Privacy policy

Last updated: December 23, 2016

Section A: GENERAL INFORMATION

Wishround LLC (“Wishround”) is committed to protecting and respecting Users’ privacy, and appreciates Users’ trust that Wishround will do so carefully and sensibly.
This Privacy Policy is provided to let the User know Wishround’s privacy practices and procedures regarding the collection, use and disclosure of personal information through wishround.com (the “Website”), in connection with the services it provides.
By registering and by logging in on the Website, as well as by ticking the respective field on the notification provided to the User during his use of the Website, the User hereby acknowledges and fully understands this Privacy Policy and consents to the collection, storage, use and disclosure of his personal information in accordance with this Privacy Policy and the UK legislation.
Personal information of Users is stored on servers in Western Europe. By logging in on the Website the User consents to the international transfers of personal information for the purposes, for which it was collected.
Please also read carefully the Terms and Conditions before using the Website. This Privacy Policy is annexed to the Terms and Conditions and constitutes their integral part.

Section B: TYPES OF INFORMATION WISHROUND COLLECTS

Personal information from users


Wishround collects personal information from Users.

As used herein, "personal information" is the information that specifically identifies an individual and information about that individual's activities, such as information about his or her use of the Website, when directly linked to personally identifiable information.
The User’s account on the Website enables to identify each User, including, but not limited to, using the profile on Facebook or other social networks. When logging in on the Website for the first time, the User gives Wishround access to his social network account. Pay attention! By interacting with Wishround services through social networks (for example, by posting information or content, such as by posting, commenting, or participating in other online activities, or interacting with services through the social networks, plug-ins or other applications), the User makes certain information public on the internet. When the User logs in via social networks, Wishround gets access to all the viewable information provided in the social network account according to its privacy settings and the respective privacy policies.
However, aiming at identifying the User, Wishround collects and uses only the following information:

  • Name / profile nickname
  • Profile picture
  • Date of birth
  • Gender
  • Phone number
  • Country of residence
  • Nationality
  • Email address
  • Available data from user accounts on social networks

This information forms the Users’ accounts. Still Users may use the Website’s options for changing, modifying and removing previously provided information at any time via their account pages. The User is solely responsible for the information to be correct, true and up-to-date.
Wishround does not collect, use or share the personal information of children (under 18 years old) in accordance with Terms and Conditions.

Automatically collected information


When the User visits this Website, some information is automatically collected, such as computer’s Internet Protocol (IP) address, computer’s operating system, the browser type and the time and date of the User’s visit. It facilitates work and User’s use of the Website.
Wishround may collect some information employing software technology known as "tracking tags" to keep track of what content on the Website is effective and serve relevant advertising. Tracking tags are small graphics with a unique identifier, which are used to track the online activity of Internet Users. Such technologies may be used for a number of purposes (to count visitors to the Website, to monitor how Users navigate it, to count how many particular articles or links were actually viewed etc.). Such information collected is used solely for the purposes described below.
Wishround may automatically collect certain information through the use of "cookies". For more information, see the Cookies Policy section. The Cookies Policy is annexed to the Terms and Conditions and constitutes their integral part.

Aggregate information


Wishround may also collect “aggregate information”, which is not personal information but data about use of the Website or about a group or category of services or Users, from which individual identities or other personal information has been removed. This is the combined information about how Users use the same service. Aggregate data helps Wishround to understand trends and needs of the Website’s services. This Privacy Policy in no way restricts or limits the collection and use of aggregate information.

Section C: USE OF THE INFORMATION


Wishround uses information it collects:

  1. To provide services, User support, and complete any transactions in connection therewith
  2. To facilitate use of the Website as well as the Wishround’s administration and operation of the Website
  3. To improve Wishround services, website content and advertising
  4. To transfer information to third parties (partners of the Website), to provide services and User support according to the User’s request
  5. To inform Users about services, news and promotional offers via SMS, email and mail

Section D: INFORMATION SHARING AND DISCLOSURE

Sharing to third parties


Wishround does not sell, rent or share personal information with third parties without User’s prior consent, except in the limited circumstances described in this Privacy Policy.
In order to enhance the quality of the services, Wishround may share information to third parties, e.g. merchants (Wishround’s partners) and issuer of e-money (Mangopay service ), as well as to Wishround’s subsidiaries and affiliates, primarily for business and operational purposes. For instance, Wishround shares User’s email through the service mandrill.com, and sends marketing emails to Users via the service mailchimp.com.
Wishround also collects and shares the information about Users within the concept of “Know Your Customer”. For example, Mangopay’s (application of the Wishround’s partner) KYC concept includes three levels of authentication, for which certain information should be collected and shared:

