PRIVACY POLICY
1.0 Overview
1.1 Purpose
Ws Mode and its operating divisions, subsidiaries, affiliates and branches (collectively, “Ws Mode,” the “Company,” “we” or “us”) are sensitive to privacy issues, and it is important to us to protect the information provided to us. Accordingly, Ws Mode provides this privacy and information practices policy to inform you about our online information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can correct or change such information (“Privacy Policy”). By using the Ws Mode.com or the Ws Mode mobile app, you expressly consent to the information handling practices described in this notice.
1.2 Scope
This Privacy Policy applies to Personal Information that is Processed by Ws Mode in the course of our business, including on the Ws Mode.com website (the “Site”) and the Ws Mode mobile application (the “App”). All individuals whose responsibilities include the Processing of Personal Information on behalf of Ws Mode are expected to protect that data by adherence to this Privacy Policy. This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.
This Privacy Policy is incorporated into and is subject to the General Terms of Use. Your use of Ws Mode and any Personal Information you provide through Ws Mode are subject at all times to this Privacy Policy and the General Terms of Use. Terms for “Ws Mode” apply to any site or mobile application owned and operated by Ws Mode, Inc.
2.0 Transparency/Notice–What Personal Information We Collect and How We Use It
The types of Personal Information we may collect (directly from you or from Third Party-sources) and our privacy practices depend on the nature of the relationship you have with Ws Mode and the requirements of applicable law. We endeavour to collect information only relevant for the purposes of Processing. Below are the legal bases and some of the ways we collect information and how we use it.
2.1 Individuals
Ws Mode collects Personal Information regarding its current, prospective and former clients, customers, visitors and guests (collectively “Individuals”).
2.2 Information Ws Mode Collects
The data we collect from or about current, prospective and former Employees, customers, visitors and guests (collectively “Individuals”) includes information that may be deemed Personal Information, such as title, name, address, phone number, email address, user name, Internet Protocol address, and credit card and other financial information related to payments for services or goods.
2.3 How Ws Mode Collects Personal Information
1. Ws Mode may collect Personal Information from you through various channels, including the Site, the App, in surveys, during business or marketing events, and when delivering programs and services to you.
2. When you use the Site and the App, Ws Mode may provide you with opportunities to sign up to receive specific information or services and may ask for your contact information (e.g. name, e-mail address or personal email address), so that we can send you specific information about our products, services and specific health conditions, with your consent.
3. As you navigate Ws Mode, certain passive information may also be collected, including Internet Protocol addresses, cookies, navigational data, the name of the domain and host from which you access the Internet, the browser software you use and your operating system, the date and time you access Ws Mode, and the Internet address of the website from which you linked directly to Ws Mode. This type of information is used for the purposes of gathering data to provide improved administration of Ws Mode, and to improve the quality of your experience when interacting with Ws Mode.
2.4 Information from Third-Party Sources
We may collect information about you from third-party sources to supplement information provided by you. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you information about our business, products and services.
We may also offer you the ability to use Third Party services to enable additional features on Ws Mode. If you choose to do this, Ws Mode may receive information about you from these Third Parties.
2.5 Research/Survey Solicitations
From time to time, Ws Mode may perform research (online and offline) via surveys. We may engage Third Party-service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of the Site and the App, various types of communications, advertising campaigns and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analysis purposes.
2.6 How Ws Mode Uses Your Personal Information
Depending on how you interact with Ws Mode, we and our Third Party-service providers may also use Personal Information in a variety of ways, including:
Providing Information and Services You Requested. Ws Mode may use the Personal Information about you to provide you information that you may request, e.g. information about a product or program we are offering. Ws Mode may also use your Personal Information to deliver a specific program or service to you, when you enroll to receive the program or service. Such use may include: (a) generally managing your information and accounts; (b) responding to questions, comments and requests; (c) providing access to certain areas and features; and (d) permitting you to register for events or participate in webinars.
Administrative Purposes. Ws Mode may use the Personal Information about you for its administrative purposes, including, without limitation, to: (a) measure interest in Ws Mode’s Website, programs or services; (b) perform internal quality control; (c) verify identity; (d) send communications regarding the Ws Mode Website, programs or services, your account, or any changes to any Ws Mode policy or terms of service; (e) process payments; (f) prevent potentially prohibited or illegal activities; and (g) enforce our Terms of Use.
