CONSENT TO INSTALLATION OF THE APPLICATION
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 here and it is important that you read that information.
Before installation of this Application, please indicate your consent to our processing of your personal data (including your name, contact details and device information) in order to install this Application on your device, as described in the policy.
YES I consent to the installation of the Application.
NO I do not consent to the installation of the Application.
How you can withdraw consent
Once you provide consent by selecting “YES”, you may change your mind and withdraw consent at any time by contacting us firstname.lastname@example.org but that will not affect the lawfulness of any processing carried out before you withdraw your consent.
At Wunder we respect your privacy and are committed to protecting your personal data. In this policy, we explain how we collect and use your personal information when you visit our website, https://wunderworld.io/, (our “Website”), if you download and use our mobile or website application (our “Application”), and/or where you purchase Wunder coins within our Application.
Please note that links from our Website and/or Application may take you to external websites which are not operated by us or covered by this policy. We recommend that you check the privacy policies of such websites before submitting any personal information to them.
1. ABOUT US
The Website and Application are operated by Kindr International Limited (“we”, “us” and “our”). We are based at Unit 1, Marlow Workshops, Arnold Circus, London, E2 7JN and are the data controller for the purposes of the UK General Data Protection Regulation and Data Protection Act 2018 (together the “Data Protection Legislation”).
If you have any questions about your privacy rights, or our use of your personal data, please contact us.
2. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU AND HOW DO WE COLLECT THAT PERSONAL INFORMATION?
You are not required to provide personal information to us in order to browse our Website.
However, we will require you to provide your personal information if you wish to use our Application which will require you to register an account and if you use particular features on our Application, such as purchase Wunder coins via the Application. At all times, we will only require you to provide personal information to us where it is necessary for you to do so.
A. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?
We may collect personal information about you whenever you contact us or interact with us or use our platforms, including where you visit our Website, use our Application and/or purchase Wunder coins. This information may include:
- Contact and Identity Data: such as your full name, title, username or similar identifier, date of birth, marital status, email address, gender, billing address, email address, phone number and a copy of your passport and/or driving licence (which will contain personal data).
- Financial Data: such as bank account and payment card details.
- Location Data: such as your current location disclosed by GPS technology or other similar technologies.
- Transaction Data: such as details about purchases via the Application such as of Wunder coins and the tracking of how those Wunder coins are utilised within the Application.
- Device Data: such as the type of computer, tablet or mobile device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting.
- Content Data: such as information stored on the device that you use to access our Website and/or Application which may include login information or photos, videos or other digital content and any personal information (about you or others) contained in the content that you upload to our Application such as photographs, videos or other media. This includes any metadata associated with your content. Depending on the content that you upload on our Application, this may include Special Categories of Personal Data (see below).
- Content Recipients: names, email addresses and usernames of recipients that you choose to share your content with via our Application as well as any message that you choose to send alongside your content.
- Profile Data: such as your chosen username and password, chosen profile picture, purchase history, charitable affiliations, interests and preferences.
- Usage Data: includes details of your use of our Website and/or Application including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the profiles that you access.
Special Categories of Personal Data
We do not directly collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, health, sexual orientation, political opinions, or any trade union membership). Nor do we directly collect any information about criminal convictions and offences. We encourage you to not provide any special category data to us directly when you contact us or via your profile unless strictly necessary. Where you do provide any special category data to us, it will be assumed that you provide your consent for us to process it for the purposes for which it was provided by you.
If you do not provide Personal Data?
You are not required (by law or by any contract with us) to provide personal information to us. We will only require you to provide personal information to us where it is necessary for us to provide you with a service at your request.
If you fail to provide personal data when requested, we may not be able to provide access to our Application or you may not be able to use specific features such as to purchase Wunder coins.
B. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
We have different methods of collecting personal data from and about you, including via:
- Direct Interactions between us:
- You may provide us with information (including Contact and Identity Data, Content Data, Financial Data, Profile Data, Location Data) by contacting us through our Website or the Application, or email, or when downloading, registering with and using our Application or when you report an issue with our Application. If you contact us, we will keep a record of that correspondence.
- You may provide us with Financial Data and Transaction Data when you purchase the Wunder coins or purchase any additional features that we make available through our Application.
- Location Data: We also use GPS or other similar technologies to determine your current location. Some of our location-enabled services may require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings. If permission is not granted or location services are not enabled, functionality of the Application may not be the same.
