Privacy policy
Last update: 30 August 2023
Wiser’s Privacy Policy
1 INTRODUCTION
1.1 Important information and who we are
Welcome to WISER MEDIA LABS LIMITED’s Privacy and Data Protection Policy (“Privacy Policy”).
At WISER MEDIA LABS LIMITED (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.
This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.
The individuals from which we may gather and use data can include: Customers
Third parties connected to your customers
and any other people that the organisation has a relationship with or may need to contact.
This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.
1.2 Who is Your Data Controller
WISER MEDIA LABS LIMITED is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us by email at [email protected] or sent in a letter to Soho Works at 180 Strand, London.
You have the right to make a complaint at any time to 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 the ICO so please contact us in the first instance.
1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you
In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:
Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases);
Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
Maintain a record of all categories of processing activities carried out on behalf of a Controller;
Cooperate, on request, with the supervisory authority in the performance of its tasks;
Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
Notify the Controller without undue delay after becoming aware of a Personal Data Breach;
2 LEGAL BASIS FOR DATA COLLECTION
2.1 Types of Data / Privacy Policy Scope
“Personal Data” 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).
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:
Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
Usage Data: information about how you use our website, products and services. We also collect, use and share Aggregated Data such as We also collect use and share
Aggregated Data such as post, curation and category preferences. . 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. 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.
We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
2.2 The Legal Basis for Collecting That Data
There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:
“Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
“Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
“Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
“Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.
3 HOW WE USE YOUR PERSONAL DATA
3.1 Our Uses
We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.
Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.
Activity: when a user signs up and spends time in an API integrated content
Types of data: Profile/Identity Data, Marketing and Communications Data andTechnical Data Usage Data
Legal Justification: Consent
Lawful basis for processing data: We keep your personal data only as long as necessary to provide you with the WISER Services and for legitimate and essential business purposes, such as maintaining the performance of the WISER Services, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes.
Consent
We keep your personal data only as long as necessary to provide you with the WISER Services and for legitimate and essential business purposes, such as maintaining the performance of the WISER Services, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes.
3.2 Marketing and Content Updates
You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.
3.3 Change of Purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4 YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US
4.1 What Control Do I Have Over WISER MEDIA LABS LIMITED’s Use Of My Personal Data?
Access - You always have the right to receive information about the Processing of data that concerns you. We only provide information if we have been able to verify that it is you that are requesting the information.
Rectification - If you find that the Personal Data we process about you is incorrect, let us know and we will fix it!
Erasure - Do you want us to completely forget about you? You have the right to be forgotten and request deletion of your Personal Data when the Processing is no longer necessary for the purpose for which it was collected. If we are required to retain your information under applicable law or a contract that we have entered with you, we will ensure that it is processed only for the specific purpose set forth in such applicable law or contract. We will thereafter erase the information as soon as possible.
Objections - Do you disagree with our assessment that a legitimate interest for Processing your Personal Data overrides your interest in protecting your privacy? Don’t worry - in such case, we will review our legitimate interest assessment. Of course, we add your objection to the balance and make a new assessment to see if we can still justify our Processing of your Personal Data. If you object to direct marketing, we will immediately delete your personal information without making an assessment.
Restriction - You can also ask us to restrict our Processing of your Personal Data.
Whilst we are Processing a request from you for any of your other rights;
If, instead of requesting erasure, you want us to limit the Processing of Personal Data for a specific purpose. For example, if you do not want us to send advertising to you in the future, we still need to save your name in order to know that we should not contact you; or
In cases where we no longer need the information in relation to the purpose for which it was collected, provided that you do not have an interest in retaining it to make a legal claim.
Data portability - We may provide you with the data that you have submitted to us or that we have received from you in connection with a contract that we have entered with you. You will receive your information in a commonly used and machine-readable format that you can transfer to another personal data manager.
Withdraw consent - If you have given consent to one or several specific processing(s) of your Personal Data, you have the right to withdraw your consent at any time and thus ask us to terminate the Processing immediately. Please note that you can only withdraw your consent for future processing of Personal Data and not for Processing that has already taken place.
4.2 Location and Data Protection Rights
Your EEA, UK, and Swiss Rights
If you are located in the European Economic Area (EEA), the UK or Switzerland, you have the following privacy rights:
You can access, correct, update, or delete your personal information.
You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
If you do not want us to use your email address to promote our own or third parties’ products or services, you can opt-out of receiving marketing emails at any time.
If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Contact details are available here.
Your California Privacy Rights
This Section of our Privacy Policy provides information for California consumers, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”).
You may request access to, or for a copy of the personal information we have collected, used, disclosed, and sold about you over the past twelve (12) months.
You may also request that we delete certain personal information we have collected from you.
You have a right not to receive discriminatory treatment for the exercise of your CCPA privacy rights
You can request, under California Civil Code Section 1798.83, certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.
