Wazoku Crowd Privacy Policy

Contents:
Introduction
Important information and who we are
The data we collect about you
How is your personal data collected?
How we use your personal data
Disclosures of your personal data
International transfers
Data security
Data retention
Your legal rights

Additional Disclosures for Nevada Residents

Additional Disclosures for California Residents

Introduction

Wazoku respects your privacy and is committed to protecting your personal data.

This Privacy Policy tells you the types of information we collect about you when you visit our websites, use our products and services (where applicable), interact with us offline and we make this Privacy Policy available to you, or which we otherwise obtain directly from you or from another party, how we use that information, and the instances in which we share your information.  We may also process personal data about employees of our customers as a processor when that customer uses our software, and if you have any queries about this use of your personal data you should contact the controller (your employer).  This Privacy Policy may change from time to time so please check this policy regularly.

Our website, products and services are not intended for children and we do not knowingly collect data relating to children.

For the purposes of this Privacy Policy, the term “personal data” means any information which identifies, relates to, describes, is reasonably capable of being associated with you or which allows you to be reasonably identified, directly or indirectly, when combined with other information (personal data as used in this Privacy Policy includes “personal information”, “personally identifiable information”, or similar term as defined under applicable law(s)).

Important information and who we are

Controller

This Privacy Policy is issued by Wazoku Limited, referred to as “Wazoku”, “we”, “us” or “our” in this Privacy Policy. Wazoku Limited is the controller and responsible for this website.

We have appointed a data privacy representative who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Full name of legal entity:  Wazoku Limited (company number 07540637)

Title of data privacy manager: Chief Operating Officer

Email address: privacy@wazoku.com

Postal address: Unit M19, St Magnus House, 3 Lower Thames Street, London, EC3R 6H

Telephone number: +44 (0)20 8743 5724

You have the right to make a complaint at any time to the applicable data protection supervisory authority. The applicable supervisory authority in the UK is the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the relevant supervisory authority so please contact us in the first instance.

This Privacy Policy has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us at privacy@wazoku.com.

Changes to the Privacy Policy and your duty to inform us of changes

This version was last updated on 28^th November 2022.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Other Parties

This website may include links to websites, plug-ins and applications owned and operated by other parties. Clicking on those links or enabling those connections may allow other parties to collect or share data about you.

Some examples include:

• Links. Our website, products and services include links that hyperlink to websites, platforms, and other services not operated or controlled by us.
• Brand Pages. We may offer our content through social media. Any data you provide to us when you engage with our content (such as through our brand page on Facebook or our Twitter feed) is treated in accordance with this Privacy Policy. Also, if you publicly reference our website, products or services on social media (e.g., by using a hashtag associated with Wazoku in a tweet or post), we may use your reference on or in connection with our website, products and services.

When you interact with other parties, including when you leave our website, those parties may also independently collect data about you and solicit data from you. We do not control these parties and are not responsible for their privacy statements. The data collected and stored by these other parties remains subject to their own privacy statements and practices. When you leave our website, we encourage you to read the privacy policy and terms of use of every website you visit.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title.
• Contact Data includes work address, email address and telephone numbers. If you are an employee of a customer or vendor of ours, this will be your work contact data, but if you are a Solver, this will be your personal contact information.
• Technical Data includes information about how you use our websites, emails and advertisements you view, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website and links you have clicked on.
• Location Data includes imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level).
• Profile Data includes your username and password, your job title, your employer, your feedback and survey responses.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
• Products and Services Data may include additional personal data to the above where you have been invited to use our products and services by one of our clients. The type of additional personal data collected by us will depend on the data fields activated by and under the control of the relevant client or if you participate in an InnoCentive Open Innovation Challenge and provide optional personal data as part of your profile.
• Awards Data includes information we require from you in order to comply with our obligations under tax law and other applicable laws in the event you receive an Award for a Solution you submitted in response to an InnoCentive Challenge. Such information may include copies of positive identification documentation and a tax identification number (for US individuals, this will often be your Social Security number). We also collect information about any payments that you receive for a Solution.
• Content includes content within any messages you send to us (such as feedback, questions to customer support, and requests for demos).
• Usage Data includes information about how you use our website, products and services.
• Employment Data includes your current and past employment experience, qualifications, skills, interests and any other information disclosed by you in relation to an application for a role within Wazoku.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose permitted under applicable law. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not, directly or indirectly, reasonably reveal your identity. For example, we may aggregate or de-identify your Technical Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can reasonably, directly or indirectly, identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

We may process your personal data if:

• You visit our website.
• You or the company you work for are a customer or a supplier of ours.
• You or the company you work for use our products or services.
• You register to be a Solver.
• You are someone (or you work for someone) to whom we want to advertise or market our goods or services, and, where required, you have given consent.

