Privacy Policy
Welcome to WAYD Privacy Policy. We care about all sensitive data and we are following all GDPR rules and compliance.
If you have any questions about this privacy notice or our privacy practices, including any requests to exercise your legal rights, please contact us by sending an e-mail.
GENERAL

Wayd respects this notice and is committed to protecting your personal data. This privacy notice will inform you of how we look after your personal data when you access our website or web application (regardless of where you visit it from), engage with us in any other way, how we process our clients’ personal data when we provide our products, and tell you about your privacy rights.

Wayd products, including our website and app, are not intended for children and we do not knowingly collect data relating to children under 13 years old.

HOW TO DELETE YOUR DATA AND ACCOUNT?

In the app go to the first tab “Profile” in bottom navigation, then tap your picture in the top left corner.  On the bottom here you can see big red button that will lead to “Delete account” screen. Pick delete account reason, confirm again that you want all your data to be removed from the WAYD servers and reauth. After that all user data will be removed from the WAYD servers.

WHO WE ARE?

We are Wayd AS  (here in after referred to as “Wayd” in this privacy notice). Wayd is the controller of your personal data and responsible for this website, our office is located at Agronomveien 23a, 1187, Oslo, Norway.

WHAT IS PERSONAL DATA?

Personal data is any information that relates to a living individual who can be identified from that information either by If your place of a residence is other than the EEA, please contact us for further information. The information alone or together with any other information likely to come into, or already in our possession. It does not include anonymous information. The obtaining, storing and use of personal data is governed by the General Data Protection Regulation 2016/679 and Norwegian Personal Data Act 2018.

DATA WE COLLECT ABOUT YOU?

6.1 Information and content you provide. We collect the content, communications and other information you provide when you use our website and web app, including when you sign up for an account (e.g. your name, surname, age, profile photo and email address), create or share a moment and message or communicate with others. This can include information in or about the content that you provide such as the location of a photo or the date a file was created. Our systems automatically process content and communications that you and others provide to analyse context and what's in them. We also access, upon your authorization, the photo gallery from your device.

6.2 Networks and connections. We collect information about who you are connected with and how you interact with them across our website and web app, such as people you tagged on your moments, people you communicate with the most or groups that you are part of.

6.3 Your usage. We collect, through Firebase Analytics, information about how you use our website and web application, such as the types of content that you view engage with, the features you use, the actions you take, the people or accounts you interact with and the time, frequency and duration of your activities.

6.4 Things others do and information they provide about you. We also receive and analyse content, communications and information that other people provide when they use our Products. This can include information about you, such as when others share or comment on a photo of you, or when you upload, sync or import your moments.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.   Aggregated Data could be derived   from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or app feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any special categories of personal data about you.

CONTENT RESTRICTIONS

The Company is not responsible for the content of the Service’s users. You expressly understand and agree that You are solely responsible for the Content and for all activity that occurs under your account, whether done so by You or any third person using Your account.

You may not publish any Content that is unlawful, offensive, upsetting, intended to disgust, threatening,libellous, defamatory, obscene or otherwise objectionable. Examples of such objectionable Content including but are not limited to, the following:

.• Unlawful or promoting unlawful activity.
• Defamatory, discriminatory, or mean-spirited content, including references or commentary about religion, race, sexual orientation, gender, national/ethnic origin, or other targeted groups.
• Spam, machine - or randomly - generated, constituting unauthorised or unsolicited advertising, chain letters, any other form of unauthorised solicitation, or any form of lottery or gambling.
• Containing or installing any viruses, worms, malware, trojan horses, or other content that is designed or intended to disrupt, damage, or limit the functioning of any software, hardware or telecommunications equipment or to damage or obtain unauthorised access to any data or other information of a third person.
• Infringing on any proprietary rights of any party, including patent, trademark, trade secret, copyright, right of publicity or other rights.
• Impersonating any person or entity including the Company and its employees or representatives.• Violating the privacy of any third person.
• False information and features.

The Company reserves the right, but not the obligation, to, in its sole discretion, determine whether or not any Content is appropriate and complies with this Terms, refuse or remove this Content. The Company further reserves the right to make formatting and edits and change the manner of any Content. The Company can also limit or revoke the use of the Service if You post such objectionable Content. As the Company cannot control all content posted by users and/or third parties on the Service, you agree to use the Service at your own risk. You understand that by using the Service You may be exposed to content that You may find offensive, indecent, incorrect or objectionable, and You agree that under no circumstances will the Company be liable in any way for any content, including any errors or omissions in any content, or any loss or damage of any kind incurred as a result of your use of any content.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the particulars of our terms and conditions, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, you may not be able to use our services and products and access our website or app. We will notify you if this is the case at the time.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. Please note that we may process your personal data without your knowledge or consent, incompliance with the above rules, where this is required or permitted by law.

