WISHSLATE INC. PRIVACY POLICY

Last Modified: 11/19/2019

 

SCOPE OF THIS POLICY

This privacy policy describes the treatment of information provided or collected on the sites and applications where this privacy policy is posted, whether on our digital properties or on applications we make available on third-party sites or platforms.  We follow this privacy policy in accordance with applicable law in the places where we operate.  In some cases, we may provide additional data privacy notices specific to certain products, practices, or regions. Those terms are to be read in conjunction with this policy.

Please keep in mind that when you provide information to us on a third-party site or platform (for example, via our applications), the information you provide may be separately collected by the third-party site or platform. The information we collect is covered by this privacy policy, and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications. Please also keep in mind that our sites and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal information.

WHO WE ARE 

WishSlate Inc. (“WishSlate, “we”, “us”, “our,” etc.) develops various digital websites, mobile and web apps (“Service”) for the purposes of informing, educating and improving gift experiences for users.

 

DEFINITIONS

“Aggregate information” means information about groups or categories of guests, which does not identify and cannot reasonably be used to identify an individual guest.

“Anonymous information” means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual guest.

“Application” means a program or service operated by us (or on our behalf) that may be displayed on various online, mobile, or other platforms and environments, including those operated by third parties, which permits us to interact directly with our guests.

 “Children” means individuals who we have identified are not of legal age to consent to the collection and processing of their personal information. In the United States and Latin America, the term “children” refers to individuals under 13 years of age.

The “data controller” is WishSlate Inc. or a subsidiary or an affiliated entity of WishSlate Inc. that is responsible for the personal information collected and used within the scope of this policy from our sites and applications. 

A “data processor” is a person or entity that processes personal information on behalf of a data controller (or data controllers) and is permitted to perform data processing only as directed by the data controller(s).

An “IP address” is associated with the access point through which you enter the Internet, and is typically controlled by your Internet Service Provider (ISP), your company, or your university. We may use IP addresses to collect information regarding the frequency with which our guests visit various parts of our sites and applications, and we may combine IP addresses with personal information.

“Member” means a subsidiary or affiliated entity that is part of The Walt Disney Family of Companies.

“Parents” means a parent or legal guardian.

“Personal information” means information that identifies (whether directly or indirectly) a particular individual, such as the individual’s name, postal address, email address, and telephone number. When anonymous information is directly or indirectly associated with personal information, the resulting information also is treated as personal information.

“Public Forums” are conversation, information or discussion areas provided by our sites and applications that may offer message boards, conversation pages, blogs, chat rooms, social community environments, profile pages, and other forums that do not have a restricted audience. If you provide personal information when you use any of these features, that personal information may be publicly posted and otherwise disclosed without limitation as to its use by us or by a third party.

INFORMATION WE COLLECT

We collect two basic types of information – personal information (as defined in this policy) and anonymous information (as defined in this policy) – and we may use personal and anonymous information to create a third type of information, aggregate information (also defined in this policy).   For example, we collect:

  • Registration information you provide when you create an account, enter a promotion, or link your profile on a third-party site or platform with your registration account, such as your first name and surname, country of residence, gender, date of birth, email address, username, and password;
  • Transaction information you provide when you request information, contact WishSlate, or purchase a product or service.
  • Information you provide in public forums on our sites and applications, such as your public posts;
  • Information sent either one-to-one or within a limited group using our functionality in our Service, where we are permitted by applicable law to collect this information;
  • Information we obtain from a third party, such as a site or platform provider, about use of our applications on third-party platforms or devices;
  • Location information, including location information provided by a mobile or other device interacting with one of our sites or applications (including through beacon technologies), or associated with your IP address, where we are permitted by law to process this information;
  • Activity information about your use, and the use by any person(s) you authorize through your account, of our Service, such as the content you view or post, how often you use our services, and your preferences; and
  • Usage, viewing, technical, and device data when you use our Service, or open emails we send, including your browser or device type, unique device identifier, and IP address.

