WiziWill Privacy Notice

Finally, please note that some of the above-mentioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it [for internal and external purposes, including, without limitation, to improve the services and for research purposes]. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, to improve our services and enhance your experience with them).

2.    HOW WE PROTECT AND RETAIN YOUR INFORMATION​​​​​​​

2.1  Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised because of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device, or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

2.2  Retention of your Personal Data. Your Personal Data will be stored until we delete the record and we proactively delete it or you send a valid deletion request, please note that in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually. Regarding the retention of cookies, you can read more about our cookie policy through our "Cookie Settings" visible on our website.

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3.     HOW WE SHARE YOUR PERSONAL DATA 

In addition to the recipients described above, we may share your Personal Data as follows:

3.1  With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies WiziWill.

3.2 To the extent necessary, with regulators, courts, or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order. We may use or disclose the information we collect to ensure that our users are complying with all applicable aspects of our policies;

3.3 We may disclose information with our lawyers, accountants, auditors, and other professional advisors where necessary to obtain legal or other advice or otherwise protect and manage our business interests;

3.4 We may use or disclose the Personal Data to investigate, prevent, or take action regarding illegal activities, suspected fraud, cybersecurity threats, situations involving potential threats to the physical safety of any person, violations of this Policy, or as otherwise required or allowed by law and regulations;

3.5 If, in the future, we sell or transfer, or we consider selling or transferring some of or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;

3.6 In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or

3.7 Where you have provided your consent to us, sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

3.8 If you want to receive the list of the current recipients of your Personal Data, please make your request by contacting us at privacy@wiziwill.com.

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4.    ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

External transfers: Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will generally obtain contractual commitments from them to protect your Personal Data. 

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​5.    YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT​

5.1. Rights:

The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

a.  You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee when permitted by applicable law;
b.  You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;
c.  You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise, or defense of legal claims;
d.  You have the right to object to or to request restriction of the processing;
e.  You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used, and machine-readable format, and that you have the right to transmit that data to another controller;
f.   You have the right to object to profiling;
g.  You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
h.  You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
i.   You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place of work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

5.2. You can exercise your rights by contacting us at privacy@wiziwill.com. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent with written permission signed by you. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes before processing and/or honoring your request. We reserve the right to charge a fee when permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law. 

5.3. Deleting your account: Should you ever decide to delete your account you may do so by emailing privacy@wiziwill.com. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account.

5.4. Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject "BLOCK" to privacy@wiziwill.com. Please note that the email must come from the email account you wish to block OR if you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt.

 

6.    USE BY CHILDREN

We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data to us. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@wiziwill.com.

 

7.    INTERACTION WITH THIRD PARTY PRODUCTS

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third-Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third-Party Service..

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8.    ANALYTIC TOOLS/COOKIES  ​

• Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us, and the Google Privacy Policy, available at http://www.google.com/policies/privacy. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout.

• Smartlook. We also use Smartlook, an analytics service provided by Smartlook.com, s.r.o., to help us understand how users interact with our software and to improve user experience. Smartlook records information such as your device type, operating system, IP address (anonymized where possible), and user interactions (such as clicks, navigation, and usage patterns) within our application. The information collected by Smartlook may be transmitted to and stored by Smartlook on servers located in the European Union. We use this data solely for the purpose of analyzing user behavior and improving our services. For more information on how Smartlook processes your data, please visit Smartlook’s Privacy Policy at https://help.smartlook.com/docs/privacy-policy. If you wish to opt out of Smartlook analytics tracking, you can do so by following the instructions at https://www.smartlook.com/opt-out. The processing of your data for analytics purposes is based on our legitimate interest in understanding and improving the use of our software. You have the right to access, rectify, or erase your Personal Data, restrict or object to its processing, and lodge a complaint with a supervisory authority. For more information, please see the “Your Rights” section of this Privacy Notice.

