Wooly is a set of tools and services designed to help our brand clients build and manage relationships with their customers who may become advocates and ambassadors for our clients (“Ambassadors”).
When you enter into an agreement with us, either by accessing the Services, by executing an agreement in hard copy or by clicking “I Accept” or similar language online, we will process your Data for the purposes of fulfilling the terms of our contract with you. In that case, our processing of your Data is based on the contract, so your withdrawal of consent will only be effective after the purposes for processing that Data have been fulfilled and after we no longer have a legal obligation to keep that Data.
In all cases, we will comply with applicable law and we will cease processing your Data after the legal right, obligation, or other lawful basis expires.
3. INTENDED USERS
The Services are directed solely to persons 18 years of age or older or of children under 18 who are supervised by a parent, guardian, or other caregiver. Other than for Data collected for the specific purpose of providing the Services to users, we do not knowingly collect Data from users who are under 13. If we become aware that we have gathered Data from a person under 13, except to provide the Services to such person, and except to the extent allowed or required by law, then we will attempt to delete such Data as soon as possible, subject to our obligations under applicable law. If you believe that we have gathered Data from a person under 13 in contravention of this policy, please contact us at email@example.com.
Listed below are the categories of Data we collect when you use our Services. We never sell your Data, and we always have a lawful basis for gathering the Data, but that lawful basis might be different for different categories, and we describe those uses below. Regardless, we never use the Data for any purpose other than the purpose for which we gathered the Data in the first place, unless we get your prior explicit consent.
1. Data Description: Usage Data consists of the following and similar information:
2. Lawful Basis for Processing: Our lawful basis for processing Usage Data is (1) our contract with you or your employer, (2) our legitimate interest in providing the Services to your or your employer, and/or (3) your consent.
3. How We Use It and Who We Share It With: Usage Data is accessible to us and to you. We do not share it with third parties, except at your specific request, but we may use Usage Data to make improvements to the Services. To the extent we are required to delete any Usage Data about you, we may still retain aggregated and anonymized information that may have originated as your Usage Data.
1. Data Description: Payment Data is only collected when (1) your use of the Services is subject to the payment of a fee or other charge or (2) your use of the Services involves an integration with a payment gateway (e.g., Paypal) or other similar service that allows us to make or receive payments on your behalf under your account. Payment Data is the information necessary for us to process your payments for Services. Payment Data will vary depending on the payment method you use (e.g. direct via your mobile phone carrier or by invoice) but may include information such as:
2. Lawful Basis for Processing: Our lawful basis for processing Usage Data is (1) our contract with you and (2) our legitimate interest in improving our Services based on the Payment Data we receive from you.
3. How We Use It and Who We Share It With: We only use Payment Data to facilitate payment, and we only communicate it to those parties who are strictly necessary for that purpose.
1. Data Description: The Services may include publicly available social information including without limitation social media handle, profile information, content, content data, and website URLs ("Social Media Data"). This data may be collected directly from you by using the Services or when people publicly tag our clients on social networks.
2. Lawful Basis for Processing: Our lawful basis for processing Social Data is (1) our contract with you, (2) our legitimate interest in providing our Services, or (3) your consent by using the Services.
3. How We Use It and Who We Share It With: We use Social Data for the purposes set forth in the Data Description section to provide insights for you and our clients who engage with ambassadors, influencers, fans, and advocates of the brand. This data may be provided from or through sub-processors, social networks, or other public sources.
We may acquire data for sales and marketing purposes from third parties, such as data brokers, and we have done so in the last twelve months. In the last twelve months, we have acquired data from the following categories of providers: Sales Prospecting Tools.
Except where a specific limitation is noted above, we may share your Data as follows:
If we ever plan to use any Data in the future for any other purposes not identified above and we do not have a separate lawful basis for that new purpose for processing, we will only do so after obtaining your specific consent.
The technologies we use for automatic Data collection may include the following:
By using our Services, you agree that we may use your Data to market our other Services to you. If, after giving your consent, you wish to opt-out of our using your Data to market Services to you, please follow the instructions below.
We will comply with your request(s) as soon as reasonably practicable. Please also note that if you do opt-out of receiving marketing-related emails from us, we may still send you messages for administrative or other purposes directly relating to your use of the Services, and you cannot opt-out from receiving those messages.
For employees and other authorized users operating in their role as administrators or users of our services, our lawful basis is the legitimate interest we have in providing the services to their employer.
The GDPR also requires us to take appropriate technical and organizational measures to protect the security of Data relating to residents of Europe. We make commercially reasonable efforts to ensure the privacy and security of the Data of our European visitors and customers, and we are happy to give you a complete description of our most Wooly efforts, if you will write us at firstname.lastname@example.org. You may also write us at that address to communicate with our chief technology officer who will serve as our data protection officer, also available at email@example.com.
California has also adopted the California Consumer Privacy Act (“CCPA”), which took effect at the beginning of 2020. We comply with the requirements of the CCPA to the extent they apply to us.
If you are a California resident and we qualify as a “business” under the terms of that law, you will have the following rights:
Note that we are not allowed by law to at any time disclose your Social Security number, driver’s license number, or other government-issued identification number, financial account number, any health insurance or medical identification number, or any account password or security questions or answers.
We have listed the specific and general categories of information we have collected, disclosed, or sold in the last 12 months in the section above entitled “Data We Collect and How We Use It.” That section also lists the specific and general categories of Data we have disclosed to third parties for our business purposes.
We do not sell your Data.
We do not sell the personal information of minors under 16 years of age.
For more information, please direct your questions to us at firstname.lastname@example.org.
The security of your Data is important to us. We use commercially reasonable efforts to store and maintain your Data in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Data that you provide to us. We have implemented procedures designed to limit the dissemination of your Data to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.
You have the right to access the information we hold about you in order to verify the information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your information, although in certain limited circumstances we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.
We will make every reasonable effort to keep your information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add to your information as appropriate. As appropriate, this amended information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate information about you enables us to give you the best possible service.
You can help by keeping us informed of any changes such as a change of your personal contact information. If you would like to access your information, if you have any questions, comments or suggestions of if you find any errors in our information about you, please contact us at email@example.com. If you have a complaint concerning our compliance with applicable privacy laws, we will investigate your complaint and if it is justified, we will take appropriate measures.