 

HOW WE COLLECT INFORMATION

  • We collect information you provide to us when you request or purchase products, services, or information from us, register with us (including when you link your profile on a third-party site or platform with your registration account), use our Service,  respond to guest surveys, or otherwise interact with us using one or more devices.  
  • We collect information through a variety of technologies, such as cookies, Flash cookies, pixels, tags, software development kits, application program interfaces (APIs), and web beacons, including when you use our Service using one or more devices, whether or not you are logged in or registered. 
  • We collect information using analytics tools, including when you visit our sites and applications or use our applications on third-party sites or platforms.

HOW WE USE YOUR INFORMATION

WishSlate Inc. that is the data controller for your information is responsible for and may use your information for the purposes described in this policy. Consistent with applicable law and choices and controls that may be available to you, we may use information collected from you, or from devices associated with you, to:

  • Provide you with the experiences, products, and services you request, view, engage with, or purchase;
  • Communicate with you about your account or transactions with us and send you information or request feedback about features on our Service or changes to our policies;
  • Send you offers and promotions for our products and services or third-party products and services;
  • Personalize content and experiences;
  • Provide you with targeted advertising based on your activity on our Service and on third-party sites and applications;
  • Operate, understand, optimize, develop, or improve our Service and operations, by using guest survey research and analytics tools; and
  • Detect, investigate and prevent activities that may violate our policies or be illegal.

 

CHILDREN’S PRIVACY

We recognize the need to provide further privacy protections with respect to personal information we may collect from children on our Service. Some of the features on our sites and applications are age-gated so that they are not available for use by children.. When we intend to collect personal information from children, we take additional steps to protect children’s privacy, including:

  • In accordance with applicable law, and our practices, obtaining consent from parents for the collection of personal information from their children, or for sending information about our products and services directly to their children;
  • Limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity; and
  • Giving parents access or the ability to request access to personal information we have collected from their children and the ability to request that the personal information be changed or deleted.

 

  • In any instance where we ask for age and determine the user 13 years of age, we will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at info@wishslate.com

 

SHARING YOUR INFORMATION

We will not share your personal information with a third party except in limited circumstances, including:

  • When we share your personal information with third parties in connection with the sale of a business, to enforce our Terms of Use or rules, to ensure the safety and security of our guests and third parties, to protect our rights and property and the rights and property of our guests and third parties, to comply with legal process, or in other cases if we believe in good faith that disclosure is required by law.

 

  • When companies perform services on our behalf, like package delivery, marketing and advertising, and customer service; however, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law; and

YOUR CONTROLS AND CHOICES

We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. In accordance with applicable law, your controls and choices may include:

  • Correcting, updating, and deleting your account;
  • Choosing or changing your choices for subscriptions, newsletters, marketing information and alerts;
  • Controlling targeted advertising from many ad networks and partners; data exchanges; and marketing analytics and digital advertising and marketing service providers.
  • Choosing to control targeted advertising you receive within applications by using the settings and choices made available to you through your device(s), for example, by re-setting your device’s advertising identifier and/or opting out of interest-based ads;
  • Requesting access to the personal information we hold about you and that we amend or delete it.

 

You may exercise these controls and choices in various ways, including by sending us an email at info@wishslate.com.  You can opt out of interest based ads by visiting the Digital Advertising Alliance or European Interactive Digital Advertising Alliance.

Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our services may not be able to take account of your interests and preferences. 

DATA SECURITY, INTEGRITY AND RETENTION

The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect guest information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. We will retain your personal information for the length of time needed to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law.

DATA TRANSFERS, STORAGE, AND PROCESSING GLOBALLY 

We may operate globally and may transfer your personal information to individual companies of third parties in locations around the world for the purposes described in this privacy policy. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. Additionally, when using or disclosing personal information transferred from the European Union, we use standard contractual clauses approved by the European Commission, adopt other means under European Union law for ensuring adequate safeguards, or obtain your consent. We also apply the substantive requirements of standard contractual clauses when transferring personal information from Australia.

CHANGES TO THIS PRIVACY POLICY

From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on our sites and applications, or by other means, consistent with applicable law.

CALIFORNIA RESIDENTS 

If you are a California resident, you may have certain additional rights. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by WishSlate Inc. to third parties for the third parties’ direct marketing purposes. California Business and Professions Code Section 22581 permits registered users who are minors to request and obtain deletion of certain posted content.   

If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to info@wishslate.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

COMMENTS & QUESTIONS

If you have a comment or question about this privacy policy, please email us at info@wishslate.com  

 

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