• Firebase Analytics. We also use “Google Analytics for Firebase”. By enabling this tool, we enable the collection of data about App Users, including via identifiers for mobile devices (including Android Advertising ID and Advertising Identifier for iOS), cookies and similar technologies. We use the information we get from Google Analytics for Firebase to maintain and improve our App(s). We do not facilitate the merging of personally identifiable information with non-personally identifiable information unless we have robust notice of, and your prior affirmative (i.e., opt-in) consent to, that merger. Finally, please note that Google Analytics for Firebase’s terms (available at https://firebase.google.com/terms) shall also apply.

• New Relic. We use New Relic, a service provided by New Relic, Inc., to monitor the performance, stability, and usage of our software. New Relic may collect information such as your IP address, device and browser information, operating system, and usage data (such as page views, errors, and response times) to help us analyze and improve the functionality and reliability of our services. The information collected by New Relic may be processed and stored on servers in the United States or other countries. For more information on how New Relic processes your data, please see the New Relic Services Data Privacy Notice at https://newrelic.com/termsandconditions/services-notices. The processing of your data for these purposes is based on our legitimate interest in ensuring the security and performance of our software. You have the right to access, rectify, or erase your personal data, restrict or object to its processing, and lodge a complaint with a supervisory authority. For more information, please see the “Your Rights” section of this Privacy Notice.

• Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others to integrate, use and exchange information with Facebook, such as for the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info choices or http://www.youronlinechoices.eu.

• Facebook Custom Audience

• Lookalike Audience 

• Google Signals. The Website uses a tool called “Google Signals” to collect information about use of the Website. When we activate Google Signals, some existing Google Analytics features are updated to also include aggregated data from Google users who have turned on “Ads Personalization” (Ads Personalization available at https://support.google.com/ads/answer/2662856). Audiences that we create in Google Analytics and publish to Google Ads and other Google Marketing Platform advertising products can serve ads in cross-development eligible remarketing campaigns to Google users who have turned on Ads Personalization. Google Analytics collects additional information about users who have turned on Ads Personalization, based across device types and on aggregated data from users who have turned on Ads Personalization. The data is user based rather than session based. The Cross Device reports include only aggregated data. No data for individual users is ever exposed. You can modify your interests, choose whether your Personal Data is used to make ads more relevant to you, and turn on or off certain advertising services in the Ads Personalization link above.

• Advertising Partners. Through our services, we allow third-party advertising partners to set up technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile/website identifiers, page(s) visited, location, time of day). We also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners will use this information (and similar information collected from other websites) for the purpose of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We allow access to other data collected by the services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your Personal Information with third party advertising partners, you may let us know.

• We use log files: We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information. 

• Do not track: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, but we may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Website.We reserve the right to remove or add new analytic tools.

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9.    SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

9.1  General. This Privacy Policy for California Residents supplements and is expressly made part of the information contained in this Privacy Policy, and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Privacy Policy to comply with the California Consumer Privacy Act of 2018 and its amendments and regulations ("CCPA"). Any terms defined in the CCPA have the same meaning when used in this Privacy Policy.
9.2. Categories of Personal Information. Personal Information collected in the last 12 months as described above in Section 1. If you have further questions with respect the collection, use, disclosure or sale of your Personal Information, please make your request by contacting us at privacy@wiziwill.com. 

9.3. Categories of sources. WiziWill obtains these categories of personal information listed above from the following categories of sources:

a.  Directly from you. For example, from forms you complete or products and services you purchase.
b.  Indirectly from you. For example, from observing your actions on our Website(s).
c.  Data Collected about you as a Trusted Contact when a User appoints you as such - This includes your name, contact information and relationship to the User.