Marketing Products and Services. Ws Mode may use the Personal Information about you to provide you with materials about offers, products and services offered by us, including new content or services on Ws Mode. Ws Mode may provide you with these materials by phone, postal mail, facsimile or email, as permitted by applicable law. If you do not wish us to use your Personal Information for marketing purposes, you may contact us at any time to opt out of the use of your Personal Information for such purposes, as further described below.
Research and Development. Ws Mode may use your Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and services or develop new products, processes and services.
Information Submitted Via Ws Mode. You agree that Ws Mode is free to use the content of any communications or other information submitted by you via Ws Mode, excluding User Content, but including any narratives, images, ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or services. However, Ws Mode does not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a site will be published or otherwise used with your name on it; or (c) we are required to do so by law.
Sharing Content with Friends or Colleagues. Ws Mode may offer various tools and functionality. For example, Ws Mode may provide functionality that will allow you to forward or share certain content with a friend or colleague. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Ws Mode or any other Third Parties for any other purpose.
Fictitious Data. Including as discussed below in Section 2.12, Ws Mode may use and share your anonymized or aggregated information within the Ws Mode group of companies or with Third Parties for, research, analytics and any other legally permissible purposes.
Fraud protection. Ws Mode may use the Personal Information about you in order to prevent fraud and to protect the accuracy and integrity of financial transactions made through Ws Mode.com or the Ws Mode mobile app. Ws Mode may share the Personal Information with a third party service provider for such a purpose.
Other Uses. Ws Mode may use Personal Information for other purposes for which we have a legitimate interest, such as direct marketing, individual or market research, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
2.7 Human Resources Data
Ws Mode collects Personal Information from current, prospective and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave.
We acquire, hold, use and Process Human Resources-related Personal Information for a variety of business purposes including:
workflow management, assigning, managing and administering projects;
Human Resources administration and communication;
payroll and the provision of benefits;
compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labour laws, and company recognition programs;
job grading activities.
performance and employee development management.
organizational development and succession planning.
benefits and personnel administration.
absence management.
helpdesk and IT support services.
regulatory compliance.
internal and/or external or governmental compliance investigations.
internal or external audits.
litigation evaluation, prosecution and defence.
diversity and inclusion initiatives.
restructuring and relocation.
emergency contacts and services.
Employee safety.
compliance with statutory requirements.
Processing of Employee expenses and travel charges; and
acquisitions, divestitures and integrations.
2.8 Social Media
Generally, online social media resources are interactive tools that enable Data Subjects to collaborate and share information with others. Social media resources include, but are not limited to, social networks, discussion boards, bulletin boards, blogs, wikis, and referral functions to share web site content and tools with a friend or colleague.
Ws Mode may collect Personal Information to enable Data Subjects to use online social media resources offered either by Ws Mode or a Third Party. We may also enable you to use these social media resources to post or share Personal Information with others. When using social media resources, you should take into careful consideration what Personal Information you share with others.
If you use on online social media resource offered by a Third Party (“Third Party SMR”) through the Ws Mode Website, you acknowledge that Ws Mode may be able to access any information you make public through such Third Party SMR (such as your username, comments, posts and contacts) and other information your privacy settings on such Third Party SMR permit Ws Mode to access. Ws Mode will comply with the terms of this Privacy Policy and the privacy policies applicable to the social media resources it uses.
2.9 Direct Mail, Email and Outbound Telemarketing
Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings or phone calls from us with information on Ws Mode or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the individual by following the instructions in Section 3 below.
2.10 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
We, as well as Third Parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.
2.10.1 Cookies
Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
2.10.2 Pixel Tags/Web Beacons
A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
2.10.3 Social Media Widgets
Our Website includes social media features such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third Party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.
2.10.4 Analytics Information
We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behaviour and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visi www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our Site and App, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools;
Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you when you sign into our sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites
Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
2.11 Mobile Devices
Ws Mode may provide websites and online resources that are specifically designed to be compatible and used on mobile devices. Ws Mode will collect certain information that your mobile device sends when you use such websites or online resources, like a device identifier, user settings and the operating system of your device.
