Effective Date: January 6, 2020
1. INFORMATION COLLECTION
Users of the Service may be Clients (anyone utilizing the Weply platform) or Agents (any individual user utilizing the Weply platform to offer services to Weply or an employee of a Client using the platform to perform the agent services for a Client).
Information You Provide to Us
Personal Information: In the course of using the Service (whether as a Client or Agent), we may require or otherwise collect information that identifies you as a specific individual and can be used to contact or identify you (“Personal Information”).
Collected information for Clients include:- Name- Company name- Email address- Telephone number- Address- Zip code- Country- VAT number
Client information is collected for operational, communication and billing purposes. Most information is publicly available but we may require a specific name, email address and telephone number of you as a Client for communication and billing purposes.
Collected information for Agents include:- Name- Email address- Telephone number (only external agents)- Social security number (only external agents)- Highest education completed (only external agents)- IP address- Paypal account (only external agents)- Picture (optional)- Skills (only external agents)- Weply tests taken (only external agents)- Weply test Scores (only external agents)- Pay rates (only external agents)- Ratings (only external agents)- Feedback (only external agents)
This information is collected and kept for operational and communication purposes. We collect social security numbers from our external agents in order to report their earnings to the Danish authorities. We pay agent earnings via Paypal why this information also is required.
All personal data is kept for the duration of our affiliation with a Client or Agent plus one year for communication, billing and tax purposes. If a Client or Agent at any point wants his or her data deleted, this must be requested by email to email@example.com. We will delete information requested this way within 30 days unless Danish law prohibits this.
All Personal Information will be handled in accordance with the General Data Protection Regulation (“GDPR”) and the legal basis for processing such Personal Data is based on your consent and/or our legitimate interest.
Payment Information: If you use the Service to make or receive payments, we will also collect certain payment information, such as credit card, PayPal or other financial account information, and billing address.
Identity Verification: We may collect Personal Information, such as your date of birth, or taxpayer identification number, to validate your identity or as may be required by law, such as to complete tax filings. We may request documents to verify this information, such as a copy of your government-issued identification or photo or a billing statement.
General Audience Service: The Service is general audience and intended for users 18 and older. We do not knowingly collect Personal Information from anyone younger than age 18. If we become aware that a child younger than 18 has provided us with Personal Information, we will use commercially reasonable efforts to delete such information from our files. If you are the parent or legal guardian of a child younger than age 18 and believe that Weply has collected Personal Information from your child, please contact us at firstname.lastname@example.org. or through the in-site chat.
Non-Identifying Information: We also may collect other information, such as zip codes, demographic data, information regarding your use of the Service, and other types of general data (“Non-Identifying Information”). We may aggregate information collected from Weply registered and non-registered users (“Weply Users”).
Combination of Personal and Non-Identifying Information: Certain Non-Identifying Information would be considered a part of your Personal Information, if it were combined with other identifiers in a way that enables you to be identified (for example, combining information with your name). But the same pieces of information are considered Non- Identifying Information when they are taken alone or combined only with other non- identifying information (for example, your notification preferences). We may combine your Personal Information with Non-Identifying Information, but Weply will treat the combined information as Personal Information.
Information Collected from Users Automatically
We and our third-party service providers, including analytics and third-party content providers, may automatically collect certain information from you whenever you access or interact with the Service. This information may include, among other information, the browser and operating system you are using, the URL or advertisement that referred you to the Service, areas within the Service that you visited, and other information commonly shared when browsers communicate with websites. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, and site functionality
The information we collect includes generated chat conversations and sales lead.
The information we collect also includes the Internet Protocol (“IP”) address.
The technology used to collect information automatically from Weply Users may include the following:
Cookies: Like many websites, we and our marketing partners, affiliates, analytics, and service providers use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use both persistent cookies that remain on your computer or similar device (to track your compliance with any Weply applicable policies) and session ID cookies, which expire at the end of your browser session (for example, to enable certain features of the Service, to better understand how Weply Users interact with the Service and to monitor aggregate usage by Weply Users and web traffic routing on the Service). You may be able to instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all functionality of the Service.
