Privacy & Safety Policy

WE CARE ABOUT YOUR PRIVACY

What Would The 1% Do, is committed to respect your privacy and to comply with applicable data protection and privacy laws. This privacy policy describes how we collect and use personal data where What Would The 1% Do is the data controller or where we refer to the applicability of this Policy. “Personal data” means information relating to you or another identifiable individual.

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We will give you additional privacy information that is specific to a product or service in Supplements to this Policy and other notices you may see while using our products or services. If there is a difference between such notices and this Policy, the notices should be considered first. Software on your device may access your information. Our products or services may contain links to, or may be embedded within, other companies’ websites and services that have privacy policies of their own. Where our products or services are embedded to products and services of our customers, we require our customers to provide necessary transparency to you. This might include linking to this Policy and the relevant Supplements, or providing the transparency in integrated and embedded notices which identify us as the service provider or controller.

If you do not agree with this Policy, do not use our products and services or provide What Would The 1% DO with your personal data.

What information do we collect?

We collect your personal data and other information when you make a purchase, use or register into our products and services, take part in campaigns or research or otherwise interact with us. This includes following categories:

Product and service activations

What Would The 1% Do products and services may require electronic activation, where your device and application type, as well as unique device, application, network and subscription identifiers are sent to What Would The 1% Do.

Use of products and services

When you access our services online, our web servers automatically create records of your visit. These records typically include IP-address, access times, the sites linked from, pages visited, the links and features used, the content viewed or requested, browser or application type, language and other such information. Our applications may contact our servers periodically, for example to check for updates or to send us information relating to service usage. Additionally, we may invite you to join voluntary product and service improvement or research programs where detailed information is collected.

Information you provide us with

When you create an account, make a purchase, request services, participate in research or campaigns or otherwise interact with us, we may ask for information such as your name, email address, phone number, street address, user names and passwords, feedback, information relating to your devices, age, gender, and language, bank account number, credit card details and other such financial information. We also maintain records of your consents, preferences and settings relating to, for example, location data, marketing and sharing of personal data.

Your transactions with us

We maintain records of your purchases, downloads, the content you have provided us with, your requests, agreements between you and What Would The 1% Do, the products and services provided to you, payment and delivery details, your contacts and communications and other interactions with us. We may, in accordance with applicable law, record your communication with our customer care or with other such contact points.

Positioning and Location data

Location-based services establish location through the use of satellite, mobile, Wi-Fi, Bluetooth Low Energy (“BLE”) or other network based positioning methods. These technologies may involve exchanging your location data and unique device and mobile, Wi-Fi, Bluetooth, or other network related identifiers with What Would The 1% Do. Our products may operate on multiple device platforms, applications and services which may also collect your location data. We do not use this information to identify you personally without your consent. When you use our location based services and features, for example location based search, navigation and routing, or request for map data, your location data is sent to What Would The 1% Do to serve you with the right content, which may also include location based advertising.

Information provided by partners

We obtain information from industry partners and a variety of other sources, including publicly available sources such as business registries. We require these sources to comply with applicable laws with regard to collecting and transferring this data to us, including ensuring that there is a legal basis for the transfer or anonymizing the data in accordance with applicable laws prior to disclosure of the data to us.

Why do we process Personal Data?

What Would The 1% Do may process your personal data for the following purposes. One or more purposes may apply simultaneously.

Providing products and services

We may use your personal data to provide you with our products and services, to process your requests or as otherwise may be necessary to perform the contract between you and What Would The 1% Do, to ensure the functionality and security of our products and services, to identify you as well as to prevent and investigate fraud and other misuses.

Accounts

Some services may require an account to help you manage your content and preferences. Depending on the service, an account creation may be either required or voluntary. Account creation requires you to provide us with basic contact details about yourself, such as name, email address, country of residence and date of birth. You may also be able to voluntarily provide more information about yourself while creating a profile, such as a photo or avatar of your choice.

Developing and managing products and services

We may use your personal data to develop and manage our products, services, customer care, sales and marketing. We may combine personal data collected in connection with your use of a particular What Would The 1% Do product and/or service with other personal data we may have about you, unless such personal data was collected for a purpose, where the original purpose is incompatible with this purpose.

Communicating with you

We may use your personal data to communicate with you, for example to inform you that our services have changed or to send you critical alerts and other such notices relating to our products and/or services and to contact you for customer care related purposes.

Marketing, advertising and making recommendations

We may contact you to inform you of new products, services or promotions we may offer and to conduct market research when we have your consent or it is otherwise allowed. We may use your personal data to personalize our offering and to provide you with more relevant services, for example, to make recommendations and to display customized content and advertising in our services. This may include displaying What Would The 1% Do and third party content.

