Effective date: 13 September 2018
Wetrend Media Ltd, t/a WeTrend ("we", "us", "our") is committed to protecting and respecting your privacy.
1. Scope of Policy
This policy (together with our Terms of Service, as set out at http://wetrend.com/terms) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting wetrend.com or contacting us you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679, the data controller is Wetrend Media Ltd, as registered with the ICO.
2. INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
2.1 Information you give us. You may give us information about you by filling in forms on our website wetrend.com or by corresponding with us by e-mail or otherwise. This includes information you provide when you create an account or report a problem with our website. The information you give us may include your name, address, e-mail address, date of birth and phone number, financial and credit information and personal description.
2.2 Information we collect about you. With regard to each of your visits to our website we may automatically collect the following information:
2.2.1 technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), your login information, browser type and version, time zone setting, browser plug-in-types and versions, operating system and platform;
2.2.2 information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), products or services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number;
2.2.3 details of your use of our website and the resources that you access.
2.3 Information we receive from other sources. We are working closely with third parties (including, for example, business partners, financial advisors, sub-contractors in technical, payment and delivery services, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
If you contact us, we may keep a record of that correspondence.
3. What information does WETREND collect about me if I’m under 18?
WeTrend does not knowingly collect any information about or market to children, minors or anyone under the age of majority. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal data, we will take steps to terminate that person’s registration and delete their account information from WeTrend. If we do delete an account because you violated our no children rules, we may retain your email and IP address to ensure that you do not try to get around our rules by creating a new account.
4. What is the legal basis that allows WeTrend to use my data?
|Purpose for which data is used||Data||Legal basis|
|To provide you with the WeTrend service||Name, address, email address, date of birth||Contractual necessity|
|To verify your identity and prevent fraud and to ensure the safety and security of users||Phone number||Legitimate interests – it is in our legitimate interests to ensure that accounts are not set up fraudulently and to safeguard users of the site|
|To send you information about our offers and services||Email address||Legitimate interests – it is in our legitimate interests to promote our services|
|To enable payments for services to be processed||Payment card details||Contractual necessity and legitimate interests – we have a legitimate interest in enabling payments to be processed|
A cookie is a small file of letters and numbers that we store on users' browsers or the hard drive of users' computers if users agree. Cookies contain information that is transferred to users' computers' hard drive. We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable users to log into secure areas of our site or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise users when they return to our site. This enables us to personalise our content for users, greet users by name and remember users' preferences.
- Targeting cookies. These cookies record users' visits to our site, the pages users have visited and the links users have followed. We will use this information to make our site more relevant to users' interests. We may also share this information with third parties for this purpose.
Users can block cookies by activating the setting on their browser that allows users to refuse the setting of all or some cookies. However, if users use their browser settings to block all cookies (including essential cookies) users may not be able to access all or parts of our website.
6. USES MADE OF THE INFORMATION
We use information held about you in the following ways:
6.1 Information you give to us. We will use this information:
6.1.1 to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
6.1.2 to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about whether provided by us or by one of our affiliates;
6.1.3 to provide you with information about goods or services we feel may interest you. We will only contact you by electronic means (e-mail) with information about goods and services similar to those which were the subject of services previously provided to you and will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please visit this page for more information;
6.1.4 to notify you about changes to our service;
6.1.5 to ensure that content from our site is presented in the most effective manner for you and for your computer.
6.2 Information we collect about you. We will use this information:
6.2.1 to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
6.2.2 to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
6.2.3 to allow you to participate in any interactive features of our service, when you choose to do so and if provided by us;
6.2.4 as part of our efforts to keep our site safe and secure;
6.2.5 to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
6.3 Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the
7. DISCLOSURE OF YOUR INFORMATION
We may share your personal information with any member of our group, which means our subsidiaries, our holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties including:
7.1 Our affiliates to provide you with information about other products and services that are similar to those you have already purchased or enquired about or where your enquiry relates to products or services that are provided by one of our affiliates;
7.2 Advertisers, business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
7.3 Analytics and search engine providers that assist us in the improvement and optimisation of our site;
7.4 Fraud prevention and anti-spam providers to protect the service from criminal activity;
7.5 Law enforcement agencies, where we are required to by law or to protect the vital interests of a person; and/or
7.6 Payment processing and telecommunications companies to facilitate payments.
In the event that WeTrend or any of its affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re- organisation, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data.
8. WHERE WE STORE YOUR PERSONAL DATA
Where data is transferred outside the EEA, we ensure that it is adequately protected by ensuring that valid, legal mechanisms are in place such as: EU approved model clauses (which can be found here), US privacy shield certification (more information can be found here); and implementing robust contractual standards. If you want more information relating to the nature of the safeguards we have in place please email email@example.com.
9. How does WETREND protect my personal data?
WeTrend has implemented appropriate security measures to protect and prevent the loss, misuse, and alteration of the information under our control, including your personal data. Our technical experts at WeTrend work hard to ensure your secure use of our site.
While we take reasonable precautions against possible security breaches of our website, member database and records, no website or internet transmission is completely secure and we cannot guarantee that unauthorised access, hacking, data loss, or other breaches will never occur; any transmission of information via the internet is at your own risk. We urge you to take steps to keep your personal data safe (including your password) and to log out of your account after use. If you lose your password or give it out, or another service provider that you use suffers a data breach and you have used the same credentials with that service provider as you have with WeTrend, your personal data may be compromised. If that happens, please report it to us via firstname.lastname@example.org.
10. YOUR RIGHTS
Under UK and EU law, you have the right to lodge a complaint with data protection regulators. WeTrend has its main office in the UK and the Information Commissioners’ Office (ICO) is our lead regulator. You can find out how to raise a concern with the ICO by visiting their website at www.ico.org.uk. If you’re within the EU, you may also get in touch with your local Data Protection Regulator who may liaise with the ICO on your behalf.
You have a number of rights under European Data Protection law if you are an EU citizen.
- Right to be informed: what personal data an organisation is processing and why (this notice).
- Right of access: you can request a copy of your data.
- Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
- Right to erasure: you have the right to have your data deleted in certain circumstances.
- Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
- Right to data portability: you can request a copy of your data in a machine-readable form that can be transferred to another provider.
- Right to object: in certain circumstances (including where data is processed on he basis of legitimate interests or for the purposes of marketing) you may object to that processing.
Rights related to automated decision making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.
If you want to exercise any of your rights listed above please email us at email@example.com.
Our site may, from time to time, contain links to and from the websites within the group, Advertisers, or one of our partner networks or affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
11. How long will WETREND keep my data?
We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 4) and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore.
In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window) or after 30 months of continuous inactivity, unless:
- we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);
- there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
- the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behaviour or security incidents from opening a new account.
12. Does WETREND use my personal data for any other purpose?
We use your personal data to resolve disputes, troubleshoot problems and enforce our Terms of Service.