Effective Date: November 5th, 2020
This Policy applies to all Wanelo's operating divisions, subsidiaries, affiliates, and branches and any additional subsidiary, affiliate, or branch of Wanelo that we may subsequently form.
3. Transparency/Notice — Types of Personal Information We Collect and How We Use It
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Wanelo and the requirements of applicable law. Some of the ways that Wanelo may collect Personal Information include:
- You may provide Personal Information directly to Wanelo through interacting with the Services, participating in surveys, during events such as sweepstakes, and requesting Services, or information.
- As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
3.1. Types of Personal Information We Collect
Wanelo collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, guests, and Employees (collectively "Individuals").
Information You Provide to Us
When you use the Services or engage in certain activities, such as registering for an account with Wanelo, purchasing or selling items, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
Creating an Account with Us. Our Services may give you the ability to register for an account or to create and update a user profile on the applicable Service. If you create an account with us, we will collect Personal Information including, for example, email address, phone number and user name. We may indicate that some Personal Information is required for you to register for the account or to create the profile, while some is optional.
Selling or Purchasing Items Through Us. If you sell or purchase items through Wanelo, we may collect Personal Information from you to facilitate your order, such as your name, shipping and billing address, items sold, purchased or returned, and payment information. We may also ask for additional identification, such as your driver’s license, to prevent fraudulent purchases.
Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, register for Wanelo's newsletter or a loyalty program that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.
Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/or Services and in any manner consistent with the policies provided herein.
Posting on the Site. Wanelo may offer publicly accessible comments, features, blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself on Wanelo's comments, features, blogs, private messages, and community forums, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered "public" and will not be subject to the privacy protections set forth herein.
Registration for Sweepstakes or Contests. Occasionally, Wanelo may run sweepstakes and contests. We ask those who enter in the sweepstakes or contests to provide contact information (e.g., an e-mail address). If you participate in a sweepstakes or contest, your contact information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing and business purposes. Some jurisdictions require the Personal Information of contest winners to be posted publicly. All sweepstakes/contests entry forms will provide a way for participants to opt out of any communications that are not related to awarding prizes.
Information Collected from Merchants. Wanelo "the App" provides an ecommerce plugin to merchants who use Shopify to power their stores. When you install or use the App in connection with your Shopify-supported store, we may access certain types of information from your Shopify account such as full name, address, store domain, date of birth, phone number, last four digits of your bank account, last four digits of your Social Security number, timezone, and email address. Additionally, we may collect the following types of Personal Information from you and/or your customers once you have installed the App: name; username; email address; age and/or birthday; gender; IP address; location; language; browser information; browsing history; device ID; carrier; device type; transactions; transaction-related data like zip code; billing address and shipping address; listings created; comments and reviews posted; photos posted; push notification credentials; credentials users provide us to communicate to them or link their Wanelo accounts with third-party services such as Facebook and Twitter; and any other information necessary for us to provide our Services.
Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
Information Submitted Via Services You agree that Wanelo is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Wanelo will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
Information from Other Sources We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you access our Services through a Third-Party application, such as an App Store or SNS, we may collect information about you from that Third-Party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS user name, location, sex, birth date, email, profile picture, and your contacts on the SNS. This supplemental information allows us to verify information that you have provided to Wanelo and to enhance our ability to provide you with information about our business, products, and Services.
Additionally, if you sign into the Services through a Third-Party service such as an SNS, your list of "friends" from that service may be automatically imported to Wanelo, and such "friends," will appear in your profile if they are also registered users of the Website.
3.2 How Wanelo Uses Your Information
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
To Provide Products, Services, or Information Requested. Wanelo may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
- Generally manage Individual information and accounts;
- Respond to questions, comments, and other requests;
- Provide access to certain areas, functionalities, and features of Wanelo's Services;
- Contact you to answer requests for customer support or technical support;
- Undertake activities to verify or maintain the quality or safety of a service or device;
- Allow you to register for events.
