WIW warrants to respect everyone’s privacy and to handle all the personal data with the utmost discretion and confidence . We inform you that all personal and any other data you provide can only be used by WIW and will not be disclosed to any third party, unless it is legally requested by the authorities or prescribed by a specific law. We are strongly committed to the protection of your internet data and will take all the technical, organizational and security measures to protect the information you share. For example, the use of SSL encryption for the overall protection of personal data is one of these,measures. However, you are also responsible for your own data and your privacy. Please, for your own safety, exercise the greatest discretion with regard to your personal data provided for the registration and throughout our services, as well as to your user name and password being indispensable for accessing and using the services. It is only for previously agreed and predetermined purposes that personal data are handled by WIW, and solely and exclusively until the goal has been reached and only to the extent and for the time-period absolutely necessary for the goal to be reached.
I. Definition of data handling
It designates the handling of data performed on the basis of the voluntary, informed and determined consent given by the users of the WIW application with respect to users that register in the WIW application.
II. Our obligations
WIW is fully committed to protect the data of users using our services. Our goal is to provide a safe user experience to all our members. We do our best in every respect to ensure that the information provided remain confidential and be used only for the purposes intended here.
III. Data controller- Data recipients
Data are collected by:
WOOP PRODUCTION FRANCE – SAS RCS Versailles : 821 565 017. The headquarters are located: 5 Rue du Chant des Oiseaux, 78360 Montesson, France. Only some of the support team employees and authorized managers can process the data for the purpose described at article IV.
These employees and authorized managers only have access to the data necessary to the performance of their duty.
These subcontractors allow WIW among other things to establish statistics on the volume of traffic and/or the use of the app and/or ensure the smooth operation of the service.
IV. Purpose of the process of personal data
The data collected by WIW are necessary to the smooth operation and improvement of the service proposed by the Application to the Members. These data can also allow WIW to realize statistical studies and marketing analysis relating to the use of the Application and its services by the Members. It allows WIW to send promotional messages from advertisers and other partners via the Application. However, WIW never transfers any personal data of its Members to such advertisers and partners. WIW can access, store and share the Member’s personal data with authorized third parties in order to answer to a legal demand or to conform itself to legal obligations, to detect or prevent fraudulent activities or security attempt to the services, in application of the legislation.
V. Handling of information provided
When upon registration you become a member of WIW you disclose a series of personal information, such as your name, phone number, postal code, address, age, sex, occupation, hobbies, interests etc. As far as the data stored in the log files are concerned, data storage primarily has the aim of helping the user during his next log-in learn with greater ease about events that occurred while he was off-line. The aim of data handling is to make the WIW application as simple and efficient as possible. Regulations related to data handling and the protection of the visitors’ personal data apply exclusively to natural persons since personal data can only be interpreted within the scope of natural persons. Data or information apt for personal identification extend to all the personal data regarding natural persons which can be used to identify an individual, to get in touch with him, and to determine his physical availability.
Upon the user’s request the data handler is obliged to inform him about the data it handles, the purpose, legal basis and validity period of data handling, the name and address (headquarters) of the data processor as well as all the related activities. The user is also entitled to know who has gotten access to his data and for what reason. Information on this may be requested at firstname.lastname@example.org.
It is only for previously agreed and predetermined purposes that personal data are handled by the WIW application, and, in all cases, only until the goal has been reached and to the extent absolutely necessary for the goal to be reached. The WIW application undertakes to handle data justly and in compliance with the laws, always respects the principles of integrity and legality, and uses its best efforts that the handled data be exact and complete. By accepting the data handling guidelines as well as the terms of service, User agrees to have previously received adequate, all-embracing, detailed, understandable and easily accessible information. If User requests that his data be erased or rectified, WIW agrees to comply with User’s request. WIW informs User that the Data Handler has the obligation to record, notify and report events related to incidents regarding data protection.
User has the right to get an insight into his own data handled by WIW, and the WIW application undertakes to inform User about the data it stores in a comprehensive and machine-readable form. In the meantime, the Data Handler obviously ensures that users can only see their own data. The right to data portability grants a Member the right to receive the personal data he/she gave to WIW, in a structured, commonly used format, legible on a machine, and to forward them to another processing entity, in compliance with article 20 of the GDPR. User has the right to ask WIW to erase data stored about him, and WIW complies with the request. In case of an unexpected incident regarding personal data, WIW undertakes to comply with its reporting obligation within 72 hours. The WIW application shall use all reasonable endeavors to ensure the protection of the personal data it was entrusted with. In the notice provided to User, he has to be informed in a clear and understandable language about the character of the data protection incident, as well as the name of the data protection officer or the name and contact details of any other focal point in charge of further communication; he has to be informed about the potential consequences expected to arise from the data protection incident as well as the measures taken or planned to be taken by the Data Handler to redress the data protection incident, including measures aiming to lessen potential detrimental consequences arisen from the data protection incident. User does not have to be informed if any of the following conditions holds true:
- the Data Handler has taken the appropriate technical and organizational measures, and they have been applied to the data affected by the data protection incident, especially those, such as the use of encryption, which make it impossible for unauthorized persons to interpret the personal data;
- following the data protection incident, the Data Handler has taken additional actions that ensure that the high risk that affected User’s rights and freedoms is presumably no longer valid;
- informing User would involve a disproportionately high effort.
