Privacy Policy

Last updated March 06, 2022

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This privacy notice for Whyness Ltd ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Download and use our application(s), such as our mobile application — Whyness, or any other application of ours that links to this privacy notice

• Engage with us in other related ways ― including any sales, marketing, or events

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Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@whyness.co.uk.

 

SUMMARY OF KEY POINTS

 

This summary provides key points from our privacy notice.

 

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Whyness Ltd and the Services, the choices you make, and the products and features you use.

 

Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.

 

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid reason to do so.

 

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. We will never intentionally share your information with third parties without your consent and only ever in the interest of improving the quality of our Services and/or meeting our legal and ethical obligations. We will only share the minimum amount of personal information necessary to deliver our Services, while maintaining quality, accuracy, and reliability. We will never sell or share your data for commercial gain.

 

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. Keeping your data safe is of utmost importance to us and we do everything we can to manage and store your data securely. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

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1. WHAT INFORMATION DO WE COLLECT?

 

Personal information you disclose to us about yourself

 

In Short: We collect personal information that you provide to us. As far as possible, we minimise the personal information we ask you to provide to access our Services while meeting legal obligations and maintaining a good user experience.

 

We collect personal information that you voluntarily provide to us when you register for our Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

 

Beyond standard data required to access our Services, the nature of our Services means we are likely to process and produce highly sensitive information about you, including but not limited to your personal values, your life goals, your personality type, and the most important and/or traumatic life experiences that have made you who you are today. We treat this data with the utmost care and confidentiality.

 

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names

• phone numbers

• email addresses

• usernames

• passwords

• contact or authentication data, including biometrics

• job titles

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Sensitive Information

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When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• student data

• information revealing religious or philosophical beliefs

• information revealing your race, sex, age

• information revealing political opinions

• personal life and career experiences

• personal interests and hobbies

• personality traits

• voice recordings

• video recordings

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All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

 

Social Media Login Data

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We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

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Information you disclose to us about other people

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In Short: We collect personal information that you provide to us about other individuals.

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• Invites & referrals: If you choose to invite another user to track your progress or as a referral we will ask you for their email address and/or phone number and/or social media profile. We will use this data to invite him or her to join the product and will store it for the purpose of sending invitations and tracking the success of the referral programme.

• Personal insights: People you know on the platform (e.g. friends, family, colleagues) may ask you to provide information about them that will help with their own self-awareness and personal development. This includes but is not limited to specific personality traits and stories about their life and your observations of them. We will use this data to derive deeper insights about the individual, in order to help them with their personal and professional development and improve the accuracy of our job matching algorithms. This could include feedback from colleagues / managers relating to workplace performance.

 

Information automatically collected

 

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services

 

If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's microphone, storage, and other features.

• Mobile Device & Usage Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.

• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s).

 

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

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2. HOW & WHY WE PROCESS YOUR INFORMATION

 

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

 

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences.

• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest or the vital interests of a third party, such as to prevent harm. This may include sensitive information you reveal to us that could indicate issues relating to mental health, including suicidal thoughts. We do not take responsibility for monitoring all the data you provide in order to prevent or remedy any such issues, nor are our Services intended for clinical or health-related care or therapy. However, we endeavour to maintain high ethical and moral standards - we reserve the right to implement duty of care on behalf of our users, including but not limited to interventions that could prevent serious harm or loss of life to them or others.

• To generate personality type classification analytics. We may process your information to attempt to classify user's responses using neurolinguistic methods, psycho-analysis, personality tests, artificial intelligence and machine learning methods. This includes explorative, non-standard solutions and methods (in addition to standardised, tried and tested techniques).

• To match users with career development opportunities. We may process the information provided by you, or generated about you by our Services, to provide you personalised recommendations about job roles, employment opportunities, and personal and professional development opportunities.

• To train and improve our Machine Learning models. We may process your information to help improve the accuracy of our machine learning models and artificial intelligence algorithms.