What is our legal basis for processing your Personal Data?

Our legal basis for processing your personal data is dependent on the purpose for processing and may vary as described in the Supplement applicable to the product or service you are using. In general, we process your personal data under the following legal bases:

Performance of a contract with you

We process your personal data to perform our obligations under the Service Terms applicable to the product or service you are using, provided by us or our customers.

Legal obligations

We process your personal data as needed to comply with laws and regulations.

Legitimate interests

We process your personal data to further our legitimate interests, such as in connection with managing, developing, testing, securing, and in limited circumstances marketing, advertising, and making recommendations regarding our products and services. Any such processing is conducted subject to appropriate measures to protect your fundamental rights and freedoms related to your personal data, and in any event will be subject to the restrictions provided in this Policy. Further information or specification of our legitimate interests may be provided in relevant Supplements applicable to the product or service.

How long do we retain Personal Data?

We endeavor to only collect personal data that are necessary for the purposes for which they are collected, and to retain such data for no longer than is necessary for such purposes. The length of time personal data is retained, and criteria for determining that time, are dependent on the nature of the personal data and the purpose for which it was provided. For example, for your personal data related to managing your account (such as name, email address, and account content and preferences) are maintained for as long as they are retained by you within your account. Other data, such as records of your activity within the application, are typically maintained only for a short period before being anonymized or pseudonymized. Additional information may be provided in the Supplement applicable to the product or service you are using.

Do we share Personal Data?

We do not sell, lease, rent or otherwise disclose your personal data to third parties unless otherwise stated below.

Your consent and social sharing services

We may share your personal data if we have your consent to do so. Some services may allow you to share your personal data with other users of the service or with other services and their users. Please consider carefully before disclosing any personal data or other information that might be accessible to other users.

What Would The 1% Do companies and authorized third parties

We may share your personal data with other What Would The 1% Do companies or authorized third parties who process personal data for What Would The 1% Do for the purposes described in this Policy. This may include for example billing through your network service provider or otherwise, delivery of your purchases, providing services including customer service, managing and analyzing consumer data, credit checks, conducting research and managing marketing and other such campaigns. When you purchase a What Would The 1% Do product from us with a network service provider plan, we may need to exchange information with your network service provider to provide you with such service.

We may conduct joint marketing and other communications with our partners, for example your mobile operator. To avoid duplicate or unnecessary communications and to tailor the message to you we may need to match information that What Would The 1% Do has collected with information that the partner has collected where this is permitted by law.

These authorized third parties are not permitted to use your personal data for any other purposes. We bind them contractually, require them to act consistently with this Policy and to use appropriate security measures to protect your personal data.

International transfers of personal data

Our products and services may be provided using resources and servers located in various countries around the world. Therefore your personal data may be transferred across international borders outside the country where you use our services, including to countries outside the European Economic Area (EEA) that do not have laws providing specific protection for personal data or that have different legal rules on data protection, for example, the United States of America. In such cases we ensure that there is a legal basis for such a transfer and that adequate protection for your personal data is provided as required by applicable law, for example, by using standard contractual clauses approved by the European Commission or relevant authorities (where necessary) and by requiring the use of other appropriate technical and organizational information security measures.

Mandatory disclosures

We may be obligated by mandatory law to disclose your personal data to certain authorities or other third parties, for example, to law enforcement agencies in the countries where we or third parties acting on our behalf operate. We may also disclose and otherwise process your personal data in accordance with applicable law to defend What Would The 1% Do legitimate interests, for example, in legal proceedings or in connection with governmental requests and filings.

Mergers and Acquisitions

If we decide to sell, buy, merge or otherwise reorganize our businesses in certain countries, this may involve us disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and their advisers.

How do we address the privacy of children?

What Would The 1% Do products and services are typically intended for general audiences. What Would The 1% Do does not knowingly collect information of children without the consent of their parents or guardians.

How do we address Data Quality?

We take reasonable steps to keep the personal data we possess accurate and to delete incorrect or unnecessary personal data. We encourage you to access your personal data through your account from time to time to ensure that it is up to date.

What steps are taken to safeguard Personal Data?

Privacy and security are key considerations in the creation and delivery of our products and services. We have assigned specific responsibilities to address privacy and security related matters. We enforce our internal policies and guidelines through an appropriate selection of activities, including proactive and reactive risk management, security and privacy engineering, training and assessments. We take appropriate steps to address online security, physical security, risk of data loss and other such risks taking into consideration the risk represented by the processing and the nature of the data being protected. Also, we limit access to our data bases containing personal data to authorized persons having a justified need to access such information.