- Third Parties or publicly available sources: We may receive personal data about you from other sources, including:
- information we receive about you if you use any of the other websites that we operate or the other services that we provide;
- information from third parties such as charities and businesses that also use our platform; and
- information from third parties that we work with to provide platform and the Wunder coins including payment providers and technical support companies.
1. HOW AND WHY DO WE USE YOUR PERSONAL INFORMATION?
We take data protection seriously and 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:
- Where we need to perform a contract we are about to enter into, or have entered into, with you. It is necessary for us to use your personal information in order to make our Application, including all of its features, available to you. When you access our Application and if you purchase the Wunder coins or create an account, there is a contract between us (please see our respective Terms and Conditions and End User Licence Agreement) and we need to use your personal data in order to perform our side of that contract.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interest. For example, using your information in this context is necessary so that we can improve our Application and ensure that we provide you with the best user experience possible. This may include troubleshooting problems, analysing statistics, conducting research and tests and keeping our Application secure.
- Where you have consented to the processing. We rely on your consent as a legal basis for processing your personal data in narrow situations, for example:
- To install the Application on your device
- Where you give us permission to access information that is stored on your device
- Where you upload content on to your profile on our Application that contains Special Category Personal Data (see above)
- To process your Location Data
You can withdraw your consent for this type of processing at any time. Where you do withdraw your consent, please note that this may mean that our Application, or some of its features, will no longer be available to you.
- Where we need to comply with a legal or regulatory obligation.
We have set out below, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground on which we are relying to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To install the Application and to register you as a new user of our Application (including to carry out identity verification checks), to administer your account and to contact you about your account, your orders and to respond to any support requests that you make.||(a) Contact & Identity|
Performance of a Contract
Necessary for our legitimate interests (to develop our services)
|To enable you to purchase and use Wunder coins, and to manage Wunder coins in our Application, and to enable you to use our Application (including for storing and sharing your content on our Application)||(a) Contact & Identity|
|Performance of a Contract|
Necessary for our legitimate interests (to develop our service)
|Moderating Content on our Application and protecting you and others from harm||(a) Content & Identity|
|Necessary to comply with a legal obligation|
Necessary for our legitimate interests (to protect our business)
|To manage our relationship with you, including:|
(b) Asking you to leave a review or take a satisfaction survey
|(a) Contact & Identity|
|Performance of a Contract|
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how individuals use our Wunder coins and services)
|To administer and protect our business, our Application and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Contact & Identity|
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)|
Necessary to comply with a legal obligation
|To deliver relevant content through our Application and our Website as well as advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Contact & Identity|
|Necessary for our legitimate interests (to study how individuals use our services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our services, our Application and our Website||(a) Device|
|Necessary for our legitimate interests (to define types of individuals who purchase and use Wunder coins, to keep our Application and our Website updated and relevant, and to develop and inform our marketing strategy)|
|To make suggestions and recommendations to you about users / profiles that may be of interest to you or services that may be of interest to you||(a) Contact & Identity|
|Necessary for our legitimate interests (to develop our services)|
Change of purpose
We will only use your personal information for the purposes for which we collected it, as set out above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent in compliance with the above rules, where this is required or permitted by law.
4. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
We may also share your personal data with the parties set out below for the purposes set out in the table at paragraph 3. These entities will not use your information to contact you. Selected third parties will be subject to obligations to process your personal information in compliance with the same safeguards that we deploy.
We may need to disclose your information to any one of the following:
- Third party service providers, for example: payment providers, telecommunications, IT and cloud computing systems, hosting providers, ID verification providers, CRM systems etc. acting as processors whom we engage to deliver our services (e.g., host our dialler system, electronic storing of your personal data).
- HM Revenue & Customs, Regulators (Financial Conduct Authority, The Charity Commission, Information Commissioner’s Office), and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Accountants, Solicitors, Compliance Consultants and other similar services based in the United Kingdom who require the reporting of processing activities in certain legal and compliance circumstances.
If you have any concerns about your personal information being shared, please contact us for more information.
There are certain exceptional circumstances in which we may disclose your information to other third parties. This would be where we believe that the disclosure is:
- Required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings.
- Necessary to protect the safety of our employees, our property or the public.
- Necessary for the prevention or detection of crime, including exchanging information with other companies or organisations for the purposes of fraud protection and credit risk reduction.
5. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
How long will we hold your personal data?
We will only retain your personal data for as long as we need it for the purposes for which it was collected (as set out in paragraph 3), as well as for any purposes necessary to satisfy any legal, accounting or reporting requirements.
By law we may have to keep basic information about our customers (which may include Contact, Identity, Financial and Transaction Data) for 6 (six) years after they cease being customers for tax purposes.
