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Privacy Policy

Last edited: February 3, 2020

Wana Family Network PBC, a Delaware public benefit corporation, respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our Site (regardless of where you visit it from) and/or access or use our Services and tell you about your privacy rights and how the law protects you. Any terms not defined here shall have the definition provided in the Terms of Use, available here.

1.  IMPORTANT INFORMATION AND WHO WE ARE

YOUR LEGAL RIGHTS

You have the right to:

  • Opt-out of marketing emails and other direct marketing.
  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You can withdraw your consent, for example, by turning off GPS location sharing in your Device settings.
PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Wana Family Network PBC collects and processes your personal data through your use of its Site, including, without limitation, any data you may provide through the Site when you sign up for our Services or otherwise when you use or access or Services.

While the Site and Services relate to children, the use and access of the Site and Services is not intended for children and we do not collect data relating to children without your knowledge or except as provided by this privacy policy.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. The supplement for California residents is available here, and the supplement for Nevada residents is available here. References to privacy policy herein shall mean to include any other privacy policies and/or notices of the Company that are relevant.

CONTROLLER

Wana Family Network PBC, a Delaware public benefit corporation, is the controller and responsible for your personal data (collectively referred to as “Company”, “we”, “us”, or “our” in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Wana Family Network PBC
Name of DPO: Erin Beck
Email address: privacy@wanafam.ly
Postal address: 3371 Glendale Blvd., #124, Los Angeles, CA 90039, United States

If you are subject to the GDPR and/or UK Data Protection Act 2018, you may also contact your local data protection authority within the European Economic Area for unresolved complaints (for example, the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk)). We would, however, appreciate the chance to deal with your concerns before you approach your local data protection authority so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We may update our privacy policy from time to time. If we make material changes to how we treat your personal data, we will post the new privacy policy on this page, and we may also send a courtesy email to you to the email address we have on file for you, if any. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting this privacy policy to check for any changes.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

The Site may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every webpage you visit.

2.  THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). References herein to your personal data or personal data shall mean, as relevant, the personal data of your children and/or dependents. We may collect, use, store and transfer different kinds of personal data about you and/or your children and/or dependents which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth, and gender.
  • Contact Data includes billing address, delivery address, email address, and telephone numbers.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
  • Usage Data includes information about how you use our Site, products, and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

AGE LIMITS

We do not knowingly collect or solicit personal data from or direct or target interest-based advertising to anyone under the age of 13 or knowingly allow such persons to use or access the Services and/or the Site. If you are under 13, please do not send any data about yourself to us, including your name, address, or email address. No one under the age of 13 may provide any personal data. If we learn that we have collected personal data from a child under age 13, we will delete that data as quickly as possible. If you believe that we might have any data from a child under the age of 13, please contact us.

Notwithstanding the foregoing, we may request personal data of your children and/or dependents as you may elect to provide and share with potential caregivers through the Site. By providing such personal data, you warrant and represent that you have the right to provide such data and you consent to our use of such data in accordance with our privacy policy.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Services). In this case, we may have to cancel a Service you have with us but we will notify you if this is the case at the time.

3.  HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including:

  • Directly from you when you provide it to us;
  • Automatically when you use the Site and/or Services; and
  • Data we collect from our partners.

Information You Provide to Us
You may give us your, your children’s, and/or your dependents’ Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you use or access our Services; create an account on our Site; subscribe to our publications; request marketing to be sent to you; enter a competition, promotion, or survey; or give us feedback or contact us.

Your User Contributions may be published or posted publicly and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Automatic Information Collection and Tracking
When you download, install, register with, access, and use the Site and/or Services, it may use technology to automatically collect:

  • Usage Data. When you access and use the Site and/or Services, we may automatically collect certain details of your access to and use of the Services, including traffic data, usage data, location data, logs, and other communication data and the resources that you access and use on or through the Services;
  • Technical Data. We may collect information about your Device and internet connection, including the Device’s unique device identifier, IP address, operating system, browser type, mobile network information, device (including operating system) language; and
  • Location Information. The Services and/or the Site may collect real-time information about the location of your Device. You can disable this function in the settings of your Device, but some parts of the Services and/or the Site may then not function properly.

You acknowledge and accept that the Services have certain content, features, functionality and/or services that are based on geolocation, location tracking, and geofencing which may also be collecting information on your use and access of the Services, including information on your surroundings and background. You can disable this function in the settings of your Device, but some parts of the Services and/or the Site may then not function properly. If you do not want us to collect this information, do not download, install, register with, use or access the Services and/or the Site, or delete it from your Device.

Information Collection and Tracking Technologies
The technologies we use for automatic information collection may include:

  • Cookies (or mobile cookies). A cookie is a small file placed on your Device. Like most online services, we and our partners use cookies and similar technologies to provide and personalize the Services and/or the Site, analyze use, and prevent fraud. You can disable cookies in your settings, but some parts of the Services and/or the Site may then not function properly; and
  • Web Beacons. Parts of the Services and/or the Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related Services and/or Site statistics (for example, recording the popularity of certain Services and/or Site content, features, functionality, and services, and verifying system and server integrity).

