We at WeSay ("WeSay" "us", "we", or "our") recognize and respect the importance of maintaining the privacy of our customers. This Privacy Notice describes the types of information we collect from you when you visit our website and/or mobile application ("Site"/"App") and/or use our services ("Services"). This Privacy Notice also explains how we collect, process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Service, available at [https://www.wesay.life/terms] ("Terms"). "You" means any adult user of the Site, App and/or Services.
If you are an individual located in the European Union ("EU Individual"), some additional terms and rights may apply to you, as detailed herein. WeSay is the data controller in respect of the processing activities outlined in this Privacy Notice.
"Personal Data" means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. This Privacy Notice details which Personal Data is collected by us in connection with provision of the Services.
The key points listed below are presented in further detail throughout this Privacy Notice. You can click on the headers in this section in order to find out more information about any topic. These key points do not substitute the full Privacy Notice.
Personal Data We Collect, Uses and Legal Basis
Depending on your usage, we collect different types of data and we and any of our third-party sub-contractors and service providers use the data we collect for different purposes, as specified below. It is your voluntary decision whether to provide us with certain Personal Data, but if you refuse to provide such Personal Data we may not be able to register you to the Site and/or App and/or provide you with the Services or part thereof.
Registration Data - In order to use our Site and/or App and/or receive related Services and/or make a purchase from the websites which are linked from our Site and/or App, you can choose to register. If you choose not to register and would like to submit a review, you can do that subject to a provision of your email address. and provide us with the following Personal Data: your name and email address. If you use the Services by logging in through a third-party login/account registration service (such as Facebook or Gmail), we also receive Personal Data about you as provided by such third-party service, such as: your email address, name, age and profile image.
How we use this data: (1) to provide you with the Site, App and/or Services and to respond to your inquiries and requests and to contact and communicate with you; and (2) to prevent fraud, protect the security of and address any problems with the Site and/or App.
Legal Basis: (1) We process this Personal Data for the purpose of providing the Services to you, which is considered performance of a contract with you, including responding to your inquiries and requests and providing customer support. (2) When we process your Personal Data for the purposes of preventing fraud, protecting the security of and/or addressing problems with the Site and Services and/or for the purpose of providing you with informational newsletters and promotional materials relating to our Services, such processing is based on our legitimate interests.
Automatically Collected Data - When you visit the Site and/or App, we automatically collect information about your computer or mobile device, including non-Personal Data such as your operating system, and Personal Data such as IP address, device ID, and subject to your consent as may be required under applicable law, (geo) location, as well as your browsing history and any information regarding your viewing and purchase history on our Site and/or App. For more information about the cookies and similar technologies we use and how to adjust your preferences, please see the section "Cookies and Similar Technologies" below.
How we use this data: (1) to review usage and operations, including in an aggregated non-specific analytical manner, develop new products or services and improve current content, products, and Services; (2) to prevent fraud, protect the security of our Site, App and Services, and address any problems with the Site, App and/or Services; (3) to provide you with customized content, targeted offers, and advertising related to our products and Services or products and services of third parties, based on your usage history on the Site and/or App, on other third-party sites or apps you may visit and/or use, or via e-mail.
Legal Basis: We process this Personal Data for our legitimate interests to develop our products and Services, review usage, perform analytics, prevent fraud, for our recordkeeping and protection of our legal rights and to market our own services. [We will only use your Personal Data for marketing third parties' products and Services if you have consented to such use. You may withdraw your consent at any time by contacting us at firstname.lastname@example.org. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.] Additional information regarding direct marketing is provided below.
Materials You Upload – Any materials including reviews, images and/or pictures and/or photos and/or documents you may upload to the Site and/or App will be collected by us.
How we use this data: To provide you with the Services.
Legal Basis: We process this Personal Data for the purpose of performance of a contract with you.
Special Categories of Data – In the course of providing our Services to you, we also collect data relating to your data concerning your medical information such as your medical condition in the past and present, treatments received, medication and/or cannabis product used, the effect of such treatments, medication and/or cannabis product and any other medical information you shall share in your reviews, which is subject to special protections under the law. We will only collect such data if you provide your consent.
How we use this data: (1) to provide other users with information regarding different Products as which are linked on the App and/or Site, (2) to provide other users with reviews of the Products which are linked on the App and/or Site, analyze the applicable uses of such Products and conduct an analysis of the effectiveness of such Product and their applicability to different medical conditions.
Legal Basis: We process this Personal Data based on your explicit consent. You may withdraw your consent by contacting us at email@example.com. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.
Statistical Information By analyzing all information we receive, including all information concerning users we may compile statistical information across a variety of platforms and users ("Statistical Information").Statistical Information helps us understand trends and customer needs so that new products and services can be considered and so that existing products and services can be tailored to customer desires. Statistical Information is anonymous and aggregated and we will not link Statistical Information to any Personal Data. We may share such Statistical Information with our partners, without restriction, on commercial terms that we can determine in our sole discretion.
