Effective Date: January 22, 2023.
Thank you for downloading, accessing, and using the Both Wise website and app, including the associated social networking features and services. This privacy policy describes how we process and handle any personally identifiable information (personal information) and other information we collect when you access and use Both Wise.
Please, ensure you read and agree to this privacy policy (as well as other legal documents that apply to Both Wise) before you continue using Both Wise. By using Both Wise, you agree to how we handle your personal information.
Information Collection
Some of the pieces of information we collect are personal (i.e., they may be used to identify you). We also collect pieces of information that may not be used to identify you unless they are combined with other information. We may collect information directly from you, from third parties, or automatically.
Please note that you are not statutorily required to provide us with any personal information with respect to Both Wise. However, if you do not provide us with personal information, we may be unable to provide the Both Wise features and services.
The Information You Provide
• Registration and profile information: This may include your name, phone number, email address, date of birth and other demographics, area of expertise, location, likes, interests, photo, and so on. This information is collected on the Both Wise app.• Content information: This refers to the information contained in your user-generated content, especially those that are posted to your feed, and message boards, and those shared privately with other users. The information mayinclude pictures, comments, and other content.
• Communication information: We will retain any information you share in the conversation you hold with us, including via the Both Wise app and website, our email address, and other communication channels relating to Both Wise.
• Sensitive information: Some of the personal information you provide us when you register on the Both Wise app may be regarded as “sensitive information” under certain privacy laws because of their sensitive nature. Where we obtain this type of information, it will be based on your consent, and we will provide additional protection for it.
The Information We Obtain from Third Parties
We may obtain certain information about you from third parties. For example, our marketing partners may share the information they have about you with us for interest-based or behavioral marketing purposes.
The Information We Obtain Automatically
To get the best matches, secure and make Both Wise safe for all, and personalize your use, we collect certain information automatically when you access the Both Wise app (we do not collect this information on the website). This information may be collected through cookies, pixels, and third-party tracking tools and APIs. This information may include your:
• search criteria and inputs.
Permissions
To provide certain features, including importing your photos and enabling messages on the Both Wise app, we request permission to access your camera, gallery, file manager, push notification, and similar device permissions. You can withdraw your permissions at any time by going to the app settings function of your device.
Our Legal Bases for Collection
We are required to have legal bases (or lawful reasons) for collecting and using the information we collect. When we collect personal information, we rely on the below legal bases:
• Consent: The major personal information we process about you is done because you have given us informed consent to do so. If consent is not the basis for processing your personal information, the other legal bases below may apply.
• Legitimate interest: We process certain data (for example, where we collect verifiable information and usage analytics on the app)because it helps to safeguard our interest, secure Both Wise for us and other users, and help us gather the information that may be used to improve Both Wise.
• Complying with our legal obligations: In certain situations, we are required by the applicable law to collect and retain records for a period. In this case, we are collecting your data to comply with a legal obligation.
• Contractual obligation fulfillment: We process some of your data because we are required to fulfill a contract that exists between you and us (for example, where you opt in to receive marketing newsletters).
Information Uses
As already highlighted above, we use the information we collect majorly to provide Both Wise, connect users, secure Both Wise, comply with applicable laws, and protect our legitimate interest. Specific uses of your information include:
• to allow you to access certain features, provide Both Wise, create a profile for you, and match you with users that fit your profile.
• to establish communication with you, including sending you stuff about your account, your interactions, and new features, and respondingto your inquiries, queries, concerns, and feedback.
• to secure your account, verify your access and information, and ensure only you have access to your account.
• to secure Both Wise, investigate violations of our Terms of Service, prevent actions relating to fraud, and comply with applicable laws.
• to gather information about your interactions on Both Wise and use it to send adverts that are relevant to your behaviors.
• to perform any other actions described to you at the time of collection.
Cookies, Similar Technologies, and Third-Party APIs
We use third-party service providers and APIs on the app to provide some of the Both Wise features. These third parties may embed cookies, pixels, beacons, and similar technologies on Both Wise and their APIs to perform their services (for example, our analytics provider may embedcookies on user devices to gather usage and analytics information about user behaviors on the Both Wise app).
Cookies and similar technologies are used for certain purposes, including tracking user behaviors, movements, and traffic sources, and enabling certain functions on a website or app.
Nevertheless, you may choose to accept cookies from these third parties. You can control cookies by using the settings function of your device browser.
Information Disclosure
We do not directly share personal information about you other than within the circumstances described below.
Service Providers
As already highlighted under this privacy policy, we do not provide the Both Wise features alone. We hire third parties (service providers) to perform certain tasks such as data storage, hosting services, app distribution, marketing, etc. And it is necessary that we share relevant information with them for their services to be provided (for example, personal information may be exposed to Amazon because we use them for web services, including data storage).
Internal Disclosures
Some of the Both Wise features and services (such as support services) are provided by employees; therefore, your information may be exposed to such individuals. Also, we may disclose information to any parent, subsidiary, or affiliated entity and any authorized top-level staff on a need-to-know basis. However, they are bound by Non-Disclosure Agreements and are obligated to keep proprietary information about Both Wise confidential.
