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Privacy Policy

Privacy Policy

WR1 Inc (together with its parent company and subsidiaries, if any, “WR1”) operates the WR1 website (the “Site”) and related mobile applications and software (collectively with the Site, the “Service”), which enable people to create and subscribe to content channels and access exclusive text, voice notes, audio clips, videos, photos, live broadcasts, direct events (collectively, “Content”) all in real time. The Content is available for free or at premium at the Channel Holder discretion to share and subscribe.

WR1 is committed to respecting and protecting your privacy. To that end, we have prepared this privacy policy (“Privacy Policy”) to describe our information gathering and dissemination practices and our data protection practices for the Service. The terms “WR1,” “we,” “us,” and “our” refer to WR1 and its subsidiaries. The terms “you,” “your,” and “yours” refer to the user/customer utilizing the Service. This Privacy Policy is governed by our Terms of Use.

Children 
The Service is not intended for or directed to persons under the age of 13, and we will not knowingly collect information from such persons. Any person who provides information to us through registration or in any other manner on the Site or the Service represents to WR1 that they are 13 years of age or older. If we learn that a child under 13 has submitted personal information to us, we will attempt to delete the information as soon as possible. If you believe that a child has provided us with personal information, please contact us at support@WR1.com.

Collection of Information 
“Personally Identifiable Information” means any information which can be used to identify an individual, and may include, but is not limited to, name, email address, postal or other physical address, title, or occupation.

We may collect the following Personally Identifiable Information from you when you register for or use the Service: name, email, phone number, credit card payment information, other payment information, and billing address.

We may collect information when you register to join the Service by logging into an account that you already have with certain third-party social networking sites (“SNS”) (including, but not limited to, Facebook and Twitter) via the Service. By connecting to the Service with SNS, you give us permission to access, store and use your information from the SNS, including, but not limited to, your Personally Identifiable Information, any information that you have permitted the SNS to share with us, any information you have made public in connection with that service, any interests that are not hidden and mutual friends that you may have in common with another users. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the Service.

To participate in certain activities and to obtain certain services or documents offered on or through the Service, you may be asked to provide or share additional Personally Identifiable Information. We endeavor to limit our requests for Personally Identifiable Information to information we believe is reasonably necessary to achieve our purposes as described in the “Information Use” section below. You can choose not to provide us with certain information, but then you might not be able to take advantage of many of the Service’s features. Any Personally Identifiable Information received in communication or in material you transmit to WR1 by electronic mail or otherwise are and will be treated in accordance with this Privacy Policy.

We also automatically receive and record information on our server logs from your browser, including without limitation your IP address, cookie information (as described below), and the page(s) you request.

We also reserve the right to anonymously track and report a user’s activity inside the Site and mobile applications.

Cookies 
Some of the pages on the Site may contain “cookies.” A cookie is a small data file that may be sent to your Web browser and stored on your computer. This allows our server to “recognize” you when your computer visits the Site in the future. Most Web browsers can be configured to not accept cookies, or to notify you if a cookie is sent to you. In some instances, WR1 may collect non-Personally Identifiable Information (aggregate or demographic data) through cookies.

Information Use 
WR1 uses Personally Identifiable Information for several general purposes:

  • to provide you with product and service information, demos, and news regarding the Service,
  • to support the products and services offered on or through the Service,
  • to fulfill your subscription requests,
  • to process your payments including credit checks and collection,
  • to notify you of technical updates or changes in policy, or

We may use non-Personally Identifiable Information such as demographic data to analyze and develop our marketing strategy and further improve the Service and our other products and services.

You also may have the option to import your personal contacts (including email addresses of friend lists via SNS) to the Service so that you can find your friends on the Service, and your friends can find you on the Service.

Information Sharing and Disclosure 
We will not sell or rent your Personally Identifiable Information to third parties except as described in this Privacy Policy. We may disclose your Personally Identifiable Information to other companies or people under any of the following circumstances:

  • when we have your consent to share the information.
  • to those of our content providers or business partners from which you receive content and/or services (“users”).
  • if sharing the information is reasonably necessary to provide a product or service that you have requested.
  • to keep you up to date on the latest Service announcements, special offers, or other information we think you would like to hear about either from us or from our partners.
  • if we believe in good faith that we are required to do so by law, in connection with litigation, to prevent a crime, or to protect personal safety, the public, or the Service.
  • in connection with a sale of stock or assets, reorganization, consolidation, merger with another entity, or if WR1 should ever file for bankruptcy or have its assets sold to another entity.
  • WR1 may also share non-Personally Identifiable Information, such as aggregate or demographic data, with third parties.

We may share the information in your WR1 account (including your Personally Identifiable Information) with the SNSs that you have linked to your account. These third parties have access to your Personally Identifiable Information only for this purpose (unless the SNS has received your Personally Identifiable Information independently of the Service) and not for other purposes.

Third Party Privacy Policies 
As described in this Privacy Policy, WR1 may share your Personally Identifiable Information with our users and/or business partners. Additionally, the Service may contain links to other sites. We encourage our users to be aware when leaving the Site or the Service to read the privacy statements of each site that collects Personally Identifiable Information, as those sites are solely responsible for such policies and protections.

You should also be aware that if you submit information to “comments feeds” and similar public communications channels, through the Service or otherwise, then such information becomes public information, meaning that you risk losing any privacy rights you might have with regards to that information. Such disclosures may also increase your chances of receiving unwanted communications from third parties.