Web Beacons: We and our marketing partners, affiliates, analytics, and service providers may also employ software technology known as “web beacons” or “tracking tags” to help us keep track of what content on our Sites is effective and to serve relevant advertising to you. Web beacons are small graphics with a unique identifier that may be invisible to you, and which are used to track the online activity of Internet users. Web beacons are embedded in the web pages you review or email messages you receive. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our Service, to monitor how Weply Users navigate the Service, to count how many emails that were sent were actually opened, or to count how many particular articles or links were actually viewed.
Embedded Scripts: An Embedded Script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your computer or other device and is deactivated or deleted when you disconnect from the Service.
In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes, and we may use third parties to perform these services on our behalf.
User Profiles: You may have the opportunity to create a profile, which consists of information about you, and may include Personal Information, photographs, skills, tests taken, test scores, pay rates, feedback/rating information and other information, including your username (“Profile”). The information in your Profile may be visible to all Weply Users. You may edit certain information in your Profile via your account. If in any case, you believe that an unauthorized profile has been created about you, you can request for it to be removed by contacting us at email@example.com.
Social Networking Services
You may register to join the Service directly via the Service or by logging into your account with a third-party social networking service (“SNS”) via our Service (e.g., Facebook). If you choose to register via an SNS, or to later link your account with the Service to your account with an SNS, we will use the Personal Information you have provided to the SNS (such as your name, email address, gender and other information you make publicly available via the SNS) to create your account. Note that the information we collect from and through an SNS may depend on the privacy settings you have set with the SNS and the permissions you grant to us in connection with linking your account with the Service to your account with an SNS. Other than what we may share with the SNS as described below, the Personal Information an SNS has about you is obtained by the SNS independent of our Service, and Weply is not responsible for it.
You represent that you are entitled to use your SNS account for the purposes described herein without breach by you of any of the terms and conditions that govern the SNS, and without obligating Weply to pay any fees or making Weply subject to any usage limitations imposed by such SNS. Please note that your relationship with any SNS is governed solely by your agreement(s) with such SNS. If your SNS account terminates, then functions enabled through the link between your Weply account and your SNS account will terminate as well.
2. USE AND RETENTION OF INFORMATION
WE USE INFORMATION WE COLLECT:
To provide and improve the Service, complete your transactions, and address your inquiries, process your registration, verify the information you provide is valid and for compliance and internal business purposes;
To contact you with administrative communications and Weply newsletters, marketing or promotional materials (on behalf of Weply or third parties) and other information that may be of interest to you;
To tailor content we display to you and offers we may present to you, both on the Service and elsewhere online;
To administer and develop our business relationship with you and, if applicable, the company you represent;
To prepare related governmental and internal statistics reports; and
Unless you request that we delete certain information we retain the information we collect for as long as necessary to our business and for legal purposes.
3. INFORMATION SHARING AND DISCLOSURE
Information about Agents Shared with Clients: We share information regarding Agents working with Client. Note that if an Agent is suspended from the Weply Service, we may share that information with Clients for whom that Agent has worked. If you choose to apply for work as an Agent via the Service, we will share information relevant to you with the applicable Client(s), including, but not limited to, the information contained in your Agent Profile.
Service Providers: We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services (e.g., without limitation, maintenance services, database management, web analytics and online advertising, payment processing, fraud detection and improvement of Weply’s features) or to assist us in analyzing how our Service is used. These third parties may have access to your Personal Information in order to perform these tasks on our behalf. If Personal Information is exchanged with such third parties, we will (to the extent legally required) have data processing agreements in place to ensure the data’s safekeeping and compliance with the GDPR.
Legal and Investigative Purposes: Weply will share information with government agencies as required by law, including without limitation, in connection with reporting earnings. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), at the request of governmental authorities or other third parties conducting an investigation, to protect the property and rights of Weply or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, fraudulent, unethical or legally actionable activity.
Internal and Business Transfers: Weply may share information, including Personal Information, with its subsidiaries, and affiliates, primarily for business and operational purposes. We may sell, transfer or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due-diligence process with any potential acquiring entity) or in the event of bankruptcy. You will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
4. THIRD PARTY ANALYTICS PROVIDERS, AD SERVERS AND SIMILAR PARTIES
Weply works with (or may in the future work with) advertisers, agencies, analytics service providers, and other vendors to provide us with information regarding traffic on the Service, including pages viewed and the actions taken when visiting the Service; to serve our advertisements on other web sites, within mobile apps and elsewhere online; and to provide us with information regarding the use of the Service and the effectiveness of our advertisements. Our service providers may collect certain information about your visits to and activity on the Service as well as other websites or services, they may set and access their own tracking technologies on your device (including cookies and web beacons), and may use that information to show you targeted advertisements. Some of these parties may collect Personal Information when you visit the Service or other online websites and services. If Personal Information is exchanged with such third parties, we will (to the extent legally required) have data processing agreements in place to ensure the data’s safekeeping and compliance with the GDPR.
