Privacy Policy

Effective as of 2021-08-15

1. Introduction

   Thanks for choosing Wazoo! At Wazoo, we want to give you the best possible experience to ensure that you enjoy our service. Your privacy and the security of your personal data is, and will always be, enormously important to us. So, we want to transparently explain how and why we gather, store, share and use your personal data - as well as outline the controls and choices you have around when and how you choose to share your personal data. That is our objective, and this Privacy Policy ("Policy") will explain exactly what we mean in further detail below.

2. About this Policy

   This Policy sets out the essential details relating to your personal data relationship with Wazoo Inc. The Policy applies to all Wazoo services and any associated services (referred to as the “Wazoo Service”). The terms governing your use of the Wazoo Service are defined in our Terms of (the "Terms and Conditions of Service"). From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any material change to the way we collect or process your personal data we will provide you with more information or additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.

   The aim of this Policy is to:

   1. ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with;
   2. explain the way we use the personal data that you share with us in order to give you a great experience when you are using the Wazoo Service;
   3. explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.

   We hope this helps you to understand our privacy commitments to you. For information on how to contact us if you ever have any questions or concerns, please see Section 14 'How to Contact Us' below. Alternatively, if you do not agree with the content of this Policy, then please remember it is your choice whether you want to use the Wazoo Service.

3. Your Rights and Your Preferences: Giving You Choice and Control

   The General Data Protection Regulation or "GDPR" gives certain rights to individuals in relation to their personal data. Accordingly, we are happy to offer transparency and access controls to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:

   1. right of access - the right to be informed of, and request access to, the personal data we process about you;
   2. right to rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete;
   3. right to erasure - the right to request that we delete your personal data;
   4. right to restrict - the right to request that we temporarily or permanently stop processing all or some of your personal data;
   5. right to object - the right, at any time, to object to us processing your personal data on grounds relating to your particular situation; the right to object to your personal data being processed for direct marketing purposes;
   6. right to data portability - the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party's service; and
   7. right not to be subject to automated decision-making - the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

   For additional privacy rights under the California Consumer Privacy Act (CCPA), please see Section 12 ‘Additional California Privacy Disclosures’ of this Policy.

4. Data We Collect From You

   1. User data

      This is the personal data that is provided by you or collected by us to enable you to sign up for and use the Wazoo Service. Depending on the type of Wazoo Service plan you sign up for, this may include your name, email address, phone number gender, and country. Some of the personal data we will ask you to provide is required in order to create your account. You also have the option to provide us with additional personal data in order to make your account more personalized. The exact personal data we will collect depends on the type of Wazoo Service plan you sign up for, how you create an account, and whether you use third party services to sign up and use the Wazoo Service. If you use a third party service to create an account, we will receive personal data via that third party service but only when you have consented to that third party service sharing your personal data with us. Please note that the available plans and sign-up options may differ by country.

   2. Usage data

      This is the personal data that is collected about you when you’re accessing and/or using the Wazoo Service, including:

      1. Information about your type of Wazoo Service plan.
      2. Information about your interactions with the Wazoo Service such as your search queries (including the date and time of any requests you make), created alerts, tournaments added to your watchlist, saved searches, and your interactions with the Wazoo Service or Content. This also may include details of your use of third party applications in connection with the Wazoo Service.
      3. Inferences drawn about your interests and preferences based on your usage of the Wazoo Service.

   3. Certain Technical Data

      1. URL information;
      2. online identifiers including cookie data and IP addresses;
      3. information about the types of devices you are using such as unique device IDs, network connection type (e.g. wifi, 3G, LTE, Bluetooth), provider, network and device performance, browser type, language, information enabling digital rights management, operating system, and Wazoo application version;
      4. your non-precise location, which may be derived or inferred from certain technical data (e.g., your IP address, language setting of your device, or payment currency), to deliver personalized content and advertising to you.

   4. Payment and Purchase Data

      We may collect certain personal data if you sign up for a Trial or purchase any of our Paid Subscriptions (as defined in the Terms and Conditions of Use) or make other purchases through the Wazoo Service. The exact personal data collected will vary depending on the payment method (e.g. direct via your mobile phone carrier or by invoice) but will include information such as:

      1. name;
      2. date of birth;
      3. credit or debit card type, expiration date, and certain digits of your card number;
      4. postal code;
      5. mobile phone number;
      6. details of your purchase and payment history.

   5. Contests, Surveys and Sweepstakes Data

      When you complete any forms, respond to a survey or questionnaire, or participate in a contest, we collect the personal data you provide.

