Last Updated on: December 5, 2019
WTPEOPLE is committed to protecting the privacy of visitors to our website, subscribers to our newsletters, and those providing contact information.
WHAT INFORMATION DO WE COLLECT & HOW IS IT USED?
Information You Voluntarily Submit to the Website: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, register for access to the Website or purchase products or services from the Website. Personal Data may include, but is not limited to, the below:
- Your name and email address
- Phone number
- Zip Code
- Street Address
Information We Collect from Others: We may receive information about you from other sources. For example, if you use a third-party software through the site, they may transfer information to us for fulfillment. For more information about our use of third-party providers, please see below.
Automatically-Collected Information: We automatically collect certain information about you and the device with which you access WTPEOPLE. For example, when you use WTPEOPLE, we will log your IP address, operating system type, browser type, referring website, pages you viewed, and the dates/times when you accessed the website. We may also collect information about actions you take when using WTPEOPLE, such as links clicked.
HOW YOUR PERSONAL INFORMATION MAY BE USED
WTPEOPLE, and our subsidiaries and affiliates (the “Related Companies”), may use your personal information in the following ways:
- To operate and maintain the website;
- To create your account, identify you as a user of the website, and customize the website to your account;
- To send you promotional information, such as newsletters. Each e-mail newsletter will provide information on how to opt-out of future mailings by unsubscribing;
- To send you administrative communications, such as administrative e-mails, confirmation e-mails, technical notices, updates on policies, or security alerts;
- To respond to your comments or inquiries;
- To provide you with user support;
- To track and measure website performance;
- To process payment for purchases you make through WTPEOPLE;
- To protect, investigate, and deter against unauthorized or illegal activity;
- To review the effectiveness of our marketing programs and analyze other general demographic trends;
- To notify you of new information or services that may be of interest to you; or,
- To send promotional materials.
LEGAL BASES FOR PROCESSING DATA UNDER THE GENERAL DATA PROTECTION REGULATION (“GDPR”)
Below are the types of lawful basis that we will rely on to process your Personal Data:
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal or regulatory obligation means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject.
- Consent means where you have consented to a certain use of your Personal Data.
DOES WTPEOPLE SHARE MY INFORMATION?
WTPEOPLE will not share, rent, or sell your personally identifiable information with third-parties. We may, however, share your information with third-parties when we are authorized to share such information.
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
Third Parties with Permission: We may share your information with third parties to whom you ask us to send your information.
Agents, Consultants, and Related Third Parties: WTPEOPLE, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
Legal Requirements: WTPEOPLE may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity or in connection with our own investigation of suspected or actual illegal activity, in which case we may (and you hereby authorize us to) disclose information without subpoenas or warrants served on us, (ii) protect and defend the rights or property of WTPEOPLE (iii) act in urgent circumstances to protect the personal safety of users of the Website or the public, (iv) protect against legal liability including to resolve disputes, investigate problems, or enforce our Customer contracts.
Tracking: WTPEOPLE uses various marketing tools that help us create a better user experience for people visiting our site. These tools allow us to look at aggregated data such as scrolling patterns, clicks, and allow us to run tests to determine which pages result in the best actions. However, your personally identifiable information is not used by any of these tools. We use the following third-party service providers for tracking:
Remarketing: WTPEOPLE uses remarketing tracking cookies and conversion pixels from vendors such as Google and Facebook to present special offers to you for our products or services over the Google Content Network and via social networks. This means you may see an ad for one of our products or services as a result of visiting our website. In addition, WTPEOPLE uses custom audiences based on e-mails and phone numbers of subscribers and customers. This allows us to present special offers for our products and services to you via Facebook and Google. However, your personally identifiable information is not used by any remarketing service other than to present you special offers from us. We use the following third-party service providers for remarketing:
Facebook: Opt-out of Facebook remarketing here
Newsletters: WTPEOPLE uses different ESPs. Through them, we collect contact information, distributes our newsletter, and tracks actions you take that assist us in measuring the performance of the website and newsletters. Upon subscription, we also track the pages you visit on the website through them.
Our newsletters contain tracking pixels. This pixel is embedded in e-mails and allows us to analyze the success of our newsletters. Because of these tracking pixels, we may see if and when you open an e-mail, which links within the e-mail you click, and the pages you visit on our website. This behavior is not passed to third-parties. All data submitted at the time of subscription to our newsletter is stored on the ESP’s servers.
