Privacy Policy
Last update: 04/01/2024
Wise Technologies, Ltd. (“Wise Technologies,” “us,” "we," or
“our”) is committed to protecting and respecting your privacy in connection
with your use of our website, www.wise-t.com (the “Website(s)”),
applications (“Apps”) and other products, services and features thereof (the
Website, the Apps and such other products, services and features are
collectively referred to herein as the “Product” or “Products”, which may be
updated from time-to-time at the sole discretion of Wise Technologies). This
privacy policy (“Privacy Policy”) and any other documents referred to herein
set forth the basis on which any personal data we collect from you, or that you
provide to us, in connection with the Products will be processed by us. Please
read the following carefully to understand our practices regarding your
personal data and how we will collect, use, and disclose your personal data. If
you have an unresolved privacy or data use concern that we have not addressed
satisfactorily, please contact our U.S.-based third-party dispute resolution
provider (free of charge) at http://go.adr.org/privacyshield.html.
1. DATA WE MAY COLLECT
We may collect and process the following data about you: • Personal data
including, for example, your name, e-mail address, password, and in
certain instances, telephone number, data about your usage of the Products and
data collected by tracking technologies as further described in section 4 below
that may identify you as an individual or allow online contact with you as an
individual.
• For individuals who fill the contact forms in a Wise Technologies published
mobile apps, we may collect additional personal data, for example, home
address.
• Wise Technologies does not collect or process credit or debit card
(“Payment Card”) data. Apple and Google collect Payment Card data with respect
to in-app purchases made through the Apps, and our payment processor collects
Payment Card data with respect to purchases made through the Websites. Such
payment processors generally provide us with some limited data related to you,
such as a unique, anonymous token that enables you to make
additional purchases using the data they have stored, and your card’s
type, expiration date, billing address, and the last four digits of your card
number.
• Business data such as your company name, and company email address to
the extent that you provide such data.
• Facebook profile information, such as name, email address, and
Facebook ID, if you choose to log in to the Products through Facebook.
• Device information such as operating system version, device type, and
system performance data.
• Data collected via tracking technologies, as fully described in
section 4.
• If you choose to have your account verified to confirm your status as
a student, we may allow a third-party platform to access the specific personal
data you provide to perform the verification. All the information you need to
fill in the open text fields during account registration is mandatory. Any
failure to complete that information or any response Wise Technologies
considers abnormal may result in Wise Technologies refusing (or being unable)
to process your request. You agree that the personal data you provide about
yourself or subsidiary account holders to Wise Technologies will be current,
accurate, complete, and unequivocal.
• If you chose to have your account verified to confirm your status as a
US-based healthcare provider, we may collect your National Provider Identifier
(“NPI”) in connection with your email address to perform the verification.
2. CONFIDENTIALITY AND SECURITY
The security of your personal data is important to us. We follow
generally accepted standards to protect the personal data submitted to us, both
during transmission and once it is received. If you have any questions about
the security of your personal data, you can contact us at info_wise@wise-t.com.
Except as described under the “Disclosure of Your Data” section below, we do
not provide your personal data to any third party without your specific
consent, as defined by applicable law.
3. NEWSLETTERS OR OTHER ELECTRONIC COMMUNICATIONS
If you sign up to receive promotional materials from us via email and/or
(push notifications) we will use the data, you give us to provide the
communications you have requested. If you inform us that you wish to cancel
email promotional materials by selecting “unsubscribe” at the bottom of such
communication or by emailing us at info_wise@wise-t.com, we will remove you
from our mailing list. If you no longer wish to receive push notifications, you
may turn them off at the device level.
If you provide your phone number to us directly or through a third-party
for the specific purpose of receiving an SMS message with a link to our Apps,
you will receive such SMS message (the “SMS Service”). Standard text message
rates will apply.
4. TRACKING TECHNOLOGIES
Wise Technologies and our analytics partners use technologies such as
cookies, beacons, tags, and scripts to enable a service to recognize your
device so you don't have to provide the same
data several times during one task, to recognize that you may have already
given a username and password, so you don't need to do it for every web page
requested, and to measure how people are using the Products.
We use local storage, such as HTML5, to store content data and
preferences. Third parties with whom we partner to provide certain features on
the Products also use HTML5 to collect and store data. Various browsers may
offer their own management tools for removing HTML5.