In such cases, users are to be informed in public notices, or other measures ensuring efficient information of the users concerned are to be established.
If the Data Handler hasn’t informed User about the data protection incident, the supervisory authorities may order the User to be informed once it has been ascertained that the data incident carries a potentially high risk.
VI. Type of data collected (fair collection of Personal Data)
VI. 1. Identity data: The registration form must be completed in order to access the Services, or the user has the option to choose to log on to facebook and WIW collects the data from Facebook, via Facebook Connect, to simplify the process. Members are required to provide some personal data when registering:
- Her/His date of birth (only the age calculated based on the date of birth is visible on WIW)
• Her/His sex (publicly visible on WIW)
• Her/His name or nickname (publicly visible on WIW)
• Her/His interests (publicly visible on WIW)
- Her/His phone number (the Member’s phone number shall not be visible or available to the public on WIW)
- Her/His photo(s):
Member must at least provide their public profile picture. The Member then has the option of removing this photo and/or adding other photos to his/her Account from his/her Facebook account or smartphone. For the sake of transparency, the published photos must represent the member and shouldn’t mislead the other Members on his identity and/ or physical appearance.
These photos cannot represent neither a famous person nor include the photo of a minor, neither represent a racist, chocking, illegal, sexual message nor contained personal information.The photos are published in the App under the sole responsibility of the Member.
By becoming a Member, the latter accepts the publication of his photos on the App.
A Member can authorize the access to his/her Facebook list or contact list of friends in order to see during his visit of another profile on the App the list of shared friends.
The Member may also provide wiw with his mobile phone number in order to receive SMS alerts. In all cases, the Member’s surname and phone number shall not be visible or available to the public.
VI. 2. Location Data
WIW has for main purpose and vocation to allow Members to find the people they’ve crossed path in order to facilitate virtual or real life meet up.
The Member will be asked for permission to collect and process his/her geo-tracking in order to allow WIW to identify the crossing points with other Members that accepted the geo-tracking.
The news feed is created by these crossing points which permits to propose to the Member only profiles that he crossed path with and that fits his/her criteria.
WIW may, in case of express consent, access the Member’s position, approximately or more precisely depending on which technology is being used. WIW does not track the movements and/or itinerary of its Members and reminds keeping only the crossing points between the Members.
The exact position or the itinerary of the Member is not available to the other Members.
The Member is free to withdraw his/her consent at any time, and deactivate the geo-tracking technology on his smartphone. By doing that, the Member’s news feed is not updated anymore and the member cannot see the other Members he /she has crossed path with after the deactivation of the geo-tracking technology.
VI. 3. Transaction Data
WIW does not collect or process any bank data. The Apple App Store, Google Play Store have opted to refrain from sending certain data to mobile applications, which includes any banking and financial information. Such data is collected and processed solely by the above platforms, and WIW does not have the option of changing this payment method.
VI. 4. Mobile Data
When the Member uses the Application, WIW collects server logs which may include information such as IP addresses, operating systems or application crashes. WIW cannot access its Members’ browsing history.
VI. 5. Research preference Data
By default the app is set on the research of person that are 16 to 70+ years old and on the research of distance.
WIW collects this data and undertakes to comply with Article 8 of the French Data Protection Act (Loi Informatique et Libertés) of 6 January 1978.
VI. 6. Communications Data exchanged
Communication data is stored on WIW’s servers solely in order to provide the Service that allows conversations to take place between members. Messages and vocal messages are strictly private and shall only implicate the Members in question. No managers or employees hold or exercise any rights to view these conversations or the circumstances surrounding them, including those authorized to process data except in case of judicial request, legislative or administrative disposition and/ or in case of element of proof provided to WIW by a Member in the eventuality of a reporting.
Moreover, these strictly private Messages shall not be accessible to other Members who have not participated in such Messages, or to unconcerned Internet users or any third parties.
WIW ensures that the personal data the Member has published on the Application is strictly invisible to non-registered internet users and third parties. WIW cannot be held liable for data published on its platform and disclosed by a Member.
The Member’s profile will not appear on the Application to Members with whom he/she has crossed paths but who are not compatible with his/her preferences.
