2. COLLECTING INFORMATION
Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your Account, if you are an Account holder), and to enable you to enjoy and easily navigate our Services.
The data we collect depends on the context of your interactions with us, the choices you make, including your privacy settings, and the products and features you use. The data we collect can include SDK/API/JS code version, browser, Internet service provider, IP address, platform, timestamp, application identifier, application version, application distribution channel, independent device identifier, iOS ad identifier (IDFA), Android ad master identifier, network card (MAC) address, and international mobile device identification code (IMEI) The equipment model, the terminal manufacturer, the terminal device operating system version, the session start / stop time, the location of the language, the time zone and the network state (WiFi and so on), the hard disk, the CPU, and the battery use, etc.
2.1 Account Information
If you create an Account, we’ll collect certain information that can be used to identify you, such as your email address (“PII”). If you create an Account using your login credentials from one of your Social Networking Sites (the “SNS”) Accounts, we’ll be able to access and collect your name and other PII that your privacy settings on the SNS Account permit us to access. If you create an Account through the Services or one of your SNS Accounts, we may also collect your gender, date of birth and other information that is not considered PII because it cannot be used by itself to identify you.
2.2 Information Collected Using Cookies and other Web Technologies
2.3 Information Related to Use of the Services
Our servers automatically record certain information about how a person uses our Services (we refer to this information as “Log Data”), including both Account holders and non-Account holders (either, a “User”). Log Data may include information such as a User’s Internet Protocol (IP) address, browser type, operating system, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance the Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences. We may use a person’s IP address to fight spam, malware and identity theft. We also use the IP Address to generate aggregate, non-identifying information about how our Services are used.
2.4 Information Sent by Your Mobile Device
We collect certain information that your mobile device sends when you use our Services, like a device identifier, user settings and the operating system of your device, as well as information about your use of our Services.
2.5 Location Information
In some cases we may collect and store information about where you are located, such as by converting your IP address into a rough geolocation or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.
2.6 Third-Party Payment Processing
We may sell subscriptions or merchandise through our Services. When you make purchases through the Services, we process your payments through a third party application, including the Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, “App Stores”), SNS such as Facebook, and other third-party payment processers. The third party application may collect certain financial information from you to process a payment on behalf of us, including your name, email address, address and other billing information.
3. SHARING OF DATA
We will not share any PII that we have collected from or regarding you except as described below:
3.1 Information Shared with Our Services Providers
We may engage third-party services providers to work with us to administer and provide the Services. These third-party services providers have access to your PII only for the purpose of performing services on our behalf. We may also share your PII except with our marketing service providers to help us better market our products and services to you. Our marketing service providers may use your PII only for the purpose of helping us better market our products and services to you and are prohibited from transferring your PII to others. If you don’t want WeCan to use your information for these purposes, you can opt out by contacting us at email@example.com.
3.2 Information Shared with Other Systems, Such As HealthKit or Google Fit
In addition, in the event that you use one of those services, you should be careful about allowing other applications, services or people to access your information through that service. While much information collected by those services is innocuous, people who see WeCan data may be able to determine a variety of personal information.
- WeCan does not use or disclose to third parties user data or other information gained through the use of the HealthKit framework or Google Fit for advertising, other use-based data mining purposes or similar services, other than for purposes of improving health or for purposes of health or medical research.
- We do not write your data, including mindful minutes and sleep data, to the HealthKit store without your permission.
- We do not sell any of your information, including information gained through HealthKit or Google Fit, to advertising platforms, data brokers or information resellers.
- We do not use any of the information obtained through HealthKit or Google Fit for any purpose other than providing health and/or fitness services in connection with the Services.
3.3 Information Shared with Third Parties
We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling and other similar purposes.
We use data analysis services by third-party TalkingData (“Partner”). Our partner and it’s services are carefully selected by us, and we and our partner will use various security technologies and procedures to encrypt and process the data, to protect your personal information from unauthorized access, use or disclosure.
If you do not wish to participate in the targeted advertising based on the user’s portrait, please cancel it through the partner OPT-OUT channel (http://www.talkingdata.com/optout.jsp?languagetype=en_US).
3.4 Information Disclosed in Connection with Business Transactions
Information that we collect from our users, including PII, is considered to be a business asset. As a result, if we go out of business or enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, some or all of our assets, including your PII, may be disclosed or transferred to a third-party acquirer in connection with the transaction.
3.5 Information Disclosed for Our Protection and the Protection of Others
We cooperate with government and law enforcement officials and/or private parties to enforce and comply with the law. We may disclose any 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 or legal process (including subpoenas, warrants or court orders);
- to protect our property, rights and safety, and to protect the rights, property and safety of a third party or the public in general
- to prevent or stop any activity we consider illegal, unethical or legally actionable activity.
4. LEGAL BASIS FOR DATA PROCESSING
In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our Sites.
5. YOUR RIGHTS
We may offer advertisements displayed in WeCan, and may engage third-party services providers to work with us. All ads displayed in WeCan are appropriate for age 4 and up, allow the user to see all information used to target them for that ad (without requiring the user to leave the app), and do not engage in targeted or behavioral advertising based on sensitive user data such as health/medical data (e.g. from the HealthKit APIs).
Interstitial ads or ads that interrupt or block the user experience will clearly indicate that they are an ad, will not manipulate or trick users into tapping into them, and will provide easily accessible and visible close/skip buttons large enough for users to easily dismiss the ad.
Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your Personal Data, and to request access to, rectification, erasure and portability of your own Personal Data. Requests should be submitted by contacting us through firstname.lastname@example.org.
If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may lodge a complaint with a supervisory authority if you consider that our processing of your Personal Data infringes applicable law.
We retain your Personal Data as long as needed to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws.
5.2 Modifying Your Information
You can access and modify the PII associated with your Account through your Account settings or by contacting us at email@example.com.
You can request to deactivate your account (Settings – Account & Security – More – Deactivate Account). Before deactivating your account, we will confirm information such as your identity, security status, trusted devices. Please note that deactivation is irreversible. Once you deactivate your account, we will no longer collect personal information and delete all information related with your account. We guarantee that such information will not be revealed. Meanwhile, you are not able to access our service with deactivated account.
You can request to export your data by contacting us at firstname.lastname@example.org. Before exporting your data, we will confirm information such as your identity, security status.
6. THE SECURITY OF YOUR INFORMATION
We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your PII) from unauthorized access, use or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.
7. LINKS TO OTHER SITES
8. CHILDREN‘S PRIVACY
Children are not eligible to use our services and we do not knowingly collect or solicit personal information from children under 13. If you are a minor, you can use the service only in conjunction with your parents or guardians. If we are aware that a child under 13 has provided us with personal identifiable information, we will delete such information from our files. We use your email address and, in rare situations your mailing address or phone number, to contact you regarding administrative notices from time to time.