Privacy Notice

Important information and who we are

Mafavi Ventures Ltd (trading as Wemby) is the controller and is responsible for your personal data (collectively referred to as “Wemby”, “we”, “us” or “our” in this policy).

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in this notice and it is important that you read that information.

You have the right to make a complaint at any time to the Data Protection Authority applicable to your location.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy notice under regular review.

This version was last updated on 16 August 2020. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Wemby’s App may, from time to time, contain links to and from the websites of its partners, affiliates and third parties it engages with. Please note that these websites and any services that may be accessible through them have their own privacy notices and that Wemby does not accept any responsibility or liability for these notices or for any personal data that may be collected or processed through these websites or services, such as contact and location data. Please read these notices before you submit any personal data to these websites or use these services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows and as described below:

We also collect, use and share Aggregated Data such as statistical or demographic data for the purposes of maintaining and improving our services. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

How is your personal data collected?

We will collect and process the following data about you:

Cookies

We use cookies to distinguish you from other users of the App, the distribution platform (Appstore) or Services and to remember your preferences. This helps us to provide you with a good experience when you use the App and also allows us to improve the App and our Services. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

Purposes for which we will use your personal data

Purpose/activity

Type of data

Lawful basis for processing

To install the App and register you as a new App user

Identity

Contact

Financial

Device

Your consent

To process in-App purchases and deliver Services including managing payments and collecting money owed to us

Identity

Contact

Financial

Transaction

Device

Marketing and Communications

Location

Your consent

Performance of a contract with you

Necessary for our legitimate interests (including to recover debts due to us)

To manage our relationship with you including notifying you of changes to the App or any Services

Identity

Contact

Financial

Profile

Marketing and Communications

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

To enable you to participate in a prize draw, competition or complete a survey

Identity

Contact

Device

Profile

Marketing and Communications

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

To administer and protect our business and this App including troubleshooting, data analysis and system testing

Identity

Contact

Device

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

To deliver content and advertisements to you

To make recommendations to you about goods or services which may interest you

To measure and analyse the effectiveness of the content we serve you

To monitor trends so we can improve the App

Identity

Contact

Device

Content

Profile

Usage

Marketing and Communications

Location

Consent

Necessary for our legitimate interests (to develop our products/Services and grow our business)

To share your special category data:

  • With your consent

  • Where there is a concern about your or someone else’s safety

  • If there is a legal obligation to do so

Identity

Contact

Health

Your explicit Consent

Protect the vital interest of you or of another person

Necessary for the purposes of preventive or occupational medicine, medical diagnosis, the provision of health or social care or treatment

Necessary for the establishment, exercise or defence of legal claims

Disclosures of your personal data

We may share your personal data with the third parties for the purposes set out in the table Purposes for which we will use your personal data:

International transfers

Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access the App or the Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, including: storage on encrypted servers using AES256 algorithms and compliant with ISO 27001, ISO 27017 and ISO 270188 security standards.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.

In some circumstances you can ask us to delete your data: see [Your legal rights] below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the App for a period of 18 months then we will treat the account as expired and your personal data may be deleted.

Your legal rights

Under certain circumstances you may have the following rights under data protection laws in relation to your personal data:

Your right of access

 

Your right to rectification

 

Your right to erasure

 

Your right to restriction of processing

 

Your right to object to processing

 

Your right to data portability

 

Your right to withdraw consent

You can exercise any of these rights at any time by contacting us at .