Contact Information and Website Support: We offer multiple ways to contact WTPEOPLE, including contact forms and e-mails. If at any time, you attempt to contact us through a contact form, the information you provide will be stored on our servers. If you submit a form or email us, we use MaielrLite to process all these inquiries and track responses.
OTHER TYPES OF DATA
Non-Identifiable Data: When you interact with us through the Website, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. We may store such information or such information may be included in databases owned and maintained by our affiliates, agents, or service providers. The Website may use such information and pool it with other information to track, for example, the total number of visitors to our Website, the number of visitors to each page of our Website, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process.
Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Sites, WTPEOPLE my conduct research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. This aggregate information does not identify you personally. WTPEOPLE may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
PUBLICLY VISIBLE INFORMATION
If you create a user profile on WTPEOPLE or the Social Media Marketing Society or leave a comment on WTPEOPLE, certain information may be publicly visible.
WHAT ARE COOKIES?
A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website. The Cookie will collect information relating to your use of the Website, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at our Website via a link from third party site, the URL of the linking page.
In addition to Cookies, the Website may use web beacons. Web beacons allow us to count the number of users who have visited or accessed the Website and to recognize users by accessing our cookies. We may employ web beacons to facilitate Website administration and navigation, to track the actions of users of the Website, to compile aggregate statistics about Website usage and response rates, and to provide an enhanced online experience for visitors to the Website. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. A web beacon is often invisible because it is only 1 x 1 pixel in size with no color. A web beacon can also be known as a web bug, 1 by 1 GIF, invisible GIF and tracker GIF.
WHAT ARE THE DIFFERENT TYPES OF COOKIES AND HOW DO WE USE THEM?
Essential: These are Cookies which are essential for the running of our Website. Without these Cookies, parts of our Website would not function. These Cookies do not track where you have been on the internet and do not gather information about you that could be used for marketing purposes.
Examples of how we may use essential Cookies include:
- Setting unique identifiers for each unique visitor, so that website numbers can be analyzed.
Functional: These Cookies are used to remember your preferences on our Website and to provide enhanced, more personal features. The information collected by these Cookies is usually anonymized, so we cannot identify you personally. Functional Cookies do not track your internet usage or gather information which could be used for selling advertising.
Examples of how we may use functional Cookies include:
- Gathering data about visits to our Website, including numbers of visitors and visits, length of time spent on the site, pages clicked on or where visitors have come from.
- Eliminating the need for returning users to re-enter their login details.
Analytical Performance: Analytical performance Cookies are used to monitor the performance of our Sites, for example, to determine the number of page views and the number of unique users our Website has. We use this information to improve user experience or identify areas of the Website which may require maintenance. The information is anonymous (i.e. it cannot be used to identify you and does not contain personal information such as your name and email address) and it is only used for statistical purposes.
Examples of how we may use analytical Cookies include:
- Measuring users’ behavior
- Analyze which pages are viewed and how long for and which links are followed to better develop our Website.
Advertising: Behavioral advertising Cookies, which may be placed on your device by us or our trusted third-party service providers, remember that you have visited a website and use that information to provide you with advertising which is tailored to your interests. This is often called online behavioral advertising and is done by grouping together shared interests based upon web browsing history. Your web browsing history can be used to infer things about you (e.g. your age, gender etc.), and this information may also be used to make advertising on websites more relevant to you. Although behavioral advertising Cookies can track your activity around the internet, these Cookies cannot identify you personally, even if you are signed in to our Website.
Examples of how we may use advertising Cookies include:
- To market to specific users across our Website and third party sites, so that we and third parties can target advertising to users that will be more relevant to users’ interests.
Third Party Cookies: You may notice on some pages of our Website that Cookies have been set that are not related to us. When you visit a page with content embedded from, for example, YouTube or Facebook, these third party service providers may set their own Cookies on your device. We do not control the use of these third party Cookies and cannot access them due to the way that Cookies work, as Cookies can only be accessed by the party who originally set them. Please check the third-party websites for more information about these Cookies.
HOW CAN YOU MANAGE OR OPT OUT OF COOKIES?