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data in person, or other personal data when using our products and/or services or by filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:

• request information on our products or services, including when you request a demo;
• register as a Solver;
• meet with one of our employees;
• participate in an event which we have organised;
• complete a form on our website requesting us to contact you;
• subscribe to our news letters or other publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey;
• submit an application for a role within Wazoku;
• make a complaint or give us some feedback;
• manage our relationship with the company that you work for;
• use our products and services where you have been invited to access such products and services by one of our clients; or
• use our products and services where you respond to an InnoCentive Open Innovation Challenge.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Through the use of pixels, we generate various types of heat maps, including but not limited to scroll maps, click maps, and move maps, to help us determine the most popular and unpopular areas of our website and to help us better understand how users interact with our website. Please see our cookie policy for further details.

Other parties or publicly available sources. We may receive personal data about you from various parties as set out below:

• Technical Data from the following parties:
  • analytics providers; and
  • search information providers.
• Identity, Profile and Contact Data from data providers such as data brokers or aggregators.
• Identity and Contact Data from publicly availably sources such as Companies House.
• Employment, Identity and Contact Data from recruitment agencies or another party which advertise jobs on our behalf (such as LinkedIn).
• Identity, Profile and Contact Data from social networks with which you interact.

Our Clients. We provide products and services to our clients, and collect and process data about individuals (including through tracking technologies) at the direction of our clients (“client data”). Client data has historically included Contact Data, Content, Technical Data, and Location Data, among other information. Our processing of client data is governed by the terms of our service agreements with our clients, and not this Privacy Policy. In the event we are permitted to process client data for our own purposes, we will process the client data in accordance with the practices described in this Privacy Policy. We are not responsible for how our clients treat the information we collect on their behalf, and we recommend you review their own privacy policies.

How we use your personal data

We will only use your personal data when the law allows us to. We use personal data for business and commercial purposes in accordance with the practices described in this Privacy Policy. Most commonly, we will use your personal data in the following circumstances:

• Where it is necessary for our legitimate interests (or those of another party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to opt out of receiving marketing at any time by contacting us at privacy@wazoku.com.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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 at privacy@wazoku.com if you need details about the specific legal ground we are relying on 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 manage our relationship with you or the company that you work for and our business which will include: (a) Registering you for our products and services (b) Registering you as a Solver; (c) Providing our products and services or receiving products or services from the company you work for; (d) Dealing with your enquiries and complaints; (d) Notifying you about changes to our terms or privacy policy; (e) Asking you to leave a review or take a survey.	(a) Identity (b) Contact (c) Marketing and Communications (d) Products and Services Data (e) Profile (f) Award	(a) Necessary for our legitimate interests (to manage our client relationships, register Solvers, and be able to provide our products and services or receive products and services from our vendors) (b) Necessary to comply with a legal obligation
To administer and protect our business and this website (including, but not limited to, troubleshooting, data analysis, testing, system maintenance, support, fraud prevention, threats of harm, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) 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) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Marketing and Communications (d) Technical (e) Usage	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To enable you to partake in an InnoCentive Open Innovation Challenge a survey or a prize draw or competition	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our Sites, products and services, to develop them and grow our business)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)
To verify your identity and comply with applicable tax laws and other laws and regulations if you receive an Award in response to an InnoCentive Open Innovation Challenge	(a) Identity (b) Contact (c) Awards	(a) Necessary for our legitimate interests (to verify your identity) (b) Necessary to comply with a legal obligation
To process your application for a role within Wazoku	(a) Identity (b) Contact (c) Employment	(a) Necessary for our legitimate interests (to consider your application for a role within Wazoku) (b) Performance of a contract with you (c) Necessary to comply with a legal obligation

In addition, we use data to fulfil any other purpose at your direction or with notice to you and your consent.

Notwithstanding the above, we may use data that does not identify you (including data that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use data about you, please see the “Your legal rights” section below.

Marketing

We strive to provide you with choices regarding marketing and advertising.