Access 
You may correct, amend, or delete your Personally Identifiable Information by editing your profile on the Site or emailing us at support@WR1.com.

Security 
We are committed to protecting Personally Identifiable Information from loss, misuse, disclosure, alteration, unauthorized access, and destruction. WR1 takes reasonable precautions to safeguard the confidentiality of Personally Identifiable Information. We protect the security of your Personally Identifiable Information during transmission to us by using Secure Sockets Layer (SSL) software, which encrypts the information you input. While we strive to protect your Personally Identifiable Information, we cannot ensure the security of the information you transmit to us in all cases.

International Transfers 
Personally Identifiable Information collected on or through the Service may be stored and processed in the United States or any other country in which WR1 or its affiliates, subsidiaries or agents maintain facilities, and by using the Service, you consent to any such transfer of information outside of your country.

Your Consent to this Privacy Policy 
By using the Service, you agree to this Privacy Policy. We may occasionally update this Privacy Policy in our sole discretion. The date of the most recent update of this document will always be displayed at the bottom of this Privacy Policy. If we decide to use Personally Identifiable Information in a manner different from that stated at the time it was collected, we will notify users by email (the email address provided) or by posting the updated version of this Privacy Policy on the Site. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the Personally Identifiable Information we collect. Your continued use of the Service constitutes your agreement to this Privacy Policy and any updates.

Contacting WR1 
If you have any questions, comments, or concerns about this Privacy Policy, please email us at support@WR1.com.

EU Addendum to Privacy Policy

Effective date: May 24, 2018

Thank you for using WR1! We take your privacy extremely seriously and would like to describe how we collect, use and protect your information when you access our website(s), products, services and applications (collectively, the “Services”).

EU Residents

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this GDPR Privacy Notice, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. WR1 Inc. (“WR1”) will be the controller of your Personal Data processed in connection with the Services.

Where applicable, this GDPR Privacy Notice is intended to supplement, and not replace, WR1’s Privacy Policy at http://www.wr1.com/privacy-policy (the “Privacy Policy”). If there are any conflicts between this GDPR Privacy Notice and WR1’s Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this notice or whether any of the following applies to you, please contact us at support@wr1.com.

Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of Services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

What Personal Data Do We Collect From You?

We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

  • Personal Contact Details: Full Name, Address, E-mail Address, Phone Number, Birthday Date, Country & City of Residence
    • Purpose for Prospects: We process this type of Personal Data in order to market our Services to potential customers who have requested demonstrations of our Services.
      • Legal Grounds: We process this type of Personal Data based on the consent you expressly grant to us at the time we collect such Personal Data.
    • Purpose for Customers: We process this type of Personal Data in order to create an account for you and to provide you our Services.
      •  Legal Grounds: We process this type of Personal Data for our legitimate interests in providing the Services and associated support.
  • Other Personal Details: Type of Browser, page and/or feature selection, certain cookie information, Device type, Device ID, IP Address and associated Location Data
    • Purpose: We process this type of Personal Data in order to provide you our Services.
      • Legal Grounds: We process this type of Personal Data for our legitimate interests in providing the Services and performing web analytics to improve the Services and understand how our customers interact with the Services.

How and With Whom Do We Share Your Data?

We share Personal Data with third party service providers, other clients of our Services and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service.

We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:

  • Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services)
  • Social media services (if you interact with them through your use of the Services)
  • Third party business partners who you access through the Services (e.g. third party applications)
  • Other parties authorized by you

We also share information with third parties when you have given us consent to do so (as indicated at the point such information is collected).

We also share Personal Data when we believe it is necessary to:

  • Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
  • Protect us, our business or our users, for example to enforce our Terms of Service, prevent spam or other unwanted communications and investigate or protect against fraud
  • Maintain the security of our products and services

If we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

How Long Do We Retain Your Personal Data?

We retain Personal Data about you for as long as you have an open account with us and for 6 months after you close your account. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally. However, user signup data (your name, your email address, and the fact that you were a WR1 user) may be retained in third-party analytics services beyond closure of your account, unless you request that your data be deleted.

Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device which may include “cookie” information. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. Note that in the past, WR1 used cookies with longer expiration times. Delete your cookies to get the new cookies.

What Security Measures Do We Use?

We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. For example, WR1 is continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction or alteration. Some of the safeguards we use to protect Personal Data are firewalls, data encryption, and information access controls.

Personal Data of Children

As noted in our Terms of Use at http://www.wr1.com/terms-of-use/, we do not knowingly collect or solicit Personal Data from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us Personal Data, please contact us at support@wr1.com.

What Rights Do You Have Regarding Your Personal Data?

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email support@wr1.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

  • Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by accessing your account settings.
  • Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by accessing your account settings.
  • Erasure: You can request that we erase some or all of your Personal Data from our systems.
  • Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
  • Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
  • Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
  • Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
  • Right to File Complaint: You have the right to lodge a complaint about WR1’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Transfers of Personal Data

The Services are hosted and operated in USA, specifically, hosted in Oregon and operated from USA, through WR1 and its service providers. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to WR1 in USA and will be hosted on servers in USA, and you authorize WR1 to transfer, store and process your information to and in the USA and possibly other countries.

What If You Have Questions Regarding Your Personal Data?

If you have any questions about this GDPR Privacy Notice or our data practices generally, please contact us using the following information:

Name: WR1 Inc.

Physical address:

25 W 39th Street
New York City, NY 10018
USA

Email address for contact: support@wr1.com

WR1 Inc.
25 W 39th Street
New York City, NY 10018
USA

https://wr1.com · support@wr1.com