Cookies, including those which have already been set, can be deleted from your hard drive. You can also change the preferences/settings in your web browser to control Cookies. In some cases, you can choose to accept Cookies from the primary site, but block them from third parties. In others, you can block Cookies from specific advertisers, or clear out all Cookies. Deleting or blocking Cookies may reduce functionality of the Website. To learn more about how to reject Cookies, visit www.allaboutcookies.org or go to the help menu within your internet browser. If you experience any problems having deleted Cookies, you should contact the supplier of your web browser.
Opting out of Analytical Performance Cookies
If you would like to opt out of Analytics Cookies, please do so by clicking on the links below:
Google Analytics: Opt-out Browser Add-on
Opting out of Behavioral Advertising Cookies
If you would like to disable “third party” Cookies generated by advertisers or providers of targeted advertising services, you can turn them off by going to the third party’s website and getting them to generate a one-time “no thanks” cookie that will stop any further Cookies being written to your machine. Here are links to the main third party advertising platforms we use, each of which have instructions on how to do this:
FURTHER INFORMATION AND CONTACT DETAILS
RIGHTS RELATED TO YOUR PERSONAL DATA
Please note that while any amendments, corrections or deletions will be reflected in active user databases (as updated with a reasonable period of time), we may retain all Personal Data for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.
We may retain your Personal Data to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our contracts, and take other actions otherwise permitted by law.
Please contact us at hello@WTPEOPLE.com to submit a request or obtain information regarding any of the above.
Opt-out: You may opt-out of future e-mail communications by following the unsubscribe links in our e-mails. You may also notify us at hello@WTPEOPLE.com to be removed from our mailing list.
Access: You may access the personal information we have about you by submitting a request to hello@WTPEOPLE.com.
Amend: You may contact us at hello@WTPEOPLE.com to amend or update your personal information.
Forget: In certain situations, you may request that we erase or forget your personal data. To do so, please submit a request to hello@WTPEOPLE.com
California Residents: Pursuant to the California Consumer Privacy Act of 2019 (“CCPA”), you have the right to request disclosure of our data collection and sales practices in connection with our data collection of your Personal Data. You may also request the categories of Personal Data we have collected, the source of the Personal Data, our use of the Personal Data and if the Personal Data was disclosed or sold to third parties, including the categories of Personal Data sold or disclosed. You also have the right to request a copy of the Personal Data collected about you for the twelve (12) months prior to the date of your request. You have the right to request that we delete your Personal Data, with the exceptions noted above and those delineated in the CCPA. You have the right to request that we do not sell your Personal Data to any third parties. In the event you make such a request, we reserve the right to collect information from you to verify your identity and right to request such information. All requests made pursuant to the CCPA shall be made to hello@WTPEOPLE.com or to WTPEOPLE, Kufsteinerplatz 2, 81679 Munich, Germany. We will respond to all requests within forty-five (45) days of our receipt of the request, unless we inform you of our need for an extension to the request. We will not discriminate against you for exercising any of your rights under the CCPA.
SENSITIVE PERSONAL INFORMATION
Unless you choose to provide it to us, we do not collect sensitive personal information from you using the Website. This includes your social security number, information regarding race or ethnic origin, political opinions, religious beliefs, health information, criminal background, or trade union memberships. If you elect to submit such information to us, it will be subject to this Privacy and Spam Policy.
WTPEOPLE is strongly opposed to spam. We will only send e-mail to users that have explicitly requested to receive an e-mail from WTPEOPLE. Examples may include:
- Opt-in subscribers to the WTPEOPLE Newsletter
- Users that complete a contact form
- All communication will be related and relevant to what you have requested.
WTPEOPLE contains links to other sites. Please be aware that WTPEOPLE is not responsible for the privacy practices or the content of such other sites. We encourage our users to be aware when they leave our site to read the privacy and spam policies of each and every website that collects personally identifiable information. This Privacy and Spam Policy applies solely to information collected by WTPEOPLE.
If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public personal information, such as passwords, social security numbers, or bank account information, to us by email. You may “opt out” of receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of most emails we send, or as provided below; provided, however, we reserve the right to send you transactional emails such as customer service communications.
HOW DO I CONTACT WTPEOPLE?WTPEOPLEwebsite or this Privacy and Spam Policy, you may contact us.
OTHER TERMS AND CONDITIONS
Your access to and use of the Website may also be subject to any separate agreements or terms and conditions you have signed or agreed to with WTPEOPLE. Please refer to those agreements as needed.