Privacy Notice

PLEASE READ THESE LICENCE TERMS CAREFULLY

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in this notice and it is important that you read that information.

Important information and who we are

Mafavi Ventures Ltd (trading as Wemby) is the controller and is responsible for your personal data (collectively referred to as “Wemby”, “we”, “us” or “our” in this policy).

You have the right to make a complaint at any time to the Data Protection Authority applicable to your location.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy notice under regular review.

This version was last updated on 16 August 2020. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App.

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 our relationship with you.

Third party links

Wemby’s App may, from time to time, contain links to and from the websites of its partners, affiliates and third parties it engages with. Please note that these websites and any services that may be accessible through them have their own privacy notices and that Wemby does not accept any responsibility or liability for these notices or for any personal data that may be collected or processed through these websites or services, such as contact and location data. Please read these notices before you submit any personal data to these websites or use these services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Identity Data.

  • Contact Data.

  • Financial Data.

  • Transaction Data.

  • Device Data.

  • Content Data.

  • Profile Data.

  • Usage Data.

  • Marketing and Communications Data.

  • Location Data

  • Special Categories of Personal Data about: information about your health

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 App 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 notice.

CookiesHow is your personal data collected?

We will collect and process the following data about you:

  • Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App and when using the Services or by corresponding with us (for example, by email). It includes information you provide when you register to use the App, download or register the App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App’s social media functions, enter a competition, promotion or complete a survey, select content from the newsfeed, book a session, have a video session and when you report a problem with the App or our Services. If you contact us, we will keep a record of that correspondence.

  • Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.

  • Location Data. We also might use GPS technology OR other technologies to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings sending an email to help@wemby.co

  • Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below :

  • Device Data from the following parties: analytics providers such as Google based inside the EU;

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based inside the EU;

  • Identity and Contact Data from publicly available sources such as Companies House and the electoral register based inside the EU;

Cookies

We use cookies [and/or other tracking technologies] to distinguish you from other users of the App, the distribution platform (Appstore) or Services and to remember your preferences. This helps us to provide you with a good experience when you use the App and also allows us to improve the App and our Services. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • Where you have consented before the processing.

  • Where we need to perform a contract we are about to enter or have entered 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 or regulatory obligation.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

Purposes for which we will use your personal data

Purpose/activity

Type of data

Lawful basis for processing

To install the App and register you as a new App user

Identity

Contact

Financial

Device

Your consent

To process in-App purchases and deliver Services including managing payments and collecting money owed to us

Identity

Contact

Financial

Transaction

Device

Marketing and Communications

Location

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you including notifying you of changes to the App or any Services

Identity

Contact

Financial

Profile

Marketing and Communications

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

To enable you to participate in a prize draw, competition or complete a survey

Identity

Contact

Device

Profile

Marketing and Communications

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

To administer and protect our business and this App including troubleshooting, data analysis and system testing

Identity

Contact

Device

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

To deliver content and advertisements to you

To make recommendations to you about goods or services which may interest you

To measure and analyse the effectiveness of the content we serve you

To monitor trends so we can improve the App

Identity

Contact

Device

Content

Profile

Usage

Marketing and Communications

Location

Consent

Necessary for our legitimate interests (to develop our products/Services and grow our business)

To share your special category data:

  • With your consent

  • Where there is a concern about your or someone else’s safety

  • If there is a legal obligation to do so

Identity

Contact

Health

Your explicit Consent

Protect the vital interest of you or of another person

Necessary for the purposes of preventive or occupational medicine, medical diagnosis, the provision of health or social care or treatment

Necessary for the establishment, exercise or defence of legal claims 

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:

  • Internal Third Parties

  • External Third Parties

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy, save your Special Category Data which requires your explicit consent.

  • Eb2 – Evidence Based Behaviour SL.

International transfers

Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

  • Where we use certain service providers, we may use specific contracts (Model contracts) approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access the App or the Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. Storage on encrypted servers using AES256 algorithms and compliant with ISO 27001, ISO 27017 and ISO 270188 security standards.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.

In some circumstances you can ask us to delete your data: see [Your legal rights] below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the App for a period of 18 months then we will treat the account as expired and your personal data may be deleted.

Your legal rights

Under certain circumstances you may have the following rights under data protection laws in relation to your personal data:

Your right of access

  • You have the right to ask us for copies of your personal data. This right always applies. There are some exemptions, which means you may not always receive all the information we process. 

 

Your right to rectification

  • You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. 

 

Your right to erasure

  • You have the right to ask us to erase your personal information in certain circumstances. 

 

Your right to restriction of processing

  • You have the right to ask us to restrict the processing of your information in certain circumstances. 

 

Your right to object to processing

  • You have the right to object to processing if we are able to process your information because the processing is in our legitimate interests. 

 

Your right to data portability

  • This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. 

 

Your right to withdraw consent

  • This applies to information that we are processing under the lawful basis of consent.

 

You can exercise any of these rights at any time by contacting us at info@wemby.co.