Marketing Partners
We use third parties for remarketing services. We may share the analytics and the usage information we gather about our users with our marketing partners to enable them to market Both Wise and its features on their platforms and other websitesand apps, and to measure how effective it is. Please, note that in this instance the information we share with marketing partners is very limited to IP address, geolocation, usage and analytics, etc., and this information is hashed (i.e., made anonymous).
Third-Party Advertisers
We may engage in practices that may be termed under applicable laws as “sharing for a monetary consideration.” We may share some of the personal information you provide to us through the Both Wise app, including your email address, location, likes, and interests, with third-party advertisers for them to target you with personalized ads relating to their products and services (this does not apply to any information you provide via the Both Wise website). Under applicable laws, users have the right to opt out of the sale of this information to third-party advertisers by opting out.
Both Wise users
Other users may be exposed to the information you share publicly, including on feeds, and message boards, and the user you engage in a private chat. Also, based on your privacy settings, the information on your profile may be available to people who navigate to your profile. Therefore, we advise you to be careful with the personal information you share in public parts of Both Wise.
Law Enforcement
We strive to always comply with applicable laws. Therefore, we may work with law enforcement and government offices to investigate any alleged illegal activities to protect Both Wise and other users. We will also assist public and private offices in the event of an alleged infringement of their intellectual property.
Other Companies in a Business Transfer
In the event that we engage in partnerships with other companies, including the sale of our assets, a merger, consolidation, acquisition, or case of bankruptcy, we may disclose personal information to the partner company if applicable.
Our Marketing Practices
To provide more personalized service and improve Both Wise and its offerings, we engage in certain marketing activities, which may involve the information we hold about you. Our marketing practices include:
Newsletter Marketing
We may, on occasion, send emails that advertise new Both Wise features and services to your email address. Such emails are sent to your email address because you have shown your willingness to receive them by ticking the newsletter marketing consent box on the app. However, you can always opt out of newsletter emails at any time by using the unsubscribe button/instruction at the bottom of any email you receive from Both Wise.
Push Notifications
We may send marketing messages via app push notifications based on your permission settings. If you do not want to receive marketing messages via push notifications, go to your app settings on your device and withdraw your permission.
Interest-Based Advertising
As already highlighted earlier under this privacy policy, we work with (or may work with) ad agencies, marketing platforms, and analytics third-party service providers who help us with marketing services, including anonymous usage and analytics information gathering, ad remarketing, and interest-based or targeted advertising. These service providers gather hashed or anonymousinformation on our behalf on Both Wise and combine this information with the ones in their database and use it to advertise Both Wise and its features across their platforms and other websites and apps.
If you wish to learn more about or opt out of interest-based advertising, please click here. If you are in the EU, please click here. Meanwhile, be aware that if you opt out of interest-based adverts, it will not prevent you from receiving generic or non-targeted ads.
International Transfer of Information
The Both Wise operation occurs in the United States where we and third-party service providers collect and process personal information. However, some of the third-party service providers we use may be located in countries outside of the United States. This means that personal information we hold about you may be collected, accessed, transferred, and used in locations that are different from the place in which you provided the information, and whose privacy laws may not be as adequate as your location laws. However, when we transfer personal information to third parties in locations with less strict laws, we ensure the party complies with the same level of privacy as us.
If we transfer personal information about users in the EU, EEA, UK, Brazil, and similar locations under the General Data Protection Regulation (GDPR) and Lei Geral de Protecao de Dados (LGPD), we employ standard, approved transfer mechanisms (for example, and where necessary, using the approved Standard Contractual Clauses).
Information Security
We employ commercially reasonable steps in protecting your personal information from unauthorized access, alteration, and use. And we do not collect more than the information we need to provide Both Wise to you. Also, we verify your account access by sending an OTP to your email address, which ensures it is you accessing your account. Furthermore, we store personal information with the industry’s best cloud storage provider, Amazon Web Service (AWS). And we also do not share personal information aside from the circumstances described in the section “Information Disclosure” above.
However, the transmission of information over the internet has not been proven to be 100% safe. Therefore, we cannot guarantee that unauthorized third parties will not access your information. You also have a part in ensuring the safety of your data. You should strive to keep your mobile number and phone away from third parties.
If you feel like an unauthorized person has accessed your account at any time, do not hesitate to reach out to us at info@bothwise.com to have us take the necessary actions.
Information Retention
We do not retain personal information for longer than we need it. Once you delete any post or content on Both Wise, it becomes unavailable to the public. Also, your account information is deleted from our database once you delete your account using the “Delete My Account” button in your account settings. However, certain information may persist for much longer in circumstances where we need it to comply with our legal obligations of keeping records or for business continuity.
Third-Party Links
Both Wise may contain content, adverts, or links that lead to third-party websites and content. Such links are not governed by this privacy policy; therefore, we do not warrant that their privacy practices are adequate or enough. We advise that you review the privacy practices of any third party before accessing their content and providing personal information to them.
Children Policy
Both Wise is not targeted at people under 17 years of age. We do not knowingly solicit personal information from people, who under the law, are regarded as minors. By using Both Wise, you represent that you are at least 17 years of age as stated in your application. If we learn that you are under 17 years of age, we reserve the right to terminate your account.
