[Last Modified: April 04, 2023]
This privacy policy (“Privacy Policy” or “Policy”) describes how Wand Inc. (“Wand”, “we”, “us”, or “our”) collect, use and disclose certain information, including your personal information and the choices you can make about that information.
This Privacy Policy which is incorporated by reference in our Terms and Condition, the Master Service Agreement and any other beta/alpha terms of documentation (together “Terms”) governs the processing and transfer of data collected in connection with our website, available at: https://wand.ai/ (“website“), or while accessing or using the Wand cloud-based SaaS platform (“Platform”), or the services provided therein (collectively, the “Services“).
Terms not define herein shall have the same meaning ascribe to them in the Terms.
We collect and process certain information when you browse our website (“Visitors”), or when you access and use the Services, including the Alpha/Beta Service (“Customer”) (collectively shall be referred to as “you”).
In the event you are a Colorado or California resident, and the CCPA applies to you – please review our CCPA Privacy Notice.
POLICY AMENDMENTS:
We reserve the right to amend this Policy from time to time, at our sole discretion. The most recent version of the Policy will always be posted on the website. The updated date of the Policy will be reflected in the “Last Modified” heading. We will provide notice to you if these changes are material, and, where required by applicable law, we will obtain your consent. Any amendments to the Policy will become effective within 30-days upon the display of the modified Policy. We recommend you review this Policy periodically to ensure that you understand our most updated privacy practices.
CONTACT INFORMATION AND DATA CONTROLLER INFORMATION:
Wand is the controller of the Personal Data detailed below, Wand is incorporated under the laws of the state Israel and its address is Aluf Kalman Magen Street 3, Tel Aviv, Israel.
You may contact our privacy team as follows:
By Email: privacy-dpo@wand.ai
DATA SETS WE COLLECT AND FOR WHAT PURPOSE:
You can find here information regarding the purposes for which we process your personal data as well as our lawful basis for processing, the definition of “personal” and “non-personal” data, and how it is technically processed.
Non-Personal Data
During your interaction with our Services, we may collect aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the Services (“Non-Personal Data “). We are not aware of the identity of the user from which the Non-Personal Data is collected. The Non-Personal Data being collected may include your aggregated usage information and technical information transmitted by your device, such as: the type of browser or device you use, language preference, time and date stamp, country location, etc.
Personal Data
We may also collect from you, during your access or interaction with the Services, individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual (“Personal Data” or “Persona Information”). The types of Personal Data that we collect as well as the purpose for processing such data are specified in the table below. For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.
The table below details the processing of Personal Data, the purpose, lawful basis, and processing operations:
DATA SET | PURPOSE AND OPERATIONS | LAWFUL BASIS |
VISITORS | ||
Online Identifiers: Agent, unique ID, Cookie ID, IP, and other online unique identifier. | We process such data when you visit our website through third party cookies for analytic and remarketing purposes. | Consent which we will obtain through our cookie notice and consent management platform we use (“CMP”). You may withdraw consent at any time by using the cookie preference settings: enterprise.wand.ai/cookie-list/ |
Contact Information: If you voluntarily contact us for your interest in our products, support or other inquiries, through any form available on the website or by email, you may be required to provide us with certain information such as your name, job title, company name, email address, and any additional information you decide to share with us.
If you are contacting us on behalf of another person, we value your assistance and care for others, please note that it is your responsibility to make sure that any person whose Personal Data you provide is aware of the principles of this statement and agrees that you will provide Personal Data to us on this basis. | We will use this data to provide to the support you requested or respond to your inquiry. | We process such Contact Information subject to our legitimate interest in order to respond to your inquiry. |
Newsletter Registration: In the event you sign up to receive our newsletter or other marketing materials, you will be requested to provide your contact details, such as your email address. | We will use your email in order to send you our newsletter and other marketing materials. | We process such contact information subject to your consent. You may withdraw consent at any time through the “unsubscribe” link within the email or by contacting us directly. |
Job Application: In the event you apply for a job via our website, we will process your CV (and the information included therein), your cover letter as well as additional information you decide to provide such as your contact information (name, email address and phone number). | We will use this information to process your job application and for recruitment purposes. | We process such information subject to our legitimate interest. |
CUSTOMER | ||
Customer Account: In order to use our Services, or otherwise register to a training or request a demo, you will need to create an account. The information provided during the registration process or log-in will include your full name, email address, information about your company, your job title, and any other information you decide to provide. Any such information you provide us in connection with the registration for our Services is deemed “Account Information”. | We use the Account Information to create an account, provide account management, support and to provide the Services as well as perform/execute the Master Service Agreement and to grant you the license to use the Platform, account and Services. | Processing is necessary for the performance of a contract to which the data subject is party. |
Payment Information: Following the registration process, you will need to choose a plan to use our Platform, and provide us certain payment information. | We use Stripe (“Stripe”) as a third party payment processors to process this information. Consequently, any transactions that are processed by Strip will be governed by its privacy policy and terms which we recommend that you review. | Performance of a contract with you. |
Usage Data: When you use our Platform, we may directly or through third party measurement and recording tools, generate data on how you use the Platform and Services, crashes and errors, time spent, click stream, etc. (“Usage Data”). Most Usage Data does not contain Personal Data. To the extent Usage Data contains Personal Data, it will be treated as personal data and is covered under this Privacy Policy. | We use Usage Data improve our Services. | We process such information subject to our legitimate interest. |
Direct Marketing: As a Customer, we will send you invoices, materials and content through the email information you provided during your registration. | We will use this information to keep you updated with offers and content such as software updates, new capabilities and features, surveys and send you invoices and supporting documentation. | We process such information subject to our legitimate interest. You can opt-out at any time through the “unsubscribe” link within the email or by contacting us directly. |
Survey and Feedback: We reserve the right to ask you to provide feedback on our Services, including any alpha/beta services or features. We will collect your feedback through email correspondence or through a third-party service provider: Pendo.io, Please see Pendo’s privacy policy (“Pendo“); | We use this information to improve, revise and enhance our Service, as well as optimize and customize the Services. | We process such information subject to your consent. You may withdraw your consent at any time. |
Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of personal data to third-party countries, as further detailed in the Data Transfer Section, is based on the same lawful basis as stipulated in the table above.