For Administrative Purposes. Wanelo may use Personal Information about you for its administrative purposes, including to:
- Measure interest in Wanelo's Services and short-term, transient use, such as contextual customization of ads;
- Detect security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- Undertake research for technological development and demonstration;
- Develop new products and Services;
- Improve, upgrade or enhance our Services or device;
- Ensure internal quality control;
- Verify Individual identity;
- Debug to identify and repair errors that impair existing intended functionality;
- Communicate about Individual accounts and activities on Wanelo's Services and systems, and, in Wanelo's discretion, changes to any Wanelo policy;
- Send email to the email address or SMS to the telephone number you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, system maintenance, or other information regarding the Services;
- Provide automated updates on shipments and deliveries;
- Process payment for products or Services purchased;
- Process applications and transactions;
- Prevent potentially prohibited or illegal activities;
- Enforce our Terms.
To Provide You with Additional Products and Services. Wanelo may use Personal Information to provide you with marketing materials about offers, products, and Services that may be of interest, including new content or Services. Wanelo may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
- To tailor content, advertisements, and offers;
- To notify you about offers, products, and Services that may be of interest to you;
- To provide Services to you and our sponsors;
- For other purposes disclosed at the time that Individuals provide Personal Information; or
- For auditing relating to interactions, transactions and other compliance activities;
- Otherwise with your consent.
You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described in Section 6 below.
Research and Development. Wanelo may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Wanelo may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Wanelo's or our business partners' products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 6 below.
Anonymous and Aggregated Information Use. Wanelo may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Wanelo's Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors' interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Wanelo may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Wanelo and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
Sharing Content with Friends or Colleagues. Wanelo allows you to provide information about your friends through our referral and/or comment Services, such as "mention" where you may tag a friend to inform them of a product. Our Services may allow you to forward or share certain content with a friend or colleague. Personal Information that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Wanelo or any other Third Parties for any other purpose.
Other Uses. Wanelo may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
Cookies. Cookies are small text files placed in visitors' computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users' engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
Analytics. We may use analytics services, including Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. For more information about Google Analytics, please visit https://www.google.com/policies/privacy/partners and http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our Sites or on Third-Party Sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt out of the Technologies we employ on our Sites, Services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
3.4. Third-Party Websites, Social Media Platforms, and Software Development Kits
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Wanelo does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
Wanelo's Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by Third Parties for any number of purposes.
We use Third-Party software development kits ("SDKs"), such as the adjust Inc. SDK, as part of the functionality of our Services. Third-Party SDKs may allow Third Parties including advertisers to collect your personal information to provide content that is more relevant to you. You may opt out of tracking by following the instructions below.
3.5. Third-Party Payment Processing
When you make purchases through the Services, we process your payments through a Third-Party application, including the Apple Pay. The Third-Party application may collect certain financial information from you to process a payment on behalf of Wanelo, including your name, email address, address and other billing information.
4. Human Resources Data
Wanelo collects Personal Information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy ("Human Resources Data"). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver's license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.
We acquire, hold, use and Process Human Resources Data for a variety of business purposes including:
- Workflow management, including assigning, managing and administering projects;
- Human Resources administration and communication;
- Payroll and the provision of benefits;
- Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;
- Job grading activities;
- Performance and employee development management;
- Organizational development and succession planning;
- Benefits and personnel administration;
- Absence management;
- Helpdesk and IT support services;
- Regulatory compliance;
- Internal and/or external or governmental compliance investigations;
- Internal or external audits;
- Litigation evaluation, prosecution, and defense;
- Diversity and inclusion initiatives;
- Restructuring and relocation;
- Emergency contacts and services;
- Employee safety;
- Compliance with statutory requirements;
- Processing of Employee expenses and travel charges; and
- Acquisitions, divestitures, and integrations.
5. Onward Transfer — Wanelo May Disclose Your Information
5.1 Information We Share
We share your Personal Information only as described below (e.g., with our Third-Party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission. For a list of the categories of personal information we have disclosed about consumers for a business purpose in the past 12 months, please email firstname.lastname@example.org.
We have not sold consumers' personal information in the preceding 12 months.
We Use Vendors and Service Providers We employ service providers to perform tasks on our behalf and need to share your information with them so we can provide products or Services to you. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. Wanelo has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
Business Partners Wanelo may share Personal Information with our business partners and affiliates for our and our affiliates' internal business purposes or to provide you with a product or service that you have requested, such as to fulfill a transaction by an affiliate on Wanelo's Services. You can recognize when an affiliated business is associated with a Wanelo transaction or Service by the store's information published on store pages, product pages and details on order confirmation materials. Wanelo may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner's name will appear, along with Wanelo. Wanelo requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Wanelo provided them.