  1. Light Authentication: transactions worth less than €2,500 for cash-in and/or €1,000 for cash-out cumulated per legal year and per user. Within the light authentication Wishround collects the following information about the User:
    1. Email address;
    2. First Name and Last Name;
    3. Country of Residence;
    4. Birthday;
    5. Nationality.
  2. Regular Authentication: transactions worth more than €2,500 for cash-in and/or €1,000 for cash-out cumulated per legal year and per user. Within the regular authentication Wishround collects the following information about the User (additionally to previous level’s information):
    1. Address;
    2. ID Card;
    3. Occupation;
    4. Income Range.
  3. Strong Authentication: clients suspected of money laundering and/or terrorism and/or politically exposed persons. Within the strong authentication Wishround collects (additionally to previous levels’ information), the data on confirmation of residence.

Sharing to officials and government agencies


Wishround cooperates with government and law enforcement officials to enforce and comply with the law. Wishround may disclose personal information in the good faith belief that it is lawfully authorized to do so, or that doing so is reasonably necessary or appropriate to comply with the law or with legal process or authorities, respond to any claims, or to protect the rights, property or safety of Wishround, its Users, employees or the public, including without limitation to protect Wishround or its Users from fraudulent, abusive, inappropriate or unlawful use of the Website.
On official request, Wishround may disclose to officials information necessary for the investigation, e.g. the User’s name, address, phone number, email, date of birth, purchases data etc.
At the same time, in considering and responding to requests from the government authorities and organizations regarding Users, Wishround will adhere to the following principles:

  1. To be open and transparent: Wishround should have the right to disclose the number of requests received from government authorities, the number of accounts, which were concerned by these requests, and references to the law, under which such requests were made;
  2. To resist unreasonable requests: requests of the government authorities should be limited to individuals and investigations; Wishround will resist requests aimed at large (undefined) groups of persons not related to a specific investigation;
  3. To protect Users: legislation, which is the basis for receiving data on Users of online services, should not treat differently the Users based on their nationality or place of registration;
  4. To provide reliable services: government authorities do not have the rights and ability of installation / integration of software for unauthorized access to the Users’ data.

Section E: SECURITY


Safety of the Users’ data is critical to Wishround and it takes the full liability under the applicable law regarding this matter.
For that purpose, Wishround is registered as the data controller in the Information Commissioner's Office in accordance with the law of UK, registration number ZA217683.
Wishround believes that the data of Users should have the same protection regardless of whether it is stored on its own/leased servers or on the hard drive of the User’s home computer.
The Website has security measures in place to protect the loss, misuse and alteration of the information under Wishround’s control. Firstly, Wishround does not collect any information on credit cards or bank accounts of its Users since payment services are provided by our partners’ secured websites. Secondly, when you enter sensitive information, we encrypt the transmission of that information using secure socket layer technology (SSL).
Wishround encourages its Users to protect the confidentiality of personal information by keeping their passwords confidential and not disclosing them to any other person. Users are responsible for all uses of the Website by any person using their password.
Users shall also immediately inform Wishround in the event of unauthorized use of their data by other Users, or unauthorized access to their accounts as soon as they become aware of this fact, to block access to such data. To do this, the User shall send a notification to the e-mail: care@wishround.com.
If this Website contains links to other websites, Wishround is not responsible for the privacy practices or the content of such websites. Wishround encourages Users to be aware when they leave this Website and to read the privacy statements of each and every website that collects personal information.
If Users delete their accounts, Wishround will remove their personal information. However, please note:

  1. There is a possibility of delays in removal of the information from Wishround servers; and
  2. The information may be saved if it is necessary to fulfil Wishround’s legal and financial obligations, dispute resolution, or for the fulfilment of its contracts, but not for more than 36 months following the removal of personal information on the User’s request.

Section F: PRIVACY POLICY UPDATING


Wishround reserves the right to change the provisions of this Privacy Policy at any time. Wishround will alert the User that changes have been made by indicating on the Privacy Policy the date it was last updated. The use of the Website following the posting of such changes or revised statement shall constitute the User’s consent to any changes in Wishround’s privacy practices. Regarding that, Wishround encourages the User to carefully review the Privacy Policy from time to time.

Section G: CONTACTS


Wishround welcomes the Users’ feedbacks. If you have any comments or concerns about this Privacy Policy or would like to contact Wishround for any reason, you may reach us at care@wishround.com or by mail at Kemp House, 152 City Road, London, UK, EC1V 2NX, WISHROUND LTD.

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