Mobile versions of Ws Mode may require that users log in with an account. In such cases, information about use of each mobile version of the website may be associated with user accounts. In addition, Ws Mode may enable Individuals to download an application, widget or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to Ws Mode to enable Data Subjects to access user accounts and to enable Ws Mode to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. Ws Mode may use personal or non-identifiable information transmitted to the Company to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices Ws Mode provides.
2.12 Anonymous and Aggregated Information
Ws Mode may use your Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Ws Mode Website or other online services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Site and App. Anonymized or aggregated information is not Personal Information, and Ws Mode may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes. We may share this information within Ws Mode and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
3.0 Choice/Modalities to Opt Out
You have the right to opt out of certain uses and disclosures of your Personal Information, as set out in this Privacy Policy.
3.1 General
Where you have consented to Ws Mode’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out by following the instructions in this Section 3. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out.
Prior to disclosing Sensitive Data to a Third Party or Processing Sensitive Data for a purpose other than its original purpose or the purpose authorized subsequently by the Data Subject, Ws Mode will endeavour to obtain each Data Subject’s explicit consent (opt-in). Where consent of the Data Subject for the Processing of Personal Information is otherwise required by law or contract, Ws Mode will comply with the law or contract.
3.2 Email and Telephone Communications
An “Unsubscribe” button will be provided at the top or bottom of each email communications sent by Ws Mode so that you can opt-out. However, we may continue to send transaction-related emails regarding products or services you have requested in response to such request. We may need to send you certain communications regarding the Ws Mode programs and services and you will not be able to opt out of those communications – e.g., communications regarding updates to our Terms of Use or this Privacy Policy.
3.3 Human Resources Data
With regard to Personal Information that Ws Mode receives in connection with the employment relationship, Ws Mode will use such Personal Information only for employment-related purposes as more fully described in section 2.3 above. If Ws Mode intends to use this Personal Information for any other purpose, the Company will provide the Data Subject with an opportunity to opt-out of such uses.
3.4 “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Ws Mode does not recognize or respond to browser-initiated DNT signals. For information about “do-not-track”, visit http://www.allaboutdnt.org.
4.0 Onward Transfer
4.1 Information We Share
Ws Mode does not sell or otherwise disclose Personal Information about you, except as described in this Privacy Policy or as you explicitly consent. Ws Mode endeavour s to require third parties to which it discloses Personal Information to protect Personal Information using substantially similar standards to those required by Ws Mode (and at least the same level of privacy protection as is required by the Privacy Shield Principles and this Privacy Policy), and to notify Ws Mode if they make a determination they can no longer meet this obligation.
4.1.1 Service Providers
Ws Mode may share Personal Information with our service providers that we have retained to perform services on our behalf including (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; and (iv) customer service activities. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders.
Ws Mode has executed appropriate contracts with the service providers that prohibit them from using or sharing your personal information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
4.1.2 Information Shared via Third Party Features
Ws Mode may offer additional features that allow you to share your information with a Third Party (like Waze). If you tell us to do so, Ws Mode will share limited amounts of information with the Third Party in order to enable the feature you choose. We will tell you what information the Third Party may receive when you initially instruct us to share it. Please be aware that any information you provide to a Third Party will be subject to that Third Party’s privacy policy.
Ws Mode will share your information for as long as you use the Third Party feature. You can disable this at any time in your Ws Mode settings under Settings.
4.1.3 Business Partners
Ws Mode may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested Ws Mode may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Ws Mode’s. Ws Mode requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which it was provided.
4.1.4 Information Disclosed for Our Protection and the Protection of Others
We may disclose information about you: (i) if we are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation; (iv) to enforce Ws Mode policies or contracts; (v) to collect amounts owed to Ws Mode; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
4.1.5 Information Disclosed in Connection with Business Transactions
We reserve the right to disclose or transfer any information we have about you in the event of a proposed or actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding). Should such an event occur, Ws Mode will endeavour to direct the transferee to use Personal Information in a manner that is consistent with this Privacy Policy.
4.2 Data Transfers
All Personal Information sent or collected via or by Ws Mode may be stored anywhere in the world, including but not limited to, in the United States, in the cloud, our servers, the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Ws Mode, you consent to the storage of your Personal Information in these locations.
5.0 Rights of Access, Rectification, Erasure and Restriction
You may seek confirmation regarding whether Ws Mode is processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may use any of the methods set out in this Privacy Policy to request access to, receive (port), restrict processing, seek rectification or request erasure of Personal Information held about you by Ws Mode. Such requests will be processed in line with local laws. Although Ws Mode makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Ws Mode is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Ws Mode determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Ws Mode will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
6.0 Retention
Ws Mode retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfil the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defences, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.
7.0 Security
The security of all Personal Information provided to Ws Mode is important to us, and Ws Mode takes reasonable steps designed to protect your Personal Information. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while Ws Mode strives to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to Ws Mode, and you do so at your own risk. You are responsible for maintaining the secrecy of your own passwords. If you have reason to believe that your passwords or Personal Information is no longer secure, please promptly notify us at info@WsMode.com.
8.0 Redress/Compliance and Accountability
If after reviewing this Privacy Policy, you would like to submit a request or you have any questions or privacy concerns, please contact us at info@WsMode.com.
Ws Mode will address your concerns and attempt to resolve any privacy issues in a timely manner.
If you are an EU or Swiss citizen and feel that Ws Mode is not abiding by the terms of this Privacy Policy, please contact Ws Mode at the contact information provided above. If any request remains unresolved, you may contact the national data protection authority for your EU Member State.
9.0 Other Rights and Important Information.
9.1 Information Regarding Children
Due to the nature of Ws Mode’s business, services and benefits are not marketed to persons less than 13 years of age (and in certain jurisdictions under the age of 16 (collectively “minors”).
If you are under 13 years of age (and in certain jurisdictions under the age of 16), then you may not use or access Ws Mode at any time or in any manner.
Protecting the privacy of young children is especially important. For that reason, Ws Mode does not knowingly collect or maintain personally identifiable information from minors. If Ws Mode learns that personally-identifiable information of minors has been collected on or through Ws Mode then Ws Mode will take the appropriate steps to delete this information.
If you are the parent or legal guardian of a minor who has become Ws Mode member, then please contact Ws Mode at info@WsMode.com to have that minor’s account terminated and information deleted.
The following are some resources that may help parents and legal guardians in monitoring and limiting your childrens’ access to certain types of material on the internet. While Ws Mode does not endorse these products, we are providing information about them as a public service to our community.
9.2 California Privacy Rights
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Ws Mode does not share Personal Information with third parties for their own marketing purposes.
9.3 Links to Third-Party Websites
Please note that Ws Mode may contain links to other websites for your convenience and information. Ws Mode does not control Third-Party websites or their privacy practices, which may differ from those set out in this Privacy Policy. Ws Mode does not endorse or make any representations about Third-Party websites. Any Personal Information you choose to give to unrelated Third Parties is not covered by this Privacy Policy. Ws Mode encourages you to review the privacy policy of any company or website before submitting your Personal Information. Some Third Parties may choose to share their users’ Personal Information with Ws Mode; that sharing is governed by that company’s privacy policy, not this Privacy Policy.
9.4 Changes to the Privacy Policy
Ws Mode may update this Privacy Policy from time to time as it deems necessary in its sole discretion. If there are any material changes to this Privacy Policy, Ws Mode will notify you by email or as otherwise required by applicable law. Ws Mode encourages you to review this Privacy Policy periodically to be informed regarding how Ws Mode is using and protecting your information and to be aware of any policy changes. Your continued relationship with Ws Mode after the posting or notice of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Policy will take effect immediately after being posted or otherwise provided by Ws Mode.
9.5 Contact Information
Please contact Ws Mode with any questions or comments about this privacy notice, your personal information, and our third-party disclosure practices or your consent choices at: Reach us by email by email: info@WsMode.com. We will respond to your inquiry within 30 days of its receipt.
Ws Mode Privacy Notice (Effective: September 17, 2020)