As described above, we may use Personal Data to let you know about our products and Services that we believe will be of interest to you and, if you have consented, about products and services of third parties. We may contact you by email or telephone or through other communication channels. In all cases, we will respect your preferences for how you would like us to manage marketing activity with respect to you. To protect privacy rights and to ensure you have control over how we manage marketing with you:
We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms as well as your preferences within your account with us.
We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.
Sharing the Personal Data We Collect
We share your information, including Personal Data, as follows:
Service Providers, and Subcontractors
We also disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors, who have agreed to confidentiality restrictions and who use such information solely on our behalf in order to: (1) help us provide you with the Site, App and/or Services; (2) aid in their understanding of how users are using our Site, App and/or Services; (3) for the purpose of direct marketing (see above for more details).
Such service providers and subcontractors provide us with IT and system administration services, data backup, security, and storage services, data analysis and help us serve advertisements and provide other marketing services.
Your Personal Data may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation) in such case, your Personal Data shall continue being subject to the provisions of this Privacy Notice.
Law Enforcement Related Disclosure
We may share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party's rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; or (iii) as is necessary to comply with any legal and/or regulatory obligation.
We use subcontractors and service providers who are located in countries other than your own, such as the USA, EU, India and Israel and send them information we receive (including Personal Data). We conduct such international transfers for the purposes described above. We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice, including appropriate remedies in the event of the violation of your data protection rights in such third country.
Whenever we transfer your Personal Data to third parties based outside of the European Economic Area ("EEA"), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us at firstname.lastname@example.org if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
We have implemented and maintain appropriate technical and organization security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to Personal Data appropriate to the nature of such data. The measures we take include:
Safeguards – The physical, electronic, and procedural safeguards we employ to protect your Personal Data include secure servers, firewalls, antivirus, and SSL encryption of data.]
Access Control – We dedicate efforts for a proper management of system entries and limit access only to authorized personnel on a need to know basis of least privilege rules, review permissions quarterly, and revoke access immediately after employee termination.
Internal Policies – We maintain and regularly review and update our privacy related and information security policies.
Personnel – We require new employees to sign non-disclosure agreements according to applicable law and industry customary practice.]
Encryption – We encrypt the data in transit using secure protocols.
Database Backup – Our databases are backed up on a periodic basis for certain data and are verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity, are tested regularly to ensure availability, and are accessible only by authorized personnel.]
However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.
Your Rights - How to Access and Limit Our Use of Certain Personal Data
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to the Personal Data that we hold about you, as detailed below. If you wish for us to notify all independent controllers, please specify that request when you contact us in order to exercise any of your rights. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:
Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes. Retention by any of our processors may vary in accordance with the processor's retention policy.
In some circumstances, we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether those purposes can be achieved through other means, as well as applicable legal requirements.
Please contact us at email@example.com if you would like details regarding the retention periods for different types of your Personal Data.
Cookies and Similar Technologies
What are Cookies?
A cookie is a small piece of text that is sent to a user's browser or device. The browser provides this piece of text to the device of the originating user when this user returns.
The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories:
Type of Cookie
Why We Use These Cookies
These cookies are necessary in order to allow the Site and/or App to work correctly. They enable you to access the Site and/or App, move around, and access different services, features, and tools. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies cannot be disabled.
These cookies remember your settings and preferences and the choices you make (such as language or regional preferences) in order to help us personalize your experience and offer you enhanced functionality and content.
These cookies can help us identify and prevent security risks. They may be used to store your session information to prevent others from changing your password without your login information.
These cookies can help us collect information to help us understand how you use our Site and/or App, for example whether you have viewed messages or specific pages and how long you spent on each page. This helps us improve the performance of our Site and/or App.
These cookies collect information regarding your activity on our Site and/or App to help us learn more about which features are popular with our users and how our Site and/or App can be improved.
These cookies are placed in order to deliver content, including ads relevant and meaningful to you and your interests. They may also be used to deliver targeted advertising or to limit the number of times you see an advertisement. This can help us track how efficient advertising campaigns are, both for our own Services and for other websites. Such cookies may track your browsing habits and activity when visiting our Site and/or App and those of third-parties.
How to Adjust Your Preferences
Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Services may not function properly when cookies are disabled or removed. For example, if you delete cookies that store your account information or preferences, you will be required to input these each time you login into your account.
By changing your device settings, you can prevent your device's ad identifier being used for interest-based advertising, or you can reset your device's ad identifier. Typically, you can find the ad identifier settings under "privacy" or "ads" in your device's settings, although settings may vary from device to device. Adjusting your preferences as described in this section herein does not mean you will no longer receive advertisements, it only means the advertisements that you do see will be less relevant to your interests.
Third-Party Applications and Services
All use of third-party applications or services is at your own risk and subject to such third party's terms and privacy policies.
We reserve the right to send you service-related communications, including service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications, you may cancel your account.
We do not knowingly collect Personal Data from individuals under the age of twenty one (21).
Changes to the Privacy Notice
We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version. If we make fundamental changes to this Privacy Notice, we will seek to inform our registered users, which provided us their email address, by notice on our Site or per email.
Comments and Questions
If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, please contact us at firstname.lastname@example.org.
Last updated: August 2019
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