5. OPTING OUT
Registered Weply Users may opt-out of receiving marketing emails from us by following the opt-out instructions provided in those emails. Please note that we reserve the right to send you certain communications relating to your account or use of the Service (for example, administrative and service announcements) via email and other means and these transactional account messages may be unaffected if you opt-out from receiving marketing communications. Registered Weply Users who access the Service by using a Weply mobile application may, with permission, receive push notifications. Notification preferences can be modified in the Agent Settings menu on the Site.
6. CHANGING YOUR INFORMATION OR CLOSING YOUR ACCOUNT
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact or billing information, and you must update any changes through your online account. If you request to access all personal information you’ve submitted, we will respond to your request to access within 30 days. If you completely delete all such information, then your account may become deactivated. If your account is deactivated or you ask to close your account, you will no longer be able to use the Service. If you would like us to delete your account in our system, you can do so at firstname.lastname@example.org. We will use commercially reasonable efforts to honor your request. In addition, your Personal Information may remain in our archives and information you update or delete, or information within a closed account, may persist internally or for our administrative purposes. It is not always possible to completely remove or delete information from our databases.
7. ACCESS TO YOUR PERSONAL INFORMATION
Right to access (GDPR Article 15): You have the right to obtain a confirmation from us as to whether or not Personal Information concerning you is being processed, including information on the purpose-, categories-, recipients-, and time of storage of the processing.
Right to rectification (GDPR Article 16): If you figure out, that the data that is being processed about you is inaccurate or incomplete, you have the right to get that data rectified. We will communicate any rectification or erasure of Personal Information to any recipient to whom the Personal Information has been originally disclosed, unless it proves impossible according to GDPR Article 19.
Right to erasure and restriction of processing (GDPR Article 17): You also have the right to get your Personal Information erased, if the Personal Information is no longer necessary in relation to the purposes for which they were collected or otherwise processed. Please see GDPR Article 17 for the full list of reasons for your right to erasure.
GDPR Article 18: You have the right to restrict the processing of your Personal Information if it is (i) inaccurate; (ii) unlawful; (iii) the purpose of the processing has changed; or (iv) you have objected to the processing according to GDPR Article 21.
Right to data portability (GDPR Article 20): You have the right to receive the Personal Information concerning you which you have provided to us, in a structured, commonly used and machine-readable format. You can also request that we transmit your data to another party.
Right to object (GDPR Article 21): You have the right to object to the processing of your Personal Information if it is being used for profiling or direct marketing purposes.
Weply takes commercially reasonable steps to help protect and secure the information it collects and stores about Weply Users. All access to the Sites is encrypted using industry- standard transport layer security technology (TLS). When you enter sensitive information (such as tax identification number), we encrypt the transmission of that information using secure socket layer technology (SSL). We also use HTTP strict transport security to add an additional layer of protection for our Weply Users. But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Thus, while we strive to protect your Personal Information, Weply cannot ensure and does not warrant the security of any information you transmit to us.
9. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION
10. LINKS TO OTHER SITES
Our Service contains links to other websites. If you choose to click on a third-party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We encourage you to read the privacy policies or statements of the other websites you visit.
Phishing websites imitate legitimate websites in order to obtain personal or financial information. Identity theft and the practice currently known as “phishing” are of great concern to Weply. If you believe you have received an email or had a similar interaction with a third party pretending to be Weply, please report it at email@example.com.
The Agents are not authorized to make any closing agreements whatsoever.
13. CHANGES TO THIS POLICY
14. CONTACTING US
If you find that your Personal Information has been processed in a way that does not meet the requirements of the GDPR and if you want to file a complaint, you have a specific right to lodge a complaint with the relevant supervisory authority. The supervisory authority will guide you through the process. See contact information below:
Borgergade 28, 5, 1300 København K Denmark
+45 33 19 32 00