We may use analytics services, such as Google Analytics, and your Technical Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Opting out

You can ask us or other parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at privacy@wazoku.com at any time.

Cookies and other similar technologies

Our website, and our ads displayed on other websites and services, use cookies and similar technologies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website, to track your activity across time and services for purposes of associating different devices you use, to improve our website. We may also use such technologies to display targeted advertisements to you on websites and social media platforms based on your preferences and likely interests where such websites and social media platforms are owned and operated by other parties (“Interest-based Advertising”).

We also use audience matching services to reach people (or people similar to people) who have visited our website, and products and services, or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a customer list to another party or incorporating a pixel from another party into our website, and products and services, and the other party matching common factors between our data and their data or other datasets. For instance, we incorporate the Facebook pixel on our website may share your email address with Facebook as part of our use of Facebook Custom Audiences.

The vendors and other parties we use for analytics and advertising services may act as our processors or service providers, or in certain contexts, independently decide how to process your data. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website, products and services may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table above:

• Our service providers who perform functions on our behalf in connection with the operation of our business such as IT and system administration services, host and manage data, provide programming or technical support, or conduct reference checks on candidates on our behalf. We do not allow our service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We may permit them to use data that does not identify you (including data that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
• Professional advisers including lawyers, bankers, auditors and who provide consultancy, banking, legal, insurance and accounting services.
• Our partners to analyse website traffic, understand customer needs and trends, offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
• Our affiliates and related entities, including where they act as our service providers or for their own internal purposes.
• Our clients in connection with the products and services we provide to them. For example, we share data with our clients in order to facilitate orders, maintain and administer your accounts, respond to your requests, comply with your requests, market and advertise to you, and otherwise comply with the law. Our clients are independent entities and their processing of data is subject to their own privacy policies.
• Other parties if we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our websites or customers.
• Other parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
• Other parties with whom we jointly sponsor promotions. When you voluntarily enter a promotion, we share data as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a promotion, you agree to the official rules that govern that promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials.

We also share data at your request or direction or with notice to you and with your consent.

We require all parties with whom we share personal data to respect the security of your personal data and to treat it in accordance with applicable law. Notwithstanding the above, we may share data that does not identify you (including data that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share personal data about you, please see the “Your legal rights” section below.

International transfers

Our service providers may be based outside the UK or the EEA so their processing of your personal data will involve a transfer of data outside the UK or EEA. We also share personal data where necessary with other companies in the Wazoku Group in the USA.

Whenever we transfer your personal data out of the UK or the EEA, 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 by the UK or the European Commission. For further details, see the ICO’s guidance on international transfers here and European Commission: Adequacy of the protection of personal data in non-EU countries here.
• Where we use certain service providers that are based outside of the UK or the EEA, we may use specific contracts approved for use in the UK or by the European Commission which give personal data the same protection it has in the UK or EEA. For further details, see the ICO’s international data transfer agreement and data transfer addendum here and European Commission: Standard Contractual Clauses for the transfer of personal data to third countries here.
• Where we transfer your personal data to Wazoku Group companies based outside of the UK or the EEA, we use the Standard Contractual Clauses to safeguard the personal data.

Please contact us at privacy@wazoku.com if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.

Data security

We have put in place appropriate security measures designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, service providers, contractors and other parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

For further details about retention periods for different aspects of your personal data, please contact us at privacy@wazoku.com.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise or de-identify your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

If you are a data subject in the UK or EEA, in certain circumstances, you have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of another 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms (other than in the case of direct marketing).

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to another party. We will provide to you, or another party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying 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, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at privacy@wazoku.com.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you within one month that we are extending the response deadline and keep you updated.

Additional Disclosures for Nevada Residents

Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at privacy@wazoku.com.

Additional Disclosures for California Residents

These additional disclosures apply only to California residents. The California Consumer Privacy Act of 2018 (“CCPA”), and its replacement the California Privacy Rights Act (“CPRA”)  provide additional rights to know, correct, delete and opt-out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights. This section addresses those rights and applies only to California residents. Any rights specifically relating to the CPRA shall not take effect until January 1, 2023.  

Our website is intended to provide information and services to job applicants and business clients. You understand and agree that information collected about you is solely within the context of (i) your role as an employee, job applicant, owner, director, officer, or contractor or (ii) Wazoku conducting due diligence regarding, or providing or receiving a product or service to or from your employer.

Notice of Collection.

