- 1. Introduction
- 2. What Information Do We Collect?
- 3. How Do We Use Your Information?
- 4. Will Your Information Be Shared With Anyone?
- 5. Who Will Your Information Be Shared With?
- 6. A Note For International Users
- 8. How Long Do We Keep Your Information?
- 9. How Do We Keep Your Information Safe?
- 10. What Are Your Privacy Rights?
- 11. Controls For Do-Not-Track Features
- 12. Do California Residents Have Specific Privacy Rights?
- 13. Do We Make Updates To This Notice?
- 14. How Can You Contact Us About this Notice?
- 15. How Can You Review, Update, Or Delete The Data We Collect From You?
- 16. Additional Notices
Last updated on January 1st, 2021.
Thank you for choosing to be part of our community at Wayfyndr, LLC. ( “Wayfyndr”, “we”, “our” or “us”). At Wayfyndr we are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at email@example.com.
2. What Information Do We Collect?
How We Define Personal Data.
Our definition of personal data is based on the privacy laws and regulations of the California Consumer Privacy Act (CCPA) and the General Data Protection Regulation (GDPR). These are widely regarded as the strongest privacy protections in the world. We consider any information about you or your behavior that can be traced back to you as personal data.
Personal information you disclose to us
In short: We collect personal information that you provide to us
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our Services, when you participate in activities on the Services, and when you contact us.
The personal information that we collect depends on the context of your interactions with us, the Website, the Services, the choices you make, and the products and features you use.
Information automatically collected
In short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Website.
We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
- Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
3. How Do We Use Your Information?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
- For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, and to evaluate and improve our Services, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
4. Will Your Information Be Shared With Anyone?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
- Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: data analysis, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data on our behalf about how you interact with our Services over time. Any third parties that are allowed to use tracking technology on the Website, will be disclosed in Section 4, “Who Will Your Information Be Share With?”, below. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
5. Who Will Your Information Be Shared With?
We only share and disclose your information with the following third parties subject to their terms of service and privacy policies. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section below titled “How Can You Contact Us About This Notice?”.
6. A Note For International Users
Our Services are hosted in the United States (“U.S.”) and are intended primarily for and directed primarily to users in the U.S. If you are a user accessing our Services from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure, that differ from U.S. laws, please be advised that (i) your use of our Services, this Privacy Notice, and the Terms of Service are all governed by U.S. law, (ii) you are transferring your personal information to the U.S., and (iii) you fully consent to that transfer and release Wayfyndr from and against any claims relating thereto. If you are located in a country embargoed by the U.S., or are on the U.S. Treasury Department’s list of Specially Designated Nationals you must not engage in any commercial activities on our Services.
A cookie is a small file that can be placed on your device that allows us to recognize and remember you. It is sent to your browser and stored on your computer’s hard drive or tablet or mobile device. When you visit our Services, we may collect information from you automatically through cookies or similar technology, such as a tag, pixel, or other web beacon.
Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or to block or remove cookies altogether.
8. How Long Do We Keep Your Information?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than 90 days.
9. How Do We Keep Your Information Safe?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. Our cloud hosting, database and authentication services (Firebase) encrypt data at rest and in transit using HTTPS and logically isolate customer data. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.
10. What Are Your Privacy Rights?
In Short: You may review, change, or terminate your account at any time.
If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here:
If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain Service features.
If any of our Users upload or submit Customer Data or other content to our Service which includes Personal Data, such data will only be processed by Wayfyndr on behalf of our Customer, which is the owner of the respective Account, along with all other User Data processed on such Customer’s behalf.
In such instances, our Customer shall be deemed the “Data Controller” of such data, and Wayfyndr will process such data on the Customer’s behalf, as its “Data Processor”, in accordance with its reasonable instructions, subject to our ToS. The Customer will be responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).
11. Controls For Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
12. Do California Residents Have Specific Privacy Rights?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
CCPA Privacy Notice
The California Code of Regulations defines a “resident” as:
- every individual who is in the State of California for other than a temporary or transitory purpose and
- every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as “non-residents.”
If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.
Wayfyndr, LLC has not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Wayfyndr, LLC will not sell personal information in the future belonging to website visitors, users and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data – Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.
Right to be informed – Request to know
Depending on the circumstances, you have a right to know:
- whether we collect and use your personal information;
- the categories of personal information that we collect;
- the purposes for which the collected personal information is used;
- whether we sell your personal information to third parties;
- the categories of personal information that we sold or disclosed for a business purpose;
- the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
- the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
- you may object to the processing of your personal data
- you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data
- you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- you may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.
To exercise these rights, you can contact us by email at firstname.lastname@example.org, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
13. Do We Make Updates To This Notice?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
14. How Can You Contact Us About this Notice?
If you have questions or comments about this notice, you may email us at email@example.com or by post to:
PO Box 2502
Portland, OR 97208
15. How Can You Review, Update, Or Delete The Data We Collect From You?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please email: firstname.lastname@example.org
16. Additional Notices
Children Under 13: We are committed to protecting the privacy and rights of children online. We believe that children should be able to use the Internet in a safe, productive, and efficient manner and should be afforded the highest protection available with respect to their personal information. The Children’s Online Privacy Protection Act (“”COPPA””) took effect on April 21, 2000 and imposes certain requirements on websites directed toward children under 13 that collect information on those children, or on websites that know they are collecting information on children under the age of 13. It is Wayfyndrs ‘policy not to collect personal information on any person under 13. If we learn that a person under the age of 13 is using the Service, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any Personal Data stored with us with regard to such child. Our Services are not designed for children. This policy is designed to protect children. Federal law requires us to take special steps to safeguard children’s privacy. To learn more about COPPA, consult the Federal Trade Commission’s COPPA website www.ftc.gov or you may call 202/FTC-HELP.
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