Displaying to Other Users The content you post to the Site, including reviews and your user profile information may be displayed on the Site. Other users of the Site may be able to see some information about you, such as your name if you submit a review. User profile information, including without limitation your name, email address, and other information may be displayed to other users if you chose to enter such information on your user profile. Your user profile is public on the Services. Any content (including without limitation images, captions, and comments) you post on the Services is not protected by Wanelo; it becomes publicly available and can be collected and used by others and may be redistributed through the internet and other media channels. We are not responsible for other users who may view and use the posted information.
Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures) We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others' rights, property, or safety; (iv) enforce Wanelo policies or contracts; (v) collect amounts owed to Wanelo; (vi) prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) disclose information for necessary or advisable reasons.
In addition, from time to time, server logs or other information may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
5.2. INTERNATIONAL Data Transfers
You agree that all Personal Information collected via or by Wanelo may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Wanelo, you explicitly consent to the storage of your Personal Information in these locations.
6. Opt-Out (RIGHT TO OBJECT TO PROCESSING)
You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to Wanelo's Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting email@example.com.
6.2. Email and Telephone Communications
6.3. Mobile devices
Wanelo may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. Wanelo may also collect location-based information if you use our mobile applications. You may opt out of this collection by changing the settings on your mobile device.
6.4. Human Resources Data
With regard to Personal Information that Wanelo receives in connection with the employment relationship, Wanelo will use such Personal Information only for employment-related purposes as more fully described above. If Wanelo intends to use this Personal Information for any other purpose, Wanelo will notify the Individual and provide an opportunity to opt out of such uses.
6.5. "Do Not Track"
Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
6.5. Cookies and Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings. See http://www.networkadvertising.org/mobile-choice.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at http://www.networkadvertising.org/managing/opt_out.asp, http://youradchoices.ca/choices, http://www.youronlinechoices.eu, http://www.aboutads.info/choices, and https://tools.google.com/dlpage/gaoptout.
7. Rights of Access, Rectification, Erasure, and Restriction
In accordance with applicable law, you may have the right to:
Access to/Portability of Personal Data about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic Personal Data transferred to another party.
Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information or we may refer you to the controller of your personal information who is able to make the correction.
Request Deletion of your personal information, subject to certain exceptions prescribed by law.
Request restriction of or object to processing of your personal information, including the right to opt in or opt out of the sale of your Personal Data to third parties, if applicable, where such requests are permitted by law.
Although Wanelo makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Wanelo is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others' privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual's privacy in the case in question or where it is commercially proprietary. If Wanelo determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Wanelo will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
8. Data Retention
9. Security of Your Information
10. International Users
11. Children's Privacy
The Services are not directed to children under 18, and we do not knowingly collect information directly from children. If you are a parent or guardian and wish to review information collected from your child, or have that information modified or deleted, you may contact us at firstname.lastname@example.org.
If we become aware that a child has provided us with personal information, we will promptly take steps to delete such information, unless we have a legal obligation to retain it, and terminate the child’s account.
12. Redress/Compliance and Accountability
13. Other Rights and Important Information
New Uses of Personal Information Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Wanelo will endeavor to comply with the law or contract.
13.2. California Privacy Rights
The following capitalized terms shall have the meanings herein as set forth below.
"Agent" means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Wanelo or to which Wanelo discloses Personal Information for use on its behalf.
"Employee" refers to any current, temporary, permanent, prospective or former employee, director, contractor, worker, or retiree of Wanelo or its subsidiaries worldwide.
"Personal Information" is any information relating to an identified or identifiable natural person ("Individual").
"Process" or "Processing" means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
"Sensitive Data" or "Sensitive Personal Information" is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a "Special Category of Personal Data" under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual's sex life; or (8) information relating to the commission of a criminal offense.
"Third Party" is any company, natural or legal person, public authority, agency, or body other than the Individual, Wanelo or Wanelo's Agents.
15. Revision History