Wish Collaboration Platform Privacy Policy

Wish Collaboration and its subsidiaries and affiliates (collectively, “Wish Collaboration,” “we” or “us”) understand the importance of privacy.  This privacy policy (the “Policy”) explains how Wish Collaboration collects, stores, uses and shares personal information collected, stored or processed by us through Wish Collaboration’s Virtual Communication Platform, which includes services related to our Webcasts, Virtual Environments, Channels, and Portals (collectively, the “Platform”).

In this policy, “personal information” is information that identifies or could be used to identify an individual.

The Wish Collaboration Platform is a tool used by businesses, including direct customers of Wish Collaboration, as well as customers who have subscribed, signed up or otherwise accessed the Platform through a Wish Collaboration reseller (the “Business Customers”).  As such we collect information which may include personal information from Business Customers, as well as their employees, agents and end users (the “End Users”).  Collectively, End Users and Business Customers are “Platform Users”.

Wish Collaboration may update this Policy from time-to-time, so please review it frequently. In the event we make material changes in the way we treat user personal information, we will notify you by email.

1. Scope

This policy applies to the personal information that Wish Collaboration’s Business Customers submit to us via the Platform, as well as the personal information we collect, access, store, use or otherwise process (collectively, “process”) via the Platform on behalf of Business Customers, including the personal information we process from End Users of the Platform.  Wish Collaboration is a data processor on behalf of Business Customers (who are data controllers with respect to the User personal information collected and processed by us via the Platform).  This Policy does not apply to Business Customers use of personal information collected via the Platform, which is subject to their own policies and practices.

2. Data Collected

Information Collected Directly

Account Information. To access various parts of the Wish Collaboration Virtual Communications Platform, you may be required to register or set up an online account. This process often requires you to provide certain personal information such as your name, email address, telephone number, company name and job title as well as information about your company such as country and industry sector. We may also collect user profile information such as age, gender, zip, and areas of special interest to you.

User Communications. When you send email or other communication to Wish Collaboration or another user, we may retain those communications in order to process your enquiries, respond to your requests and to improve our services.

Affiliated Sites.  We may offer services in connection with other websites or suppliers. Personal information that you provide to those sites may be sent to us in order to deliver these services. We process such information in accordance with this Policy.

Other Information.Wish Collaboration’s Business Customers may request additional information, like surveys or polls, be filled out in some webinars or virtual environments.  Business Customers are responsible for configuring the Platform to collect such personal information.

Information Collected Automatically

Log Information.  When you use Wish Collaboration, our servers record, in a server log, information that your browser sends whenever you visit a website. Server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.

Cookies, clear GIFs, etc. Our Platform may use cookies (small pieces of information that are stored by your browser on your computer’s hard drive), clear GIFs, java script and other technology to collect and store information about your use of the Platform, such as your search activity, the pages you view, and the date and time of your visit, your browser type, type of computer or mobile device, browser language, IP address, mobile carrier, unique device identifier, location information, and requested and referring URLs.  We may combine this information with other information that we have collected about you, including, where applicable, your user name, name, and other personal information.  Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

Aggregate and De-Identified Information

Wish Collaboration may process (i.e., collect, use and disclose) aggregate de-identified information, and other information that is not personally identifiable, for research, analytics and other purposes, provided such information does not identify, and could not reasonably be used to identify a particular Business Customer or End User.

3. Our lawful basis for using information about you

When we Use your Personal Data in connection with the purposes set out in this Privacy Statement, we may rely on one or more of the following legal bases, depending on the purpose for which your Personal Data was collected and our relationship with you:

• Performance of contract:To provide our products, services and solutions as specified in our contract.
• Our legitimate business interests:To protect our legitimate business interests or those of a third party with whom we share your Personal Data. Whenever we rely on this lawful basis to Use your Personal Data, we assess our business interests to ensure that they do not override your rights. Additionally, you may have the right to object to our Use of your Personal Data in certain circumstances. See ‘Your Personal Data Rights’ section of this Privacy Statement.
• Compliance with a mandatory legal obligation: To ensure that we comply with applicable laws and regulations that govern and regulate how we do business.
• Consent:Where you have provided consent to the Use of your Personal Data.

4. Use of Information

Wish Collaboration uses the personal information we collect via the Platform to provide our services to Business Customers, including to operate and improve the Platform and our services, to provision Platform Users’ accounts, to carry out the transactions Platform Users request via the Platform, and to respond to Platform User requests.

As noted above, Wish Collaboration is a data processor of the personal information collected via the Platform. Business Customers are data controllers with respect to Platform User personal information; this Policy does not apply to the processing (including collection, use and sharing) of Platform User personal information by Business Customers.

Business Customers may use the personal information they collect via the Platform for additional purposes, such as to deliver targeted content within the Platform, to contact End Users about their use of the Platform, for marketing and promotional purposes, and for other purpose; you should review their privacy policies for more information about how they collect, use and share the personal information collected via the Platform.

5. Sharing of Information; Onward Transfers

As noted, Platform User information, including End User personal information, is shared with the Business Customer upon whose behalf the information was collected or Platform is being operated; this Policy does not apply to the processing (including collection, use and sharing) of Platform User personal information by Business Customers, and we are not responsible for such processing.

Wish Collaboration will not share personal information about Platform Users with third parties except to provide the products or services you have requested, with consent, or under the following circumstances:

• We will make personal information available to the Business Customer on whose behalf the personal information has been collected, as explained above.
• We may provide personal information to our agents, service providers, contractors and others acting on our behalf. These parties do not have any independent right to use or share this information.
• We may disclose the information we collect from you to Wish Collaboration affiliates and subsidiaries; however, if we do so, their use and disclosure of your information will be subject to this Policy.

Third parties who process personal information on our behalf must agree to use such personal information only for the purpose for which it is provided by us and they must contractually agree to provide adequate protections for personal information; Wish Collaboration will continue to be liable for any onward transfers of personal information to such third parties.

We may also disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, as well as where is necessary to satisfy any applicable law, regulation, legal process or enforceable government request, to enforce our User Agreement and investigate violations thereof, to prevent, detect and address fraud, security or technical issues, or to protect against harm to the rights and property of Wish Collaboration.  If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company (including as due diligence and for other purposes prior to the closing of such a transaction), or as part of a bankruptcy proceeding, we may transfer the information we have collected (including personal information) to the acquiring company.

6. Accessing, Amending and Limiting Use of Your Personal Information

Individuals have the right to access the personal information that is maintained about them, and in some cases to limit use and disclosure of such information.  Registered Platform Users may log into their accounts to view and amend certain personal information in their profile.  EU Platform Users who would like to request access to, to limit use of, or to limit disclosure of their personal information collected via the Platform by a Business Customer should contact that Business Customer directly; EU Platform Users may also make such requests by contacting us at customercare@wishcollaboration.com and providing the name of the Business Customer. We will refer such requests to that Business Customer and will support them as needed in responding to your request.

7. Security

To secure your personal information, access to your data is password protected, and sensitive information is protected by encryption when it is exchanged between your Web browser and our Web site. It is your responsibility to keep your password confidential and not to share this information with anyone. While we will implement the security measures detailed above, transmission of information via the internet is not completely secure and therefore transmission via the internet is at your own risk.

8. Complaints and Disputes

Individual Platform Users who have any questions, complaints, or disputes regarding this Policy or the manner in which Wish Collaboration handles or protects personal information may contact us at customercare@wishcollaboration.com.  We will promptly investigate and attempt to resolve any complaints and disputes, and will respond within 45 days of receiving any such complaint.

9. Contact Us

Please email us at customercare@wishcollaboration.com with any questions about this Policy.