We partner with third parties, such as Facebook and Google, to manage
our advertising of the Products on other sites or platforms as well as across
your other devices based on your past visits to our Website. Our third-party
partners may use technologies such as cookies to gather data about your
activities within the Products to deliver such advertising to you, such as
retargeting ads. We are not always able to respond to do-not-track signals. For
more data about interest-based ads, including how to opt-out of having your
web-browsing data used for behavioural advertising purposes, please visit www.aboutads.info/choices.
Please note that this does not opt you out of being served ads. You may
continue to receive generic ads on these third-party platforms. You may also
opt out of receiving ads across devices by adjusting your ad preference in your
Google account.
We use third party trackers to let us know when users have visited the
Products by “clicking-through” our sponsored advertising or content hosted on
third party platforms. The Products use Google Analytics code to gather
statistical data. Google Analytics sets cookies to help us accurately estimate
the number of visitors to the Products and the volumes of usage of the
Products. This is done to ensure that the Products are available when you want
them and are fast. For more data on how Google Analytics processes this data,
visit www.google.com/analytics.
We will acquire consent from you to use such trackers to the extent
required by applicable law.
MOBILE ANALYTICS
We use mobile analytics software to allow us to better understand the
functionality of our mobile software on your phone. This software may record
data such as how often you engage with the Products, the events that occur
within the Products, aggregated usage, and performance data, and where the
Applications were downloaded from. We may link the data we store within the
analytics software to any personal data you submit within the mobile
application.
LOG FILES
As true of most websites, we gather certain data and automatically and
store it in log files. This data may include Internet Protocol (IP) addresses,
browser type, internet service provider (ISP), referring/exit pages, operating
system, date/time stamp, and/or clickstream data.
If you receive the HTML-formatted version of our email newsletter, your
opening of the newsletter is notified to us and saved. Your clicks on links in
the newsletter are also saved. These and the open statistics are used in aggregate
form to give us an indication of the popularity of the content and to help us
make decisions about future content and formatting.
5. WHERE WE STORE YOUR PERSONAL DATA
All data you provide to us through the Products is stored on our secure
servers located in the EU. Any payment transactions will be encrypted using SSL
technology; all payment data is stored with our payment processor and is never
stored on Wise Technologies’s servers. Where we have
given you (or where you have chosen) a password which enables you to access
certain parts of the Products, you are responsible for keeping this password
confidential. We ask you not to share a password with anyone and suggest that
your change your password frequently.
Unfortunately, the transmission of data via the Internet is not
completely secure. Although we will do our best to protect your personal data,
we cannot guarantee the security of your data transmitted to the Products; any
transmission is at your own risk. Once we have received your data, we will use strict
procedures and security features to try to prevent unauthorized access.
6. CORPORATE AND OTHER COMMUNITY SHARING
There is interest by large consumer communities (companies,
universities, hospitals, government agencies, etc.) (“Communities”) to introduce
the Products to their employees and members. If you have registered to use the
Products through a code or other registration credential furnished by a
Community (a “Community Subscription”), the Community will have access to your
email address, the date you registered to use the Products, and the date on
which you last used the Products. The Community will also have access to your
Community's aggregated and anonymized general usage data.
Your Community may also have access to your usage data on an individual
basis, but only if you have provided appropriate consent under applicable law
for such sharing. For example, many Communities are offering incentive programs
based on members' participation in health and wellness programs, and desire to
better understand how their employees are using the Products.
7. SINGLE SIGN-ON
You may be able to log-in to our Products using sign-in services such as
Facebook Connect or an Open ID provider. These services will authenticate your
identity, provide you the option to share certain personal data (such as your
name and email address) with us, and to pre-populate our sign-up form. Services
like Facebook Connect give you to the option to post data about your activities
on our Products or to your profile page to share with others within your
network.
8. YOUR DATA RIGHTS
As you may know, a recent European Union law called the General Data
Protection Regulation (“GDPR”) give certain rights to applicable individuals in
relation to their personal data. Accordingly, we have implemented transparency
and access controls to help such users, including residents of the EU,
Switzerland, and the United Kingdom exercise those rights. As required under
applicable law, the rights afforded to you are:
A right of access: you have the right to
obtain (i) confirmation as to whether personal data
concerning you are processed or not and, if processed, to obtain (ii) access to
such data and a copy thereof. We provide an easy-to-view snapshot of such data
via the “My Data” tab in the Products.