California consumers have the right to opt-out of the sale of their personal information. We do not and will not sell your personal information. We may provide third parties with certain personal information to provide or improve our products and services, for example to deliver services at your request. In such cases, we require those third parties to handle the information in accordance with applicable laws and regulations.
California privacy laws also require that we provide California consumers information about how we use their personal information, whether collected online or offline. This document and specifically the sections above are intended to satisfy that requirement. If you are a California resident and would like a copy of this notice, please submit a written request to [email protected].
Your Canadian Privacy Law Rights
If your information is collected from within Canada, you have the following privacy rights:
You can access, correct, update, or delete your personal information.
If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time.
If you wish to make a complaint about a breach of Personal Information Protection and Electronic Documents Act (PIPEDA), please contact us using the details below and we will take reasonable steps to investigate the complaint and respond to you. If after this process you are not satisfied with our response, you can submit a complaint to the Office of the Privacy Commissioner of Canada.
4.2 How Does WISER MEDIA LABS LIMITED Protect Customers' Personal Data?
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems, including Organisational security measures are measures that are implemented in work methods and routines within the organisation such as login and password management. Technical security measures are measures implemented through technical solutions such as but not limited to; encryption, access control level, access log, firewall, back-up and regular security inspection . Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of WISER MEDIA LABS LIMITED to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
4.3 Opting Out Of Marketing Promotions
You can ask us to stop sending you marketing messages at any time by We have an unsubscribe from e-mails option from our newsletters. .
Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.
4.4 How to Request your Data and the Process for Obtaining it
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure you have the 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.
5 YOUR DATA AND THIRD PARTIES
5.1 Will We Share Your Data With Third Parties?
We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors or affiliates (subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions).
We may also share Personal Data with interested parties in the event that WISER MEDIA LABS LIMITED anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.
If WISER MEDIA LABS LIMITED is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).
We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.
5.2 Third-Party Links
This 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 website you visit.
6 HOW LONG WILL WE RETAIN YOUR DATA FOR?
We keep your personal data only as long as necessary to provide you with the WISER Services and for legitimate and essential business purposes, such as maintaining the performance of the WISER Services, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal data for as long as you are a user of the WISER Services. For example, we keep your posts, curations, and account information.
If you request, we will delete or anonymise your personal data so that it no longer identifies you, unless we are legally allowed or required to maintain certain personal data, including situations such as the following: Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users
We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
7 AGE LIMIT FOR OUR USERS
You must not use WISER MEDIA LABS LIMITED unless you are aged 12 or older. If you are under 12 and you access WISER MEDIA LABS LIMITED by lying about your age, you must immediately stop using WISER MEDIA LABS LIMITED.
This website is not intended for children and we do not knowingly collect data relating to children.
8 INTERNATIONAL TRANSFER OF DATA
In order to run our business, we may need help from others who will process Personal Data on our behalf, so-called Processors.
In cases where our Processors transfer Personal Data outside the EU/EEA, we have ensured that the level of protection is adequate, and in compliance with Applicable Law, by controlling that either of the following requirements are fulfilled:
● the EU Commission has determined that the level of protection is adequate in the third country where the data is processed;
● the Processor has signed up to the EU Commission’s standard contract clauses (SCCs) for data transfer to non-EU/EEA countries; or
● the Processor has taken other appropriate safeguards prior to the transfer and that such safeguards comply with Applicable law.
We have entered into Data Processing Agreements (DPA) with all our Processors. The DPA sets out, among other things, how the Processor may process the Personal Data and what security measures are required for the Processing.
We may also need to disclose your personal information to certain designated authorities in order to fulfill obligations under applicable law or legally binding judgements.
Our processors
Processor: Google Analytics
Personal data being processed: Name, IP-number, user behavior, e-mail address
Instructions: Data Storage, Processing, Analysis
9 NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY
We keep our Privacy Policy under review and will place any updates on this webpage. This version is dated 30 August 2023. By using WISER MEDIA LABS LIMITED, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of WISER MEDIA LABS LIMITED will constitute your express acceptance of any modifications to this Privacy Policy.
10 INTERPRETATION
All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.).
Our staff are not authorised to contract on behalf of WISER MEDIA LABS LIMITED, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a WISER MEDIA LABS LIMITED address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any WISER MEDIA LABS LIMITEDrights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the WISER MEDIA LABS LIMITED legal department.
11 TERMS OF USE
Please also see our Terms of Use (https://wisermedia.com/privacy-policy-gdpr) which set out the terms, disclaimers, and limitations of liability governing your use of WISER MEDIA LABS LIMITED.
12 CONTACT
If we don’t keep our promiseIf you think that we are not Processing your Personal Data correctly, even after you have notified us of this, you are always entitled to submit your complaint to the Information Commissioner’s Office (ICO).
More information about our obligations and your rights can be found at wisermedia.com.
You can contact the authority via e-mail at: [email protected]