   6. Data From Third Party Sources

      1. Authentication Partners - If you register for or log into our services using third party credentials (e.g. Facebook), we will import your information from such third party to help create your account with us.
      2. Technical Service Partners - We work with technical service partners that provide us with certain data, such as mapping IP addresses to non-precise location data (e.g., city, state), to enable us to provide the Wazoo Service, content, and features.
      3. Payment Partners - We may receive data from our payment partners to enable us to send you invoices, process your payment and provide you with what you’ve purchased.
      4. Advertisers and Other Advertising Partners - We may obtain certain data about you, such as cookie id, mobile device id, or email address, and inferences about your interests and preferences from certain advertisers and advertising partners that allow us to deliver more relevant ads and measure their effectiveness.

5. What We Use Your Personal Data For

   When you use or interact with the Wazoo Service, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data (identified in Section 4 'Personal Data We Collect From You') used for these purposes:

   1. To provide and personalize the Wazoo Service
   2. To understand, diagnose, troubleshoot, and fix issues within the Wazoo Service
   3. To evaluate and develop new features, technologies, and improvements to the Wazoo Service
   4. For marketing, promotion, and advertising purposes,
   5. To comply with legal obligations and law enforcement requests
   6. To establish, exercise, or defend legal claims
   7. To conduct business planning, reporting, and forecasting
   8. To process your payment
   9. To detect fraud, including fraudulent payments and fraudulent use of the Wazoo Service
   10. To conduct research, contests, surveys, and sweepstakes

   If you require further information about the balancing test that Wazoo has undertaken to justify its reliance on the legitimate interest legal basis under the GDPR, please see Section 14 'How to Contact Us' for further details on how to contact us.

6. Sharing your personal data

   We have set out the categories of recipients of the personal data collected or generated through your use of the Wazoo Service.

   1. Third Parties

      Third party applications and devices you connect to your Wazoo Account. If you connect your Wazoo account to a third party application and/or device(s), such as social media, Wazoo shares technical data with the operator of that third party application and/or device in order to connect your Wazoo account.

   2. Service Providers

      We work with service providers that work on our behalf which may need access to certain personal data in order to provide their services to us. These companies include those we have hired to provide customer service support, operate the technical infrastructure that we need to provide the Wazoo Service, assist in protecting and securing our systems and services, and help market Wazoo’s own products and services as well as partner products, services, events, and co-branded promotions in which Wazoo is involved.

   3. Payment Processor

      We will share your personal data with our payment processors as necessary to enable them to process your payments, and for anti-fraud purposes.

   4. Advertising Partners

      We work with service providers that work on our behalf which may need access to certain personal data in order to provide their services to us. These companies include those we have hired to provide customer service support, operate the technical infrastructure that we need to provide the Wazoo Service, assist in protecting and securing our systems and services, and help market Wazoo’s own products and services as well as partner products, services, events, and co-branded promotions in which Wazoo is involved.

   5. Wazoo Partners

      Depending on how you sign up for the Wazoo Service (e.g. through a third party service or a mobile provider), we share your Wazoo username or other User Data as necessary to enable your account. We may also share personal data with that third party about your use of the Wazoo Service, such as whether and to what extent you have used the offer, activated a Wazoo account, or actively used the Wazoo Service

   6. Other Wazoo Group Companies

      We will share your personal data with other Wazoo group companies to carry out our daily business operations and to enable us to maintain and provide the Wazoo Service to you.

   7. Law Enforcement and Data Protection Authorities

      We share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. We also share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.

   8. Purchasers of Our Business

      We will share your personal data in those cases where we sell or negotiate to sell our business to a buyer or prospective buyer. In this situation, Wazoo will continue to ensure the confidentiality of your personal data and give you notice before your personal data is transferred to the buyer or becomes subject to a different privacy policy.

7. Data Retention and Deletion

   We keep your personal data only as long as necessary to provide you with the Wazoo Service and for legitimate and essential business purposes, such as maintaining the performance of the Wazoo Service, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal data for as long as you are a user of the Wazoo Service. For example, we keep your Saved Alerts and account information.

   If you request, we will delete your personal data so that it no longer identifies you, unless we are legally allowed or required to maintain certain personal data, including situations such as the following:

   1. If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
   2. Where we need to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law;
   3. Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.

8. Transfer to Other Countries

   Wazoo shares your personal data globally with Wazoo group companies in order to carry out the activities specified in this Policy. Wazoo may also subcontract processing to, or share your personal data with, third parties located in countries other than your country. Your personal data, therefore, may be subject to privacy laws that are different from those in your country. Personal data collected within the European Union and Switzerland may, for example, be transferred to and processed by third parties located in a country outside of the European Union and Switzerland. In such instances Wazoo shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organizational measures are in place such as the Standard Contractual Clauses approved by the EU Commission. For further details of the security measures we use to protect your personal data, please see Section 10 'Keeping Your Personal Data Safe' of this Policy.

