variety of technical and organizational measures to protect information from unauthorized access, use or disclosure, both during transmission and once we receive it. We store your information on secure servers and encrypt it while in transit. However, no digital transmission or form of electronic storage is completely secure. Therefore, we cannot guarantee its absolute security.
7. How Long We Keep Your Information
We use and disclose your media content consumption information for up to two (2) years from the date on which you consent unless you otherwise withdraw your consent. If we obtain a new consent from you after the date that we obtain your original consent, this period will be extended for additional two (2) year periods each time we obtain a new consent from you. If your account is inactive for over two (2) years, we still store your media content consumption information for a reasonable period of time so that it will be available again if you reactivate your account. Data for inactive accounts is stored for a maximum of five (5) years from the date of last activity, but we are not obligated to store such data for the entire five year period. Log data is stored for 90 days.
8. Cross-Border Transfers of Personal Information
Wandergier is a global service headquartered in the United States and where the laws of your country allow us to do so, you authorize us to transfer, disclose, store and use your personal data in the United States and any other country where we operate or engage service providers to assist us with the service consistent with this Notice. Please be aware that the laws of the USA and other countries outside of the EEA may not protect your data to the same level as the laws of the EEA, or give you the same rights that you would have in the EEA (including right relating to access to personal data by law enforcement or national security/intelligence agencies). But when we transfer your personal data outside of the EEA, if the receiving country’s data protection laws do not offer the same level of protection as the laws of the EEA, we place contractual obligations (the EU Model Clauses) on the recipients of your personal data to ensure that your personal data is adequately protected.
9. This Notice May Change
We may revise this Notice from time to time. If we make a change that is in our sole discretion material, we will notify you by sending you an e-mail or via a banner, pop-up box or another easy-to-spot notice when you log into your Wandergier account or visit the Wandergier home page. By continuing to access the services after those changes become effective, you agree to be bound by the revised Privacy Notice.
Data Controller: Wandergier, Inc., a Delaware limited liability company with a business address at PO Box 34949, 10421 Motor City Drive, Bethesda, MD 20817.
EU Representative for purposes of this Notice: email@example.com