Your Privacy Rights
In addition to the other rights already established under this privacy policy, users generally have the following rights:
• The right to access and update information: You can access and delete the information we hold about you by using the edit function of your profile on the app. Please be aware that you may not be able to edit certain information if it helps us to prevent an act we think may be against ethical behavior.
• The right to delete your information: You may request that we delete your information by using the “Delete My Account” button in your profile area. Upon using this button, your profile and the information you have on Both Wise will be deleted. However, we may not delete certain information if (i) we are required by the applicable law to hold it (for example, our record-keeping obligation); (ii) we need it for evidence with respect to claims and queries; (iii) we need the information for business continuity; or (iv) we need it to enforce our Terms of Service.
Users in the EU and Brazil
If you are using Both Wise from locations under the GDPR and LGPD privacy laws, the following provisions and rights apply to you:
Your privacy laws provide you with the following rights concerning Both Wise (some of the rights below may be exercised through your Both Wise account area, while you may need to reach out to us via info@bothwise.com to exercise the rest):
• Right to access and rectify your data.
California Users
This section applies to you if you are using Both Wise from the State of California, US. It contains the categories of information we have collected, disclosed, and used about you in the past 12 calendar months, as well as the rights you have under the California Consumer Privacy Act (CCPA) and similar laws.
Information Collected
As already established under the “Information Collection” section of this privacy policy, we have collected the categories of personal information, including:
• Identifiers, such as your name, phone number, email address, device IP address, and other device properties.
This information has been collected directly from you, automatically through our use of third-party tools, and third-party sources.
Information Uses
The section titled “Information Uses” under this privacy policy describes why we collect and use personal information. To highlight, in the past 12 months, we have collected and used your information to provide you with Both Wise, including to communicate with you, personalize Both Wise, and enable interaction with other users, as well as to protect Both Wise, enforce our Terms of Service, and comply with applicable laws.
Information Disclosure
In the past 12 calendar months, we have disclosed personal information about you, as discussed in the section “Information Disclosure” above, to (i)third-party service providers, such as Google and Amazon; (ii) marketing partners, ad agencies, network, advertisers, and third-party advertisers; and (iii) other users (if you post content on public parts of Both Wise or chat with a user privately).
CCPA Rights
Your rights under the CCPA include:
• The right to demand that we provide you with the categories of personal information we have collected, disclosed, or used about you in the past 12 calendar months. We have collected the categories of personal information above in the past 12 calendar months.• The right to demand that we correct certain personal information we hold about you. You can correct any inaccurate information by using the edit function of your account.
• The right to demand that we delete the personal information we have collected about you – subject to certain exceptions. You may use the “Delete My Account” button in your account to request deletion.
• The right to demand that we stop selling personal information about you to third parties for their marketing purposes. You can exercise this right by toggling off the Do Not Sell My Personal Information feature shown to you when creating an account. Please, note that the information we share with third-party advertisers for their marketing purposes is limited to the information collected on the app. We do not share those collected via the website.
• The right to exercise any of your CCPA rights without being discriminated against.
You may also contact us at info@bothwise.com to exercise any of the rights above. Please note that we may attempt to verify that you are a Californian resident before we grant you these rights. Also, if you request that we delete your information, we may be unable to further provide Both Wise to you.
Do Not Track signals
Under the California Online Privacy Protection Act (CalOPPA), we are required to disclose if we respond to Do Not Track (DNT) signals or not. A DNT is a browser feature that, when activated, sends a signal to website owners to stop tracking your online activities. Unfortunately, the DNT feature is not consistent among industry participants at this moment. Therefore, we do not currently respond to DNT signals.
Shine the light law
California Civil Code 1798.83, also known as the “Shine the Light” law permits users residing in California to obtain from us, once a year and free of cost, a list of the third parties to whom we have disclosed personal information in the preceding year for their direct marketing purposes. You can make this request if you are a California resident by reaching out to us at info@bothwise.com. Please, confirm that you are a California user in your request by attaching your address.
Nevada Privacy Right
In addition to the rights established under this privacy policy, Nevada residents have, under Nevada law, the right to opt out of the sale of personal information about them to a third party for monetary consideration and for that third party to transfer the personal information to additional third parties.
Nevada users can request to opt out of any present or future sale of their personal information. You can make this request by reaching out to us at info@bothwise.com. Please be aware that we mayverify you to be sure you are a Nevada user before we comply.
Changes to Privacy Policy
As Both Wise evolves or applicable laws change, this privacy policy is subject to reviews and changes. Any changes we make to this privacy policy will go into effect immediately after such changes are made. We reserve the right to notify you of any changes to this privacy policy via any applicable means, including through your account, email address, or by displaying a notice on Both Wise. Nevertheless, you should always visit this page to watch out for any changes.
About Us; Data Controller
Both Wise and its social networking features areprovided by Fountous LLC. We handle and decide how your personal information is processed. We are the “Data Controller” as the term is defined under applicable laws. For any inquiries, issues, or feedback regarding our privacy practices, please contact us at info@bothwise.com.