AUTOMATED DECISION-MAKING

We use technologies that are considered automated decision making or profiling. We will not make any automated decisions about you that would significantly affect you unless such a decision is necessary for entering into, or the performance of, our contract with you, we have obtained your consent, or we are required by the applicable law to use such technology. You will find information on your right to object to this processing of your data below under “Your Legal Rights”.

SECURITY OF PERSONAL INFORMATIONS

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will store all the personal information you provide on the Hive https://pub.dev/packages/hive database secure (password- and firewall-protected) servers.

We do not store any passwords as we use Google, Facebook and Apple single sign-ins.

To  prevent  access  of  users  from  admin data  we  use  Fire store  authentication and security rules.  Fire store offers robust access management and authentication to handle server less authentication, authorization, and data validation.

And we have implemented physical access restrictions for our data centers and authorization controls for data access  as part of our information security management system. All data entered into through our website and app will be protected by encryption technology. You are responsible for keeping the password you use for accessing our website and web application confidential; we will not ask you for your password (except when you log in to our website and app).

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Financial, Profile, Transaction, Technical, Usage and Compliance data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes (but is not limited to) personal data you provide when you:

Apply for our servicesCreate an account on our website or app;Use our services;
Communicate with us;
Interact with us for the purpose of collaborating with us;
Subscribe to our publications
Request marketing to be sent to you;
Enter a competition, promotion or survey; or
Give us feedback.

Automated technologies or interactions. As you interact with our website or any device application   through   which   you   may   access   our   services,   we   will   automatically   collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie notice for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including, but not limited to:
Facebook, Google and Apple, when they share your profile photo and allow your sign-in to our website and web app upon your request;
Government and law enforcement agencies;
Agents   working   on   our   behalf   including   fraud   prevention   agencies,   analytics providers, advertisers;
Companies providing due diligence and other screening activities;
Media outlets (including social media outlets).

HOW WE USE YOUR PERSONAL DATA?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to use your data to provide you with our services;
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
Where you give us express consent to use your personal data; orWhere we need to comply with a legal obligation.

Contact us to find out more about the types of lawful basis that we will rely on to process your personal data.

PURPOSES FOR WHICH WE WILL USE PERSONAL DATA?

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

DISCLOSING PERSONAL INFORMATION

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this notice. We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this notice.

Access to your personal data is limited to employees, agents, contractors and purchasers (or prospective purchasers) of Wayd who need access to it in order to provide you with our services; to communicate with you (including, with your consent,  to send you marketing communications); and to carry out legal or regulatory obligations.

We may also employ the services of third-party service providers to help us in certain areas, such as website hosting, physical security, marketing and market research. Where third-party service providers receive your information we will remain responsible for the use of your personal data. We take appropriate steps to ensure that such third parties treat your personal information with the same consideration that we do. We may from time to time be required to disclose your personal data to law enforcement bodies, regulators, tax agencies or third parties under a legal requirement or court order. We act responsibly and take account of your interests when responding to any such requests. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL DATA TRANSFERS

Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this notice.

Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is:We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts – Standard Contractual Clauses - approved by the European Commission which give personal data the same protection it has in Europe.
By providing us with your personal data, you expressly consent to our transferring your personal data to countries or jurisdictions which may not provide the same level of data protection as your home country, including without limitation countries or jurisdictions outside the EEA.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Personal information that you publish or submit for publication on our website or web app may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

RETAINING PERSONAL INFORMATIONS

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. We maintain a retention procedure which we apply to records in our care.  In all cases, where your information is no longer required we will ensure it is disposed of in a secure manner and, where required by applicable law, we will notify you when such information has been disposed of . In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

CHANGES TO THE WEBSITE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy notice under regular review and may make updates and changes from time to time.
You should check this page occasionally to ensure you are happy with any changes to this notice.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

MARKETING

Promotional offers from us
We may use your data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or services from us and you have opted into receiving that marketing.

Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out
You can ask us to stop sending you marketing messages at any time by sending us an email to privacy@wayd.com or by following the unsubscribe function present in each and every marketing communication sent to you.

THIRD PARTY LINKS

This privacy notice applies only to Wayd services and information collected by our website; however, our website may contain links to third-party websites, plug-ins and applications.  Please be aware that clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy notice of every website you visit.

COOKIES

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Notice.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please read attentively the list below to find out more about these rights:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please contact us at privacy@wayd.com.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.




This privacy notice was last updated on 16th October 2020