A right to rectification: you have the right to obtain the rectification of any inaccurate
personal data concerning you. You also have the right to have incomplete
personal data completed, including by means of providing a supplementary
statement.
A right to erasure: in some
cases, you have the right to obtain the erasure of personal data concerning
you. Upon request, Wise Technologies will permanently and irrevocably anonymize
your data such that it can never be reconstructed to identify you as an
individual. However, this is not an absolute right and Wise Technologies may
have legal or legitimate grounds for keeping such data.
A right to restriction of processing: in some
cases, you have the right to obtain restriction of the processing of your
personal data.
A right to data portability: you have the right to receive the personal data concerning you
which you have provided to Wise Technologies, in a structured, commonly used
and machine-readable format, and you have the right to transmit those data to
another controller without hindrance from Wise Technologies. This right only
applies when the processing of your personal data is based on your consent or
on a contract and such processing is carried out by automated means.
A right to object to processing: you have
the right to object at any time, on grounds relating to your situation, to
processing of personal data concerning you when such processing is based on the
legitimate interest of Wise Technologies. Wise Technologies may, however, invoke
compelling legitimate grounds for continued processing. When your personal data
is processed for direct marketing purposes, you have the right to object at any
time to the processing of such data. You may exercise that right by clicking on
the “unsubscribe” link provided at the bottom of any messages received.
A right to lodge a complaint with the competent
supervisory authority: you have the right to contact the supervisory
authority to complain about Wise Technologies’s
personal data protection practices.
A right to give instructions concerning the use of
your data after your death: as required by applicable law, you may have
the right to give Wise Technologies instructions concerning the use of your
personal data after your death. To exercise one or more of these rights, you
can email info_wise@wise-t.com.
You may access your personal data to modify or update at any time via an
online account, or by emailing info_wise@wise-t.com.
We will respond to your request in a reasonable timeframe in accordance
with applicable law.
9. USES MADE OF THE DATA
We use information held about you in the following ways:
To provide you with the Products.
To answer your questions or requests for information or handle your
complaints.
To ensure that content provided by the Products is presented in the most
effective manner for you and for your computer or other device.
To provide you with promotional communications, such as email, to the
extent that you have provided consent to receive such communications under
applicable law.
To carry out our obligations arising from any agreements entered between
you and us.
To allow you to participate in interactive features of the Products when
you choose to do so.
To notify you about updates or changes to Product features and content.
To understand your broad, non-specific geographic location to help us
identify groups of users by general geographic market (such as zip code, state or country).
To account for applicable sales taxes based on zip codes provided to our
payment processors for purchases made through the Website.
To inform your Community about your registration and use of the Products
as described under Corporate and Other Community Sharing in section 6 above.
To serve our advertisements to you through third party platforms, such
as Facebook or Google, on other sites and apps or across your devices, to the
extent that you have provided consent for such uses under applicable law.
To provide you with the SMS Service to the extent that you have provided
consent for such practices under applicable law.
We may also ask you to complete surveys that we use for research
purposes, although you do not have to respond to them.
To manage your payments and orders.
If you are an existing customer, we will only contact you by electronic
means (e-mail or in-Product communication) with information about products and
services like those which were the subject of a previous sale to you, except if
you opt-out to such communications.
10. LEGAL BASES OF PERSONAL DATA PROCESSING
In accordance with GDPR, Wise Technologies provides the following
information regarding its Article 6 legal bases for personal data processing:
The performance of the contract (the Wise
Technologies Terms & Conditions) between you and Wise
Technologies for the data processing relating to your use of Wise Technologies’s Products (including your orders and payments);
Wise Technologies’s legitimate interest, more
specifically:
Our business interest in providing you with emails and push notifications
for timely introductory materials and information about your Wise Technologies
account, our Product features, and updates, and offers to upgrade your free
account to a subscription account.
Our business interest in offering you particularized or adapted content
based on your usage of the Products.
Our business interest in collecting data regarding your general usage
activities for the purpose of improving our Wise Technologies user experience.
Our business interest in requesting that you partake in Product surveys to
better understand your needs and expectations.
Our business interest in providing you with customer service
communications regarding your account, questions about our content offerings or
your mindfulness practice, or any other matters directed to customer service
staff, in order to have clear and easy communication
with you and to respond to all your requests.
Our business interest in collecting data related to unplanned downtime
or errors in the Products.