9.4. Your privacy rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to individuals protected by the CCPA:

a.  You have the right to know what Personal Information is being collected about you, this includes the right to request that we disclose what Personal Information of yours we collect, use, disclose, and sell;

b.  You have the right to request the erasure/deletion of your Personal Information (e.g., from our records and the records of our service providers). Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise or defense of legal claims;

c.  You have the right to know whether your Personal Information is sold or disclosed and to whom;

d.  You have the right to restriction of, or object to, processing of your Personal Information, including the right to opt in or opt out of sale of your Personal Information to third parties, if applicable, where such requests are permitted by law;
e.  You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA; and

f.   You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence (e.g. the Attorney General in your State). We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution. You have certain choices about your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time and prevent further processing by contacting us as described in this Privacy Policy. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our services and for other legal purposes as described above. While we cannot guarantee privacy perfection, we will address any requests to the best of our ability as soon as possible. We will process such requests in accordance with applicable laws.

9.5. You can exercise your rights by contacting us at privacy@wiziwill.com.   If we decline to take action on one of your rights, applicable law may allow us to submit an appeal, this may be done by emailing us at privacy@wiziwill.com. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent with written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee when permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law. 

9.6. Deleting your account. Should you ever decide to delete your account, you may do so by emailing privacy@wiziwill.com. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account.

9.7. Marketing emails – opt-out. You may choose not to receive marketing email of this type by sending a single email with the subject "BLOCK" to privacy@wiziwill.com. Please note that the email must come from the email account you wish to block.

9.8. Non-Discrimination. If you decide to exercise your rights, you will not receive any discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA. However, note that some features of our Website, App, our products, and/or our services will not function without your Personal Information. Unless permitted by the CCPA, we will not:

a.  Deny you goods or services.
b.  Charge different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
c.  Provide you with a different level or quality of goods or services.
d.  Suggest that you receive a different price or rate for goods or services or a different level or quality of goods or services.

9.8. NOTICE OF RIGHT TO OPT OUT OF THE SHARING OF YOUR PERSONAL INFORMATION.

Notice of right to opt-out of the sharing of Personal Information. 

a.  We do not sell your Personal Information in exchange for monetary compensation. However, we may share your Personal Information with certain third parties (such as certain advertising services, vendors, and other tracking technologies) or allow them to collect Personal Information via automated technologies on the App or Website for marketing / cross-context behavioral advertising purposes, internal technological purposes. We also directly share information with some of our vendors to obtain marketing services and/or analytics information. This kind of sharing may be considered a “sharing” under California law, even when the Personal Information is exchanged for non-monetary consideration. The categories of Personal Information we “share” includes: identifiers such as a name, address, unique personal and online identifiers (such as a device identifier, beacons, pixel tags, mobile ad identifiers and similar technology), email address, account name, location data (which includes the location of the mobile device or tablet derived from GPS or Wi-Fi use; the IP address of the device or internet service used to access the App and the advertising ID), and phone number. Categories of third parties to whom Personal Information was disclosed that may be considered a “sharing” under CCPA are: marketing partners, data analytics providers, and other tracking technology providers.
b.  You have the right to opt out of the sharing of your Personal Information for cross-context behavioral advertising. You can exercise your right by clicking the “Do Not Sell My Personal Information” link or on our Website here [https://www.wiziwill.com/support?donotsell]  . You will not be required to create an account for exercising the opt-out right.
c.  We do not currently offer financial incentives; however, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program.
d.  We do not knowingly share (for cross-context behavioral advertising) the Personal Information of consumers under 16 years of age. For more information about the treatment of children’s Personal Information, see Section 6 above.

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9.9. NOTICE OF RIGHT TO LIMIT THE PROCESSING OF YOUR SENSITIVE PERSONAL INFORMATION 

a.  California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@wiziwill.com. Please note that we are only required to respond to one request per customer each year.
b.  Deletion of Content from California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted as comments on our blog. If you wish to remove such content or Personal Information and you specify which content or Personal Information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you may not be able to restore the removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

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10.    CONTACT US.

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@wiziwill.com.

Data controller: WiziWill LTD., privacy@wiziwill.com

GDPR representative: WiziWill LTD., privacy@wiziwill.com

DPO: WiziWill LTD., privacy@wiziwill.com

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