VII. Member Rights
In compliance with the French Data Protection Act of January 6th, 1978 (Loi Informatique et Libertés), and the GDPR, every Member has a right to access, rectify, and a right to data portability and removal of his/her personal data, along with a right to contest or limit processing of his/her personal data, and the right to decide on the way to handle the personal data after his/her death. In an effort to address its Members’ concerns, WIW commits to respecting the protection of personal data and to process requests as soon as possible. A Member can exercise his/her rights, granted he/she can prove his/her identity, by sending a letter or e-mail to email@example.com or by exercising his/her rights directly on the Application.
For any other claim, the Member may lodge a claim with the national authority responsible for the protection of data.
- The right to access allows a Member to ask WIW for data pertaining to him/her in an accessible format, based on Article 39 of the French Data Protection Act (Loi Informatique et Libertés), and article 15 of the GDPR.
- The right to correct grants a Member the right to demand WIW corrects, adds to, updates or removes any personal data on him/her that is inaccurate, incomplete, ambiguous, out-of-date, or whose use, communication or storage is prohibited based on Article 40 of the French Data Protection Act (Loi Informatique et Libertés), and article 16 of the GDPR. You can modify or rectify your information directly on the Application. You just need to go on your profile and make changes directly in the sections “My photos”, “Career and Education (Job, Company, University)”.
- Facebook registration: To change your first name, age, or gender, go to your Facebook page and update the “About me – contact and basic info” section of your profile.
- The right to data portability grants a Member the right to receive the personal data he/she gave to WIW, in a structured, commonly used format, legible on a machine, and to forward them to another processing entity, in compliance with article 20 of the GDPR.
- The right to contest grants a Member the right to contest, free of charge and at his/her own discretion, the use of his/her data by WIW for prospection, especially commercial, and to the processing based on WIW’s legitimate interest, in compliance with Article 38 of the French Data Protection Act (Loi Informatique et Libertés), and article 21 of the GDPR.
- The right to delete grants a Member the right to demand the removal, free of charge and at his/her own discretion, of the data transmitted to WIW, within the limits of the rights based on article 17 of the GDPR. You can delete your account using the corresponding feature on the Application.
- The right for the Member to set the guidelines for the retention, deletion and communication of his/her personal data after his/her death, in compliance Article 40-1 of the French Data Protection Act (Loi Informatique et Libertés).
These rights may only be exercised within the limits of WIW’s resources as it relates to its use of Facebook Connect. Some of the data is sent to WIW by Facebook Connect and cannot be corrected without Facebook’s assistance.
The Member can also rectify most of his/her personal data, at his/her own initiative, on the Application itself. User has the right to get access to the personal data and the information listed in the GDPR resolution. It is through this that the WIW application ensures users’ right of access.
The right for the Member to set the guidelines for the retention, deletion and communication of his/her personal data after his/her death, in compliance Article 40-1 of the French Data Protection Act (Loi Informatique et Libertés).
The right to data storage
The user has the right to receive the personal data that he / she has provided to a data controller in a machine readable format and transmit this data to another data controller without being obstructed by the data controller who provided the personal data.
Personal information should be provided to the user in a widely used machine-readable format. The original data handler is not responsible for whether the data will be properly handled by another data handler, so the user has to decide which data gives access to another recipient data handler.
Right to be forgotten
Personal data can be handled only for purpose and only for a limited period of time. If the target ends or the pre-recorded time lapses, or if the user withdraws his / her prior consent, the data controller must immediately delete the data from their systems.
VIII. Sensitive Data
Certain data is legally classified as “sensitive” pursuant to Article 8 of the French Act n° 78-17 of January 6, 1978, known as the Loi Informatique et Libertés (French Data Protection Act).
The Member may decide to provide sensitive data related to him/her on his/her description such as (for example and not limited to) his/her ethnic origin or political views, and thereby expressly consents to the collection of such sensitive data.
The Member won’t be in any case forced to give us some sensitive data and WIW does not encourage the disclosure of such sensitive data. Despite that, if the Member decides to disclose such data on his/her profile, the disclosure is considered as an express consent to the collect and process of these data by WIW.
IX. Storage of Personal Data
WIW will store the Member’s personal data for as long as required in order for the Member to use his/her Account. The Member is however informed that all of his/her personal data shall be stored for one year after his/her account is deleted so that it can be reallocated if the Member signs up again.
Furthermore, please note that in accordance with its status as a hosting provider, WIW has a legal obligation to retain some of Members’ personal data for a period of one year based on Article 6, II of the French Trust in the Digital Economy Act (Loi pour la Confiance dans l’Economie Numérique) of 21 June 2004.
Pursuant to the Decree of 25 February 2011 pertaining to the retention and communication of data, the retention period applied to WIW is calculated from the moment the content is created for data referred to by 1° and 2° of Article 6, II of the French Trust in the Digital Economy Act, i.e.:
• The username used to log in which is at the source of the communication;
• The username assigned to the content by the information system;
• The protocol types used;
• The operation type;
• The operation dates and times;
• The username used by the originator of the operation if provided by the latter.
