WOOSH5 Privacy Policy Last Updated: June 1, 2019
This Privacy Policy describes how WOOSH5 Holding B.V., WOOSH5 Inc. and WOOSH5 ASIA Ltd. Ptd. (“WOOSH5”, “we,” “us” or “our”) collects, uses, and shares information about you and the choices you have regarding this information. This Privacy Policy applies to the information we collect when you access or use our products, services, and technology platforms (including, without limitation, our websites, mobile applications, and other WOOSH5-controlled properties that link to this Privacy
Policy) (collectively, the “Services”). Please note that this Privacy Policy does not apply to your use of third-party sites, services, or applications you may access through our Services. We encourage you to review the privacy policies of those third parties for more information regarding their privacy practices.
CHANGES TO THIS PRIVACY POLICY
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy. In some cases, we may provide you with additional notice, such as adding a statement to our homepage or sending you an email notification. We encourage you to review the Privacy Policy whenever you access the Services to stay informed about our information practices and the choices available to you.
COLLECTION OF INFORMATION
Information You Provide to Us
We collect information you provide directly to us when using the Services. For example, we collect information when you download our mobile application(s), register for our Services, sign up for an account, complete a quiz, questionnaire or other form, participate in any interactive features of the Services including any video or audio call features we provide, apply for a job or to become a coach, request customer support, or otherwise communicate with us. The types of information we may collect include your name, email address, mailing and billing address, user ID, work experience and education, and payment information, and any other information you choose to provide.
Information About Interactions with the Services
In addition to the information above, you may provide us additional information to help us identify the best coach for you or in conjunction with your coaching sessions. For example, you may provide information about your title, employment details, language, gender, marital status, nationality, or other information about you and your personal or professional experiences. We also collect information about your use of the Services such as how often you use the coaching services, development programs planned and attended, engagement status, and session ratings.
Information We Collect Automatically When You Use the Services
When you access or use the Services, we automatically collect information about you, including the following:
-Log Information: We log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to the Services.
-Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
-Information Collected by Cookies and Other Tracking Technologies: We use different technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies, and how to disable them,
please see “Your Choices” below.
-Information We Collect From Other Sources
We may also obtain information from other sources, such as list providers and publicly available sources, and combine that with information we collect through the Services. We also may receive information about you from the coaches with whom you interact through the Services.
USE OF INFORMATION
We may use the information we collect to provide, maintain, and improve the Services, including to assess and improve the quality of the coaching services. We may also use the information we collect to:
- Provide and deliver the products and services you request, process transactions, and send you related information;
- Verify your identity and, if applicable, authorize you to use the Services (such as from your employer);
- If you are a coach or employee, determine your compensation and to compensate you;
- Respond to your comments, questions, and requests;
- Send you technical notices and other administrative messages;
- Communicate with you about products, services, offers, promotions, rewards, and events offered by us or others, and provide news and information we think will be of interest to you;
- Monitor and analyze trends, usage, and activities in connection with the Services;
- Conduct research, analysis, and surveys;
- Personalize and improve the Services and provide content or features that match user profiles or interests;
- Carry out any other purpose for which the information was
SHARING OF INFORMATION
When you use the Services, we may share information about you with our coaches so that they can provide services to you. With your consent we may also share information relating to your use of the Services with your employer or other entity who has sponsored your use of the Services, such as the program you selected and how you used the Services (such as the number of sessions you attended) but only when we have your consent to do so or as necessary to protect the rights, property, or safety of others. In all other cases your use of the platform will be fully anonymous.
We may however share or transfer information about you as follows or as otherwise described in this Privacy Policy:
- With vendors, consultants, and other service providers who need access to such information to carry out work on our behalf;
- In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation;
- If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property, and safety of you, us, or others;
- In connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company; and
- With your consent or at your direction, including if we notify you through the Services that certain information you provide will be shared in a particular manner and you provide this information.
- We may also share aggregated or de-identified information, which cannot reasonably be used to identify
ANALYTICS SERVICES
We may allow others to provide analytics services on our behalf. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by WOOSH5 and others to, among other things, analyze and track data and better understand your online activity.
TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES
We are based in Europe, the United States and Asia and the information we collect is governed by the respective laws. In Europe we are governed by the GDPR laws as from 2018. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the United States and other countries, where you might not have the same rights and protections as you do under local law.
In connection with the processing of all personal data we receive from the EU or Switzerland (“European Data”), we adhere to the EU-U.S. Privacy Shield Framework Principles and the Swiss-U.S. Privacy Shield Framework Principles issued by the U.S. Department of Commerce (collectively, the “Principles”). For more information about the Principles, please visit the Department of Commerce’s Privacy Shield Website.
The General Data Protection Regulation (GDPR) is a set of laws due to be enacted in the EU in 2018. Privacy Shield is an agreement between the EU and US allowing for the transfer of personal data from the EU to US.
The GDPR has specific requirements regarding the transfer of data out of the EU. One of these requirements is that the transfer must only happen to countries deemed as having adequate data protection laws.
In general the EU does not list the US as one of the countries that meets this requirement. Privacy Shield is designed to create an program whereby participating companies are deemed as having adequate protection, and therefore facilitate the transfer of information.
In short, Privacy Shield allows US companies, or EU companies working with US companies, to meet this requirement of the GDPR.
Please direct any inquiries or complaints regarding our compliance with the Principles to the point of contact listed in the “Contact Us” section below. If we do not resolve your complaint, you may submit your complaint free of charge to https://www.jamsadr.com/eu-us-privacy-shield , our designated Privacy Shield dispute resolution provider. Under certain conditions specified by the Principles, you may also be able to invoke binding arbitration to resolve your complaint. We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. If we share European Data with a third-party service provider that processes the data solely on our behalf, then we will be liable for that third party’s processing of European Data in violation of the Principles, unless we can prove that we are not responsible for the event giving rise to the damage.
DATA RETENTION
We store the info we collected about you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
YOUR CHOICES
Your Information
You may update, correct or delete information about you at any time by contacting us at support@woosh5.com . Please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period.
Promotional Communications
You may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us support@woosh5.com . If you opt out, we may still send you non-promotional communications, such as messages about your account or our ongoing business relations.
Mobile Push Notifications/Alerts
With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
EUROPEAN RESIDENTS
If you are a European Resident, defined for the purposes of this Privacy Policy to include residents of European Economic Area and European Free Trade Association, you have certain rights and protections under the law regarding the processing of your personal data.
Legal Basis for Processing
If you are a European Resident, when we process your personal data we will only do so in the following situations:
We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the services you have requested).
We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to our Services, and to provide, secure, and improve our Services.
You have provided consent for us to process your personal data.
Data Subject Requests
If you are a European Resident, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you can log into your account. Alternatively, you may contact us as indicated below.
Questions or Complaints
If you are a European Resident and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection- authorities/index_en.htm .
Contact Information
If you have questions or comments about our Privacy Policy, please email us at support@woosh5.com . WOOSH5, Inc.
2330 Vinemead Ct Katy TX 77450, USA
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