Data We Collect From Our Partners
We also collect the following data from our partners: demographic data (such as to determine the coarse location of your IP address); data to fight fraud (such as refund abuse or click fraud); data from platforms that the Services run on (such as to verify payment); and data for analytics purposes, so we can provide you with better services.

Third-Party Information Collection
When you use or access the Services and/or the Site or its/their content, certain third parties may use automatic information collection technologies to collect information about you or your Device, or you may otherwise be accessing and using third-party platforms, software, and applications. These third parties may include, without limitation: media platforms and services; analytics companies; your Device manufacturer; your vendor.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about a third party’s processing of your information, you should contact the responsible provider directly. You acknowledge and agree that your access and use of such third party tools may be subject to their respective terms of use and privacy policies.

4.  HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: where we need to perform the contract we are about to enter into or have entered into with you; where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; where we need to comply with a legal obligation.

We process your personal data for the following purposes:

To make the Services and/or the Site work.
To perform the contract, we process data necessary to:

  • Create accounts and allow you to use the Services, access its contents, features, functionality, and services, and to access or use the Site;
  • Operate our Services;
  • Verify and confirm payments;
  • At our discretion, provide and deliver products, services, and any other information you reasonably request;
  • Send you Services- and/or Site-related communications, such as when updates are available, and of changes to any products or services we offer or provide through the Services and/or the Site;
  • Fulfill any other purpose for which you provide the information;
  • Give you notices about your account; and
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

To make the Services and/or the Site more suitable for our users.
To provide a great application and/or Site to our users, we have a legitimate interest to collect and process necessary data to:

  • Update and develop user profiles;
  • Develop and improve the Services and/or the Site and user experience;
  • Manage our relationship with you;
  • Provide social features as part of the Services and/or the Site;
  • Customize the Services and/or the Site experience according to your individual interests, such as through storing information about your preferences and recognizing you when you use or access the Services and/or the Site;
  • Respond to your comments and questions and provide user support;
  • Provide you offers in the Services and/or the Site as well as in other websites and services, and by email;
  • Send you related information, such as updates, security alerts, and support messages;
  • Enable you to communicate with other users;
  • Speed up your searches.

To keep the Services and/or the Site safe and fair.
For more information on our prohibited uses policy, see our Terms of Use. In order to keep the Services and/or the Site and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to:

  • Analyze and monitor use of the Services and/or the Site and its social features;
  • Moderate chats, forums, and other social interaction platforms either automatically or manually;
  • Take action against fraudulent or misbehaving users.

To analyze, profile, and segment.
In all of the above cases and purposes, we may analyze, profile, and segment all collected data, including for the purpose of estimating our audience size and usage patterns.

With your consent.
With your consent, which is implied herein, we may process your data for additional purposes, such as personalized tips to improve your experience.

MARKETING & PROMOTIONAL OFFERS FROM US

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from or through us and you have not opted out of receiving that marketing.

5.  DISCLOSURES OF YOUR PERSONAL DATA

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

In addition, we may disclose personal information that we collect or you provide:

  • To our subsidiaries and affiliates;
  • To contractors, vendors, and other third parties we use to support our business and/or with which we integrate or link to deliver you the Services, its content, features, functionality, and services and/or with which you use the Services, and who may access your data and operate under their own respective terms of use and privacy policies. We encourage you to check their respective terms of use and privacy policies to learn more about their data processing practices;
  • To a buyer, investor, or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets or stock, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about the Services and/or the Site users is among the assets transferred;
  • To fulfill the purpose for which you provide it;
  • For any other purpose disclosed by us when you provide the information;
  • With your consent;
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request, including in order to combat fraud and illegal activity;
  • To enforce our rights arising from any contracts entered into between you and us; and
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

6.  INTERNATIONAL TRANSFERS

The Services, the Site, and its services may be accessed globally (despite the geographic restrictions provided in the Terms) and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than the United States (or your own country, if you are using the Services and/or the Site outside of the United States, despite the geographic restrictions provided in the Terms), we take steps to ensure adequate safeguards are in place to protect your data as explained in this privacy policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers in and to the United States.

7.  DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Unfortunately, however, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Services and/or the Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

8.  DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We retain your data for as long as your account is active or you are otherwise accessing and use the Services and/or the Site or as needed to provide you the Services and/or the Site. We will, for example, periodically de-identify unused accounts, and we regularly review and de-identify unnecessary data. You have the right to request erasure of your personal data. Note that if you ask us to remove your personal data, we may be required to retain certain data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements; you will be notified in such a case.

9.  YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please contact us the DPO at the contact information provided above.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please let us know.