Our business interest in complying with our legal obligations, such as
maintaining accurate financial records.
Our business interest in verifying your eligibility in a Community and
providing limited reporting to such Community, as further described in section
6.
11. DISCLOSURE OF YOUR DATA
We may disclose your personal data to any member of our group, which
means our subsidiaries, our ultimate holding company, and its subsidiaries.
We may also disclose your personal data to third parties as follows:
In some circumstances, based on your specific requests, we may need to
disclose your personal data to a third party so that it can provide a service
you have requested from such party, or fulfil a request for data from such
party. An example of this is the SMS Service.
In some circumstances, we may disclose the personal data that you have
provided to Wise Technologies to a third party that offers and/or provides
goods or services complementary to our own for the purpose of enhancing our
users’ experiences by offering you integrated or complementary functionality,
complementary services or bundled pricing options.
If Wise Technologies’s service providers (like
hosting, IT maintenance, market analytics, and payment service providers)
require this data to provide services to Wise Technologies. Wise Technologies
requires each of its service providers to agree to maintain the confidentiality
and security of your personal data.
If we sell or buy any business or assets, in which case we may disclose
your personal data to the prospective seller or buyer of such business or
assets.
If Wise Technologies or substantially all our assets are acquired by a
third party, in which case personal data held by us about our customers will be
one of the transferred assets.
If we are under a duty to disclose or share your personal data to comply
with any legal obligation such as to comply with a subpoena, bankruptcy
proceedings, similar legal process, or to enforce or apply our agreements with
you; or to protect the rights, property, or safety of Wise Technologies, our
customers, or others. This includes exchanging data with other companies and
organizations for the purposes of fraud protection and credit risk reduction.
With your Community, if your subscription is a Community Subscription,
as described under Corporate and Other Community Sharing above.
With third parties, such as Facebook, to serve Wise Technologies
advertisements on such third-party platforms, to the extent that you have
consented to such practices under applicable law.
If you choose to have your account verified to confirm your status as a
student, we may allow a third-party platform to access the specific personal
data you provide to perform the verification.
If you chose to have your account verified to confirm your status as a
US-based healthcare provider, we may collect your National Provider Identifier
(“NPI”) in connection with your email address to perform the verification.
12. DATA RETENTION
The retention periods applied by Wise Technologies comply with
applicable legislation in effect on the date hereof, namely:
For data relating to your account: such data will not be retained beyond
your request that your account be deleted.
For transactional data relating to your purchases: such data is kept for
the entire period of the contractual relationship, then in accordance with
legal obligations and applicable statute of limitation periods. Please note
that this data does not include Payment Card information, which is processed by
our third-party payment processors, and not Wise Technologies.
For data collected based on your consent to receive our marketing
communications: we will use such data until you withdraw consent or applicable
law requires that such data is no longer used.
When your data are collected in the context of requests/queries: such
data are kept for the period necessary to process and reply to such requests or
queries.
When cookies or other trackers are placed on your terminal, they are
kept for a period of 12 months.
Other data will be kept if necessary, for the purposes pursued and in
compliance with our legal obligations, including the applicable statute of
limitations.
13. WITHDRAWAL OF CONSENT FOR PROCESSING ACTIVITIES
To the extent that you have provided appropriate consent under
applicable law to certain processing activities, such consent can be withdrawn
at any time by emailing info_wise@wise-t.com.
14. LINKS TO THIRD PARTY SITES
The Products may, from time to time, contain links to and from the
Products of our partner networks, advertisers, and affiliates. If you follow a
link to any of these external websites, please note that these websites have
their own privacy policies and that we do not accept any responsibility or
liability for these websites or their policies. Please check these policies
before you submit any personal data to these external websites.
15. SOCIAL MEDIA WIDGETS
Our Products include social media features, such as the Facebook Like
button, and widgets, such as the “Share This” button, or interactive mini-programs. These features may collect your Internet
protocol address, which page you are visiting on or Products, and may set a
cookie to enable the feature to function properly. Social media features and
widgets are hosted by a third party or hosted directly on our Products. Your interactions
with these features are governed by the privacy statement of the company
providing it.