The retention period applied to WIW is calculated from the moment the agreement is cancelled or the profile is deleted for the data referred to by 3° of the same Article, i.e.:
• First names and surnames
• Any aliases used
• Linked e-mail addresses or Accounts
• Phone numbers
• The password and data used to verify or amend the profile (most recent version).
WIW undertakes to make every effort and to invest all means at its disposal in order to guarantee that the stored data is as secure as possible. It is however the Member’s responsibility to take appropriate action in order to protect his/her data.
WIW shall not collect data from minors. Should a Member lie about his/her date of birth, and particularly if he/she fraudulently claims to be over 16 years of age, the parents of the minor in question may inform WIW of this by sending a letter to the address shown in Article 17 in order to request that the data be deleted. WIW undertakes to delete all data on the minor in question as soon as possible.
X. Visitors’ habits and related information
We collect anonymous data about users’ activities while they use the application with the help of Google Analytics. These data are used for analyses on usage intensity and methods of use with respect to gender, age, location and type of mobile devices (telephone, tablet etc.). The data are used cumulatively and anonymously. This helps us identify best solutions for WIW users and continuously enhance user experience. When visiting the web site or the application you may be requested to supply feedback on other issues we mentioned earlier on, such as interests, or services you like or dislike on the web site or in the application. This feedback is only used with the aim of improving the user experience. Once again, the collected personal data are used by WIW only and will under no circumstances be disclosed to a third party without your former consent, unless we are legally bound to do so by the authorities or due to a specific law.
XI. General provisions and information
In accordance with our privacy guidelines, we can only disclose personal data if the law requires it and if the competent authorities oblige us in order to protect WIW users, the WIW application and others. We are entitled to share the collected and registered information with partners we hire for the fulfilment of tasks, such as server operation, server hosting services, processing of card payments etc. These companies can get access to your personal data, but only to the ones that are absolutely necessary for the fulfilment of their activities. Hence, we underline that as far as payment is concerned, it is only the data which are absolutely necessary for the fulfillment of the payment that are handed over to the financial entity, and these data are handled by the financial entity only until payment is completed and only to the extent to which the fulfillment requires them.
Anonymous information collected outside of the scope of personal identification, which cannot be connected to a natural person, or demographic data, which are collected with no regard to the personal data of identifiable individuals, hence no relationship with a natural person can be established, are not considered personal data. WIW is not offering services to individuals under the age of 16, thus WIW declares that it does not collect and does not handle personal data of individuals under the age of 16. We are not checking each and every data sheet to see if they are correct and not misleading, but we use our best efforts to try to filter out inauthentic users. Therefore we provide an opportunity for profile authentication based on User’s voluntary behavior and contribution.
XII. Modification of personal data
In the WIW application it is possible to change personal data. It is enough to log in with the user name and password and the data in the data sheet can be modified any time. It is to be noted that age can only be changed once! If User asks WIW to erase or rectify his data, WIW agrees to comply with User’s request.
XIII. Deletion of personal data
Users may temporarily suspend their stay in the WIW application (on an IOS device) on the basis of the terms and conditions defined in the terms of service. There is no data deletion in this case.
Should users realize that in spite of the deletion there are still personal data left in the system they should write an e-mail to firstname.lastname@example.org to demand deletion. The service provider deletes the data. Service Provider shall erase the data within the time period prescribed by the law following the receipt of the demand for erasure ensuring thus User’s “right to be forgotten”.
The right to delete grants a Member the right to demand the removal, free of charge and at his/her own discretion, of the data transmitted to WIW, within the limits of the rights based on article 17 of the GDPR. You can delete your account using the corresponding feature on the Application.
XV. Transfer of Personal Data outside the EU
When registering, the Member expressly consents to her/his data being transmitted to subcontractors and hosted on servers by our service providers outside the European Union, for proper provision of the service, to the end of elaborating statistical studies and for the purpose of providing customer care support to Members.
WIW guarantees that the transfers are made under conditions ensuring the confidentiality and security of the data and providing for an adequate level of protection with respect to the Article 68 and 69 of the French Data Protection Act (Loi Informatique et Libertés).
WIW guarantees that the transfers are made under conditions ensuring the confidentiality and security of the data and providing an adequate level of protection in compliance with regulations (notably the examples of contractual clauses provided by the European Commission)
Cookies installed on the hard disk can be deleted from the user’s computer before their expiry date. It can be done with the delete button in History under Tools/Settings of the browser menu.
It is important to note that deleting cookies stored on the hard disk of the computer may cause malfunctions with certain web pages.
How to contact us:
WOOP PRODUCTION FRANCE
5 Rue du Chant des Oiseaux