9. Links

   We may display advertisements from third parties and other content that links to third-party websites. We cannot control or be held responsible for third parties' privacy practices and content. If you click on a third-party advertisement or link, please understand that you are leaving the Wazoo Service and any personal data you provide will not be covered by this Policy. Please read their privacy policies to find out how they collect and process your personal data.

10. Keeping Your Personal Data Safe

    We are committed to protecting our users' personal data. We implement appropriate technical and organizational measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies including encryption, access, and retention policies to guard against unauthorized access and unnecessary retention of personal data in our systems.

    Your password protects your user account, so we encourage you to use a strong password that is unique to your Wazoo account, never share your password with anyone, limit access to your computer and browser, and log out after having used the Wazoo Service.

11. Children

    The Wazoo Service is not directed to children under the age of 13 years. The Wazoo Service is also not offered to children whose age makes it illegal to process their personal data or requires parental consent for the processing of their personal data under the GDPR or other local law. We do not knowingly collect personal data from children under 13 years or under the applicable age limit (the "Age Limit"). If you are under the Age Limit, please do not use the Wazoo Service, and do not provide any personal data to us. If you are a parent of a child under the Age Limit and become aware that your child has provided personal data to Wazoo, please contact us using the 'Contact' form on our website, and you may request exercise of your applicable rights detailed in Section 3 'Your Rights and Your Preferences: Giving You Choice and Control' of this Policy. If we learn that we have collected the personal data of a child under the age of 13 years, we will take reasonable steps to delete the personal data. This may require us to delete the Wazoo account for that child.

12. Additional California Privacy Disclosures

    Beginning January 1, 2020, the California Consumer Privacy Act ("CCPA") gives California residents certain rights with respect to the processing of personal data (known as "personal information" under the CCPA).

    1. Personal Information Collected and Processed

       Section 4 of this Policy sets forth the categories of personal information that Wazoo collects and processes about you, a description of each category, and the sources from which we obtain each category.

    2. Requests to Exercise Your Rights

       RIGHT TO KNOW REQUEST - Under the CCPA, you have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months, and ask that we provide you with the following information:

       1. Categories of and specific pieces of personal information we have collected about you.
       2. Categories of sources from which we collect personal information.
       3. Purposes for collecting personal information.
       4. Categories of third parties with which we share personal information.
       5. Categories of personal information disclosed about you for a business purpose
       6. If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold.

       To make a verifiable request for information about the personal information we have collected about you, please contact us by visiting the ‘Contact’ page on our website or emailing us at [email protected]

       RIGHT TO DELETE REQUEST - You also have a right to request that we delete personal information, subject to certain exceptions. You may exercise your right to delete by visiting the 'Contact’ page on our website and selecting "Account Deletion" as the subject or by emailing us at [email protected].

       HOUSEHOLD REQUESTS - We currently do not collect household data. If all the members of a household make a Right to Know or Right to Delete request, we will respond as if the requests are individual requests.

       REQUESTS, GENERALLY - Please note, if you do not have a Wazoo account we will not have enough information about you to verify your Right to Know and Right to Delete requests, as we do not keep sufficient information necessary to reidentify and link you to a prior visit to the Wazoo Service where data may have been collected. As such, we will be unable to verify and honor your requests. You may make a verifiable consumer request related to your personal information twice per 12-month period. We will not discriminate against you for exercising any of your rights under the CCPA.

       REQUESTS MADE THROUGH AGENTS - You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

    3. Disclosures of Personal Information for a Business Purpose

       In the preceding 12 months, Wazoo has disclosed certain data from the following categories of personal information to the categories of recipients listed in Section 6 of this Policy for one or more business purposes

       1. User Data
       2. Usage Data
       3. Plan Verification Data
       4. Payment and Purchase Data
       5. Contests, Surveys and Sweepstakes Data

    4. Sale of Personal Information

       We do not sell personal information. We have taken substantial steps to identify and remediate any data sharing arrangements that could constitute a "sale" under the CCPA.
       While we do not sell any personal information, we do provide Usage Data to advertising partners to enable us to provide you with interest-based advertising. If you prefer not to receive interest-based advertising, please opt out by visiting the 'Contact’ page on our website by emailing us at [email protected].
       We will continue to update our business practices as regulatory guidance becomes available and provides clarity on what constitutes a sale transaction, particularly in the advertising ecosystem.

13. Changes to This Policy

    We may occasionally make changes to this Policy.
    When we make material changes to this Policy, we will provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Wazoo Service or by sending you an email and/or a device notification. We may notify you in advance.
    Please, therefore, make sure you read any such notice carefully.

14. How to Contact Us

    Thank you for reading our Policy. If you have any questions about this Policy, please contact us by using the 'Contact’ form on our website, emailing [email protected], or by writing to us at the following address:

    Wazoo Inc.
    66 Mineola Avenue
    Unit 194
    Roslyn Heights, New York 11577
    USA

© Wazoo Inc.