16. HEALTH, FITNESS AND MEDICAL DATA
Our Products will not use or disclose to third party’s data gathered in
the health, fitness, and medical research context—including from the Clinical
Health Records API, HealthKit API, Motion and
Fitness, MovementDisorderAPIs, or health-related
human subject research—for advertising, marketing, or other use-based data
mining purposes other than improving health management, or for the purpose of
health research, and then only with permission. Products may, however, use a
user’s health or fitness data to provide a benefit directly to that user (such
as a reduced insurance premium), provided that the app is submitted by the
entity providing the benefit, and the data is not be shared with a third party.
At this moment there is no health data we use from Products.
Products will not write false or inaccurate data into HealthKit or any other medical research or health
management apps, and may not store personal health
information in iCloud.
Products conducting health-related human subject research will obtain
consent from participants or, in the case of minors, their parent or guardian.
Such consent will include the (a) nature, purpose, and duration of the
research; (b) procedures, risks, and benefits to the participant; (c)
information about confidentiality and handling of data (including any sharing
with third parties); (d) a point of contact for participant questions; and (e)
the withdrawal process.
Products conducting health-related human subject research will secure
approval from an independent ethics review board. Proof of such approval will
be provided upon request.
17. USE OF WISE TECHNOLOGIES BY MINORS
You must be 18 years of age, or the age of majority in your province, territory,
or country, to sign up as a registered user of the Products. Individuals under
the age of 18, or the applicable age of majority, may utilize the Products only
with the involvement and consent of a parent or legal guardian, under such
person's account.
18. DATA POSTED ON FORUMS
Wise Technologies users may have the ability to post content to one or
more Wise Technologies forums. All such users may request and obtain removal of
such posted content by contacting Wise Technologies at info_wise@wise-t.com and
specifically identifying the content to be removed. Please be advised that any
such removal does not ensure complete or comprehensive removal of all traces of
the content posted on the Wise Technologies forum(s).
19. CHANGES TO OUR PRIVACY POLICY
We may update this Privacy Policy to reflect changes to our data
practices. If we make any material changes, we will notify you by in-Product
message, email (sent to the e-mail address specified in your account) or by
means of a notice in the Products prior to the change becoming effective. We
encourage you to periodically review this page for the latest data on our
privacy practices.
20. CONTACT
Questions, comments, and requests regarding this privacy policy are
welcomed and should be addressed to info_wise@wise-t.com. In the alternative,
you may reach Wise Technologies customer support at +386 41 367 314.
Wise Technologies’s physical address is Cesta
24. Junija 23, 1231 Ljubljana, Slovenia.
21. TRANSMISSION TO OTHER COUNTRIES
The subsidiaries, service providers or other third parties listed above
to whom Wise Technologies may disclose your personal data may be domiciled
abroad, and in particular outside the European Union,
Switzerland, and the United Kingdom.
In such case, Wise Technologies will require them to take, in accordance
with applicable legislation, all organizational and technical measures that
permit ensuring an adequate level of protection of your personal data, such the
use of Standard Contractual Clauses approved by the European Commission and/or
ensuring certification with the EU-U.S. Privacy Shield and Swiss-U.S. Privacy
Shield Frameworks.
Moreover, we participate in and have certified our compliance with the
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Frameworks (https://www.privacyshield.gov/).
Wise Technologies is committed to subjecting all personal data received from
European Union (EU) member countries, Switzerland, and the United Kingdom, in
reliance on the Privacy Shield Framework, to the Framework’s applicable
Principles. To learn more about the Privacy Shield Framework, visit the U.S.
Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list
Wise Technologies is responsible for the processing of personal data it
receives, under the Privacy Shield Framework, and subsequent transfers to a
third party acting as an agent on its behalf. Wise Technologies complies with
the Privacy Shield Principles for all onward transfers of personal data from
the EU, Switzerland, and the United Kingdom, including the onward transfer
liability provisions.
For personal data covered by Privacy Shield, you can opt-out of whether
such personal data is disclosed to a third-party (apart from service providers)
or is to be used for a purpose that is materially different for the purpose for
which it was originally collected or subsequently authorized. You can contact Wise
Technologies at info_wise@wise-t.com to make such
choices.
With respect to personal data received or transferred pursuant to the
Privacy Shield Framework, Wise Technologies is subject to the regulatory
enforcement powers of the U.S. Federal Trade Commission. In certain situations,
Wise Technologies may be required to disclose personal data in response to
lawful requests by public authorities, including to meet national security or
law enforcement requirements.
Under certain conditions, more fully described on the Privacy Shield
website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint,
you may invoke binding arbitration when other dispute resolution procedures
have been exhausted.