In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on our legitimate interests.
We may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the Services provided through the website and Platform, as detailed above. If we combine Personal Data with Non-Personal Data, the combined information will be treated as Personal Data or for as long as it remains combined.
HOW WE COLLECT YOUR INFORMATION:
Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows:
COOKIES AND SIMILAR TECHNOLOGIES:
We use “cookies” (or similar tracking technologies) when you access our website. The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, as well as for statistical purposes, analytic purposes and marketing. You can find more information about our use of cookies here: enterprise.wand.ai/cookie-list/ .
DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH:
We share your data with third parties, including our partners or service providers that help us provide our Services. You can find here information about the categories of such third-party recipients.
CATEGORY OF RECIPIENT | DATA THAT WILL BE SHARED | PURPOSE OF SHARING |
Service Providers | All data | We may disclose Personal Data to our trusted agents and service providers (including, but not limited to, our Cloud Service Provider, Analytics Service Provider, payment processors, CRM provider, recording tool provider etc.) so that they can perform the requested services on our behalf. Thus, we share your data with third party entities, for the purpose of storing such information on our behalf, or for other processing needs. These entities are prohibited from using your personal information for any purposes other than providing us with requested services. |
Marketing | Online Identifiers and Contact Information | We may share Personal Data to our services providers and third parties in order to provide you with marketing materials by using cookies and other similar technologies. |
Any acquirer of our business | All data | We may share Personal Data, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy. |
Legal and law enforcement | Subject to law enforcement authority request. | We may disclose certain data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose. |
When we share information with services providers and partners, we ensure they only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit).
USER RIGHTS:
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.
For California and Colorado residents please review our CCPA Privacy Notice.
You may exercise any or all of your above rights in relation to your Personal Data by filling out the Data Subject Request (“DSR”) form available here, and send it to: privacy-dpo@wand.ai
DATA RETENTION:
In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you express your preference to optout, where applicable.
Other circumstances in which we will retain your Personal Information for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.
SECURITY MEASURES:
We work hard to protect the Personal Data we process from unauthorized access, alteration, disclosure, or destruction. We have implemented physical, technical, and administrative security measures for the Services that comply with applicable laws and industry, such as encryption using SSL, we minimize the amount of data that we store on our servers, restricting access to Personal Data to Wand employees, contractors, and agents, etc. Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty, express, implied, or otherwise, that we will always be able to prevent such access.
Please contact us at: privacy-dpo@wand.ai if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.
INTERNATIONAL DATA TRANSFER:
Our data servers in which we host and store the information are located in the EU. The Company’s HQ is based in Israel in which we may access the information stored on such servers or other systems such as the Company’s ERP, CRM, Salesforce, Strip, Pendo and other systems. In the event that we need to transfer your Personal Data out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Furthermore, when Personal Data that is collected within the European Economic Area (“EEA“) is transferred outside of the EEA to a country that has not received an adequacy decision from the European Commission, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union. Thus, we will obtain contractual commitments or assurances from the data importer to protect your Personal Information, using contractual protections that EEA and UK regulators have pre-approved to ensure your data is protected (known as standard contract clauses), or rely on adequacy decisions issued by the European Commission. Some of these assurances are well-recognized certification schemes.
ELIGIBILITY AND CHILDREN PRIVACY:
The Services are not intended for use by children (the phrase “child” shall mean an individual that is under the age defined by applicable law, which concerning the EEA is under the age of 16, and with respect to the US, under the age of 13), and we do not knowingly process children’s information. We will discard any information we receive from a user that is considered a “child” immediately upon discovering that such a user shared information with us. Please contact us at: privacy-dpo@wand.ai if you have reason to believe that a child has shared any information with us.