• To get professional input to improve our Services. We may process your information to get professionals to review your profile, including the stories you have shared. For example, psychologists or personal development coaches that can provide supplementary insights and recommendations to our algorithms. Input from such professionals may also be used to design, train, and validate our models and rules.

• To prevent fraud and security risks. We may process your information to reduce threats from hackers and improve the security of our systems and protection of your data.

 

 

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

 

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

 

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, partners, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information include but are not limited to:

• Cloud Computing Services

• Data Analytics Services

• Data Storage Service Providers

• Performance Monitoring Tools

• Customer Relations Management Tools

• Customer Services Tools

• Fraud & Cybersecurity Tools

• Sales & Marketing Tools

• User Account Registration & Authentication Services

• Identity Verification Services

• Website Hosting Service Providers

• Product Engineering & Design Tools

• Personal & Professional Development Service Providers e.g. Coaches, Training Providers

 

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy notice. Affiliates include any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

• Employers. Where we have explicit consent from you to do so, we may share your information with perspective employers interested in hiring you for a placement or full-time role.

• Partners. We may share your information with other business partners to deliver Services to you, for example with recruitment agencies helping to find suitable job opportunities.

• Academic Partners. We may share your information with our academic partners supporting with the design, development, and delivery of our Services. Information may also be shared with them for research purposes relating to our Services, for example to provide datasets for the development of new Machine Learning models.

 

 

4. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

 

In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

 

Our Services may offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

 

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

 

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5. HOW LONG DO WE KEEP YOUR INFORMATION?

 

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

 

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

 

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

 

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

 

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

 

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7. DO WE COLLECT INFORMATION FROM MINORS?

 

In Short: We do not knowingly collect data from or market to children under 18 years of age.

 

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@whyness.co.uk.

 

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8. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

 

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

 

The General Data Protection Regulation (GDPR) require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. By accepting this Privacy Policy, you are providing your consent for us to use your personal information in the ways described throughout this policy documentation and the End User Agreement.

• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

  • Send users information about special offers and discounts on our products and services

  • Analyze how our services are used so we can improve them to engage and retain users

  • Understand how our users use our products and services so we can improve user experience

• Vital interest. We may process your information when necessary to save or protect an individual’s vital interest or the vital interests of a third party, such as to prevent harm.

 

In legal terms, we are generally the “data controller” under European data protection laws of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform. This privacy notice does not apply to any personal information we may process as a “data processor” on behalf of our business customers, partners and affiliates. In those situations, the customers, partners or affiliates that we provide services to and with whom we have entered into a data processing agreement is the “data controller” responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about the privacy practices of our customers, partners and affiliates, you should read their privacy policies and direct any questions you have to them.

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9. WHAT ARE YOUR DATA PROTECTION RIGHTS?

 

In Short: Your rights are governed General Data Protection Regulation (GDPR).

 

Under data protection law, you have rights including:

• Your right of access - You have the right to ask us for copies of your personal information.

• Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

• Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

• Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

• Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.

• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

 

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

 

Contact details can be found towards the end of the Privacy Policy.

 

Account Termination

 

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

 

If you have questions or comments about your privacy rights, you may email us at support@whyness.co.uk.

 

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10. DO WE MAKE UPDATES TO THIS NOTICE?

 

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

 

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

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11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

 

If you have questions or comments about this notice, you may email us at support@whyness.co.uk or by post to:

 

Whyness Ltd

63 High Street

Chislehurst BR7 5BE

United Kingdom

 

The "data controller" of your personal information is Whyness Ltd. Whyness Ltd has appointed it’s CEO Callum Denyer to be its representative. You can contact them directly regarding the processing of your information by Whyness Ltd, by email at callum.denyer@whyness.co.uk, by visiting whyness.co.uk, by phone at +447813663937, or by post.

 

You can also complain to the ICO if you are unhappy with how we have used your data.

 

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

 

Helpline number:

0303 123 1113

 

ICO website:

https://www.ico.org.uk

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