In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA:

• Identifiers, including name, postal address, email address, and online identifiers (such as IP address). 

• Customer records, including phone number. 

• Characteristics of protected classifications under California or federal law, including gender. 

• Commercial or transactions information, including records of products or services purchased, obtained, or considered.

• Internet activity, including browsing history, search history, and interactions with a website, email, application, or advertisement.

• Non-precise geolocation data, including location derived from an IP address.

• Professional, employment and education information.

• Inferences drawn from the above information about your predicted characteristics and preferences.

For further details on information we collect, including the sources from which we receive information, review the “The data we collect about you” section above. We collect and use these categories of personal information for the business purposes described in the “How we use your personal data” section above, including to manage our website.

We do not sell your personal information as that term is traditionally understood. However, some of our disclosures of personal information may be considered a “sale” or “share” as those terms are defined under CCPA/CPRA. A “sale” is broadly defined under the CPRA to include a disclosure for something of value, and a s “share” is broadly defined under the CPRA to include a disclosure for cross-context behavioral advertising. We may collect, sell, or share the following categories of personal information for commercial purposes: identifiers, characteristics, commercial or transactions information, internet activity, non-precise geolocation data, and inferences drawn. The categories of third parties to whom we may sell or share your personal information include, where applicable, vendors and other parties involved in cross-context behavioral advertising. Please review the “Disclosures of your personal data” section above for further details about the categories of parties with whom we share information. For details about your rights regarding sales and shares, please see the “Right to Opt-Out” section below.

We do not knowingly sell or share the personal information of minors under 16 years old who are California residents.

Retention.

We retain each category of personal information for the length of time reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

Right to Know, Correct, and Delete.

You have the right to know certain details about our data practices. In particular, you may request the following from us:

• The categories of personal information we have collected about you; 
• The categories of sources from which the personal information was collected;
• The categories of personal information about you we disclosed for a business purpose or sold or shared;
• The categories of third parties to whom the personal information was disclosed for a business purpose or sold or shared;
• The business or commercial purpose for collecting or selling or sharing the personal information; and
• The specific pieces of personal information we have collected about you.

Unless you specify otherwise, the response we provide will cover the 12 month period preceding our receipt of the request. Starting with personal information collected on or after January 1, 2022, you may request that we disclose details beyond the 12-month period, and we shall do so unless doing so proves impossible or would involve disproportionate effort.

In addition, you have the right to correct (effective January 1, 2023) or delete the personal information we have collected from you.

To exercise any of these rights, please submit a request through our Online Form or call our toll free number at 1 888-522-3141. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

We acknowledge that you may have rights under the CCPA/CPRA in connection with the personal information we process on behalf of our clients. If personal information about you has been processed by us as a service provider on behalf of a client and you wish to exercise any rights you have with such personal information, please inquire with our client directly. If you wish to make your request directly to us, please provide the name of our client on whose behalf we processed your personal information. We will refer your request to that client, and will support them to the extent required by applicable law in responding to your request.

Right to Opt-Out.

To the extent Wazoku sells or shares your personal information as those terms are defined under the CCPA/CPRA, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking Do Not Sell or Share My Personal Information or calling our toll free number at 1 888-522-3141.

Authorized Agent.

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and may verify your identity directly.

Right to Non-Discrimination.

You have the right not to receive discriminatory treatment by us for the exercise of any your rights.

Shine the Light.

Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Details” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

Additional Disclosures for Virginia Residents

The Virginia Consumer Data Protection Act (“VCDPA”) provides additional rights to Virginia residents. This section addresses those rights and applies only to Virginia residents. Any rights shall not take effect until January 1, 2023.

You have the following rights under the VCDPA:

• To confirm whether or not we are processing your personal data
• To access your personal data
• To correct inaccuracies in your personal data
• To delete your personal data
• To obtain a copy of your personal data that you previously provided to us in a portable and readily usable format
• To opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you

To exercise any of these rights, please contact us as set out in the “Contact Details” section above and specify which right you are seeking to exercise. We will respond to your request within 45 days. We may require specific information from you to help us confirm your identity and process your request. If personal data about you has been processed by us as a processor on behalf of a client and you wish to exercise any rights you have with such personal data, please inquire with our client directly. If you wish to make your request directly to us, please provide the name of our client on whose behalf we processed your personal data. We will refer your request to that client, and will support them to the extent required by applicable law in responding to your request.

If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy@wazoku.com and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform.