1. About Us
2. Scope of this Policy
3. Client Services
If you have questions regarding a Client’s collection and use of personal data, you should contact the Client with your requests or inquiries, or to exercise your rights. We will cooperate with our Clients to assist you in the exercise of the rights you have related to your personal data under applicable law. If you have any inquiries specifically directed towards Wayin, please email us at email@example.com.
4. Information We Collect
We collect the following types of personal data as a data controller through the Wayin Services. Such collection and use of personal data is separate from our processing of personal data in the context of providing the Client Services, where we act as a data processor on behalf of our Clients (see 3 above for further information):
Registration Information. We collect personal information about you when you register to use the Platform. The information you provide will include items such as your username, first and last name, company, business role, email address, or billing address.
Contact Information. We collect personal data about you when you provide contact information to us via email, mail, sign up forms, or other contact forms available through the Wayin Services as well as when you attend marketing events we host or participate in. This personal data typically includes your phone number, email address, or mailing address you provide through these forms.
Biographical Information. When you use our Site to submit an application to be a contractor, employee, or otherwise join or support our team, we collect certain personal data about your relevant background, such as your education, schools attended, job history, and other information requested on the application form.
Financial Information. As our Client, with a commercial agreement in place with us (e.g. a subscription to the Platform), we will also collect financial and transactional information, which depending on the circumstance will include accounts, contacts, bank details, billing and mailing addresses, and other payment-related information.
Third Party Platforms. In certain circumstances, we collect personal data when you interact with our advertisements and other content on third-party sites or platforms, such as social networking sites. In some cases, this includes information such as “Likes”, basic profile information gathered from social networking sites or the fact that you viewed or interacted with our content.
To identify representatives of businesses that may be interested in our products and services, we obtain contact details from social networks, such as LinkedIn and Twitter, as well as business-to-business marketing lead providers, such as DiscoverOrg and Lusha Systems Limited.
6. How We Use the Information We Collect
We use your information in the following ways:
6.1 Providing the Wayin Services
We use personal data we collect as we believe necessary or appropriate to operate, maintain, administer and improve the Wayin Services; to communicate with you regarding your account (if you have one) including by sending you Service announcements, technical notices, updates, security alerts, and support and administrative messages; to respond to your inquiries and otherwise deliver customer service; and to process payments made by you;
6.2 Communicating with You
Where permitted by applicable law, we use personal data we collect to communicate directly with you, including by sending you newsletters, promotions or information about new products and services from Wayin. Your opt-out options for promotional communications are described in Section 9 (Your Controls and Choices).
Where permitted by applicable law, we use personal data we collect to deliver you advertising, including by serving and managing ads on the Wayin Services or on third party sites and to tailor ads based on your interests and browsing history. Please see Section 9 (Your Controls and Choices) for additional information on how to manage the ads you see.
6.4 Personalizing the Wayin Services
We use personal data we collect to personalize the Wayin Services, including to greet you by name, provide better recommendations to you, tailor communications to your interests, and use the information to guide overall improvements to our products and services.
6.5 Improving the Wayin Services and our Business
We use personal data we collect as we believe necessary or appropriate to analyze trends, administer or optimize the Wayin Services, monitor usage or traffic patterns (including to track users’ movements around the Wayin Services) and gather demographic information about our user base as a whole.
6.6 Security and Fraud Prevention
We use personal data we collect as we believe necessary or appropriate to control unauthorized use or abuse of the Wayin Services and our other products and services, or otherwise detect, investigate or prevent activities that violate our policies; in connection with the monitoring and analysis of our IT systems to ensure the security of information, networks, and connected systems.
6.7 For Employment
We process personal data if you use our Site to submit an application to be a contractor, employee, or otherwise join or support our team. We use this personal data only in connection with the assessment and creation of the staffing relationship. Subject to Section 9 (Your Controls and Choices), we will also use this Personal Data to process your application, contact you regarding this or other future application/vendor/work opportunities, or similar matters.
We use personal data we collect as we believe necessary or appropriate in connection with legal requirements, to protect against, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity and to protect our rights, privacy, safety or property, and/or that of you or others.
7. Sharing Your Information with Third Parties
Information we collect will be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally transfer data to third parties as follows:
7.1 Service Providers
In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other legitimate business interests, we share your personal data with service providers who provide certain services or process data on our behalf. Service providers include customer relationship management providers, email providers, data storage and hosting providers, our accountants, accounting systems and legal representatives, analytics providers, and customer support system providers.
In certain circumstances, we share your personal data with any of our current or future affiliated entities, subsidiaries, and parent companies in order to streamline certain business operations, improve personalization, and develop products and services that better meet the interests and needs of our customers, and provide you with information we believe will be of interest to you.
In order to improve personalization, deliver more relevant advertisements, and develop better products and services, in certain circumstances and where permitted by applicable law, we share certain personal data with current or future affiliated entities and trusted third parties that provide marketing, advertising, or similar promotional services to Wayin, and in certain circumstances we will allow third parties (such as Facebook, ad exchanges, data management platforms, or ad servers) to operate on our Site and process data for behavioral advertising.
7.4 Social Media
If you use any social media plugin, API, or other similar feature, use an event hashtag or similar link, or otherwise interact with us or the Wayin Services via social media, to the extent not already the case, we may make your post available on the Wayin Services or to the general public. Social media providers include Facebook, Twitter, Instagram, Snap, Youtube and Vimeo.
7.5 Corporate Events
Your personal data will be processed in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, it is possible that personal data will be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.
7.6 Legal Disclosures
7.7 Aggregated or anonymized information
In certain circumstances, we will also share aggregated or anonymized information with third parties for other purposes (e.g. to compare the performance of two promotions with a Client, to provide benchmark metrics to Clients or to provide performance metrics relating to our website).Such information does not identify you individually, but includes usage, viewing and technical information such as the types of Wayin Services our customers and users generally use, common configurations of their computers, and performance metrics related to the use of Wayin Services which we collected through our technology. If we are required under applicable law to treat such information as personal data, then we will only use and disclose it as described earlier in this Policy.
8. Other Access to or Disclosure of Your Information
Depending on the circumstances, the Sites contain features that enable you to post reviews, provide quotes, make comments or provide other content that is publicly viewable. You should be aware that any personal data you submit as part of these posts can be read, collected, or used by other visitors to the Sites. We are not responsible for the personal data you choose to publicly post on the Sites.
9. Your Controls and Choices
We will provide you with the opportunity to “opt-out” of having your personal data used for certain purposes when we ask for this information (and we will always provide you with the opportunity to “opt-out” in any promotional communication you receive from us). If you decide to opt-out, we will not be able to provide certain features of the Wayin Services to you.
9.2 Communication Preferences.
If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included on such communications or on the Wayin Services. Please note, however, that you will be unable to opt-out of certain service-related communications and notifications.
9.3 Cookies and Similar Technologies.
9.4 How We Respond to Do Not Track Signals.
Your Web browser may have a “do not track” setting which, when enabled, causes your browser to send a do not track HTTP header file or “signal” to each site you visit. At present, the Site does not respond to this type of signal.
9.5 Accessing and Updating Your Personal data
When you use the Wayin Services, subject to applicable law we make good faith efforts to provide you with access to your personal data upon your request and either provide you the means to correct this information if it is inaccurate, or to delete such information at your request if it is not otherwise required to be retained by law or for legitimate business purposes.
To do so, please contact us at firstname.lastname@example.org with your name and the information requested to be accessed, corrected or removed, or if you are a registered user of the Platform, sign in to your account, go to your profile, and make the desired changes. Please note that if you cease using the Platform or we terminate your access to the Platform in accordance with our commercial agreement, you will no longer have the ability to access or update your information through the Platform.
To the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort (for instance, requests concerning information residing on backup tapes), jeopardize the privacy of others, would be extremely impractical, or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort or if subject to another exception provided for under applicable law. Subject to applicable law, we will also retain your information as necessary to support the Wayin Services, comply with our legal obligations, for audit purposes or to resolve disputes.
The Wayin Services are not intended for use by children and Wayin does not knowingly collect or solicit personal data from children. In the US, for data protection purposes, a child is anyone under the age of 13. In the EU, a child is anyone under the age of 16.
If you are a child, you may not attempt to register for the Wayin Services or send any information about yourself to Wayin, this includes name, email address or phone number. In the event that we confirm that we have collected personal data from children without verification of parental consent, we will delete that information promptly. If you are a parent or legal guardian of a child and believe that we might have any information from or about such child, please contact us at email@example.com.
The security of your personal data is important to us. We maintain a variety of appropriate technical and organizational safeguards to protect your personal data. We limit access to personal data about you to employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs. No method of transmission over the Internet, method of electronic storage or other security methods are one hundred percent secure. Therefore, while we strive to use reasonable efforts to protect your personal data, we cannot guarantee its absolute security.
12. Your California Privacy Rights and Disclosures
California Shine the Light Law. If you are a California resident and we disclose your personally identifiable information to third parties for such third parties’ direct marketing purposes, California’s Shine the Light Law (CA Civil Code Section 1798.83) allows you to request certain information from us about such disclosures. To make a request under the Shine the Light Law, please contact us at firstname.lastname@example.org. Please note that under California law, businesses are not required to respond to such requests more than once during any calendar year.
California Minors. At any time, you can delete or remove your posts using the same deletion or removal procedures described in Section 8 (Accessing and Updating Your personal data) above, or otherwise through the Wayin Services. If you have questions about how to remove your posts or if you would like additional assistance with deletion you can contact us at email@example.com. Although we offer deletion capability for the Wayin Services, you should be aware that the removal of posts will not ensure complete or comprehensive removal of that content or information posted through the Wayin Services.
13. International Transfers
We operate in and use service providers located in the United States. If you are located outside the U.S., in certain circumstances your personal data will be transferred to the U.S or Australia.
14. Additional Information for European Union Users
In connection with the Wayin Services, Wayin, Inc. is the controller of your personal data for the purposes of European data protection legislation. We are a processor in connection with the Client Services. You can reach our Data Protection team, including our Privacy Officer, at firstname.lastname@example.org. See the end of this policy document for further contact details.
14.2 Legal bases for processing
We only use your personal data for the purposes described at 6 above and as permitted by applicable law. Under European data protection laws, we are required to inform you of the legal bases of our processing of your personal data, which are described in the table below. If you have questions about the legal basis of how we process your personal data, contact us at email@example.com.
When we collect and process your personal data (that are not special categories of personal data), such legal bases include:
- where the processing is necessary in our or a third party’s legitimate interests: which include marketing our products or services to you, otherwise communicating with you, improving our Site, services or products and ensuring the security of our Site and in an employment context (see 6.7 above). In such cases, we have taken measures to ensure that this processing does not cause unwarranted prejudice to your privacy;
- where it is necessary for the performance of a contract: where we communicate with you in relation to the services which we are providing to you, provide you with a demonstration of our services or we are negotiating with you with regards to the provision of such services;
- in limited circumstances, where you give us your consent; and
- for compliance with a legal or regulatory obligation that we are subject to: see also 6.8 above.
Special categories of personal data
European data protection laws define certain special categories of personal data (“special categories of personal data”), which are subject to heightened protections under such laws. These special categories of personal data include information relating to an individual’s physical or mental health, racial or ethnic origin, political opinions, trade union membership, religious beliefs, sexual life or genetic or biometric data.
In certain circumstances, we will also collect and process special categories of personal data that you provide to us, for example, your resume submission for a job opportunity posted on our Site. In such cases, the legal bases we will rely on to collect and process this information include:
- for the purposes of performing or exercising our or your obligations or rights in the context of employment law; and
- in limited circumstances, where you give us your explicit consent. If we do ask you for your consent to collect and process special categories of personal data, we will provide you with full details of the information we are seeking from you and the reason why, in order for you to make an informed decision. It is not a condition of your employment relationship with us that you agree to any such request.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 unauthorized 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 requirements.
For example, depending on the circumstances we are required to keep basic information about our customers (including contact, registration, and financial information) for six years after they cease being customers for tax purposes.
In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) in which case we can use this information indefinitely without further notice to you.
14.4 Your rights
European data protection laws give you certain rights regarding your personal data. You may ask us to take the following actions in relation to your personal data that we hold, to the extent required by law, you have the following rights:
- Opt-out. Stop sending you direct marketing communications on your request. Depending on the circumstance, you will continue to receive Service-related and other non-marketing emails.
- Access. Provide you with information about our processing of your personal data and give you access to your personal data on your request.
- Correct. Update or correct inaccuracies in your personal data on your request.
- Delete. Delete your personal data our your request.
- Export. Transfer a machine-readable copy of your personal data to you or a third party of your choice on your request.
- Restrict. Restrict the processing of your personal data on your request.
- Object. Object to our processing of your personal data.
- Contact Regulator. If you would like to submit a complaint about our use of your personal data or response to your requests regarding your personal data, you may contact us at firstname.lastname@example.org or submit a complaint to the data protection regulator in the jurisdiction where you live or work. You can find your data protection regulator here.
Also, in any situation where we rely on your consent to process your personal data, you have the right to withdraw your consent to such processing.
You can submit these requests by email to email@example.com or our postal address provided at the end of the policy. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.
14.5 Cross-Border Data Transfer
Whenever we transfer your personal data out of the European Economic Area (EEA) to countries not deemed by the European Commission to provide an adequate level of personal data protection, the transfer will be based on one of the following safeguards recognized by the European Commission as providing adequate protection for personal data, where required by EU data protection legislation:
- Contracts approved by the European Commission which impose data protection obligations on the parties to the transfer. For further details, see European Commission Model contracts for the transfer of personal data to third countries.
- For transfers to third parties in the United States, ensuring they participate in the E.U.-U.S. Privacy Shield Framework.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA, including if you wish to request a copy of the relevant transfer mechanism.
14.6 EU-US Privacy Shield
Wayin complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and the United Kingdom. Wayin adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability with respect to all personal data received from the EU in reliance on the Privacy Shield program. Furthermore, we require any third party recipients of EU citizens’ personal data to agree to respect these principles, and we accept liability for third parties’ processing of EU citizens’ data to the extent required by law.
Wayin has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to JAMS, a non-profit alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint.
16. Contact Us
999 18th Street
Denver, CO 80202
67 Innovation Drive