Where we do not need to retain basic information for legal reasons, the following will apply:
- Where we carry out verification of your ID, we will only process your ID documentation for the period of time necessary to verify your identification.
- If you create and maintain an account on our Application, we will retain any information you provide to us (for example, at least for as long as you keep your account on our Application and for a period of up to [12 (twelve) months] after you deactivate or delete your account.
- When you purchase Wunder coins, we will store this information only for as long as necessary in order to take payment. In most cases, this information is processed directly by the payment service provider, and we will not store or have access to full payment details that are sufficient to take payment from your account.
- Where you contact us, but you do not have an account on our Application and/or we don’t have an ongoing relationship with you, we will retain your information for a period of [12 (twelve) months], so that we can recognise you if you contact us again in the near future.
We may anonymise any of your personal data at some point, at which point it is no longer personal data.
In the event that you do not use the Application for a period of [12 (twelve) consecutive months] then we will treat your account as expired and your personal data may be deleted.
If you would like us to delete your personal information before the end of these periods, please contact us.
6. INTERNATIONAL TRANSFERS
We may transfer your personal data outside of the United Kingdom as some of our external third parties are based outside the United Kingdom so their processing of your personal data will involve a transfer of data outside the United Kingdom.
Whenever we transfer your personal data out of the United Kingdom, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
- Where we use certain service providers, we may use specific contracts approved by the United Kingdom which give personal data the same protection it has in the United Kingdom.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the United Kingdom.
7. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We try to ensure that all information you provide to us is transferred securely. Before submitting any personal information through our Website in particular, we recommend that you check for the padlock symbol in your browser and “https” in the URL. Unfortunately, the transmission of information via the internet is not always completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website or via Application; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
All information which you provide to us is stored on third party secure servers.
Where you have been provided with any passwords or other credentials which enable you to access certain parts of our Website or Application, you are responsible for keeping these details confidential.
8. WHAT RIGHTS DO YOU HAVE IN RESPECT OF YOUR PERSONAL INFORMATION?
In accordance with the current Data Protection Legislation, you are entitled to a range of specific data subject rights that you may exercise under particular conditions, with a few exceptions.
|Your right to ACCESS||You have the right to ask us to confirm whether or not we hold any of your personal data. If we do, you have the right to access a copy of your data, as well as information about how, and why, we use it. In order to prevent your data being disclosed to someone who is not authorised to access it, we may have to verify your identity before we provide you with a copy of the data that we hold.|
|Your right to RECTIFICATION||You have the right to have inaccurate or incomplete personal data that we hold about you rectified. This may involve providing a supplementary statement to the incomplete data.|
|Your right to ERASURE||Under certain circumstances, you have the have the right to have personal data erased. Also known as ‘the right to be forgotten’. This could be if:|
• The information is no longer needed for the original purpose for which we collected it.
• You withdraw your consent for us to use the information (and we have no other legal reason to keep using it).
• You object to us using your information and we have no overriding reason to keep using it.
• We have used your information unlawfully.
• We are subject to a legal requirement to delete your information.
In those situations, you have the right to have your personal data deleted. If you believe that one of these situations applies to you, please contact us
|Your right to RESTRICT PROCESSING||Under certain circumstances, you have the right to request the restriction or suppression of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:|
• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend a legal claim.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
|Your right to DATA PORTABILITY||Where your personal data is processed by automated means, you may have the right to obtain a copy of your personal data in a structured, commonly used and machine-readable format, and to ask us to transfer this data to another organisation in a safe and secure way.|
|Your right to OBJECT||You have the right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.|
|Your right to be INFORMED||We have a legal obligation to provide you with concise, transparent, intelligible and easily accessible information about your personal information and our use of it. We have written this policy for that purpose, but please contact us if you require further information.|
|Your right to WITHDRAW CONSENT||You have the right to withdraw your consent at any time where we rely on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, you may not be able to access or use the Application or certain features of the Application.|
This version was created in October 2021 and where they exist, historic versions can be obtained by contacting us.
If you wish to make a complaint about our collection or use of your personal data, we ask that you please contact us in the first instance so that we may seek to resolve your complaint.
You have the right to lodge a complaint with the relevant supervisory authorities that oversee data protection law. In the UK, you may contact the Information Commissioner’s Office if you wish to make a complaint.
11. CONTACT US
If you wish to speak to us regarding your privacy, or our use of your personal data, please contact us using the following details:
Full Name: Kindr International Limited
Post: Unit 1, Marlow Workshops, Arnold Circus, London, E2 7JN