WONDER PRIVACY POLICY
Last Updated: February 24, 2021
We at Wonder Inventions LLC (“Wonder,” “we,” “us,” or “our”) have created this Privacy Policy (the “Privacy Policy”) because we know that you care about how information you provide to us is used and shared. This Privacy Policy relates to the information collection and use practices of Wonder’s proprietary Roam application (the “Roam App,” or “App”) which means, collectively, Wonder’s proprietary desktop, web, and mobile applications under the product name “Roam.” You may use the App either as an Authorized User, or as a Guest. “Authorized User” means any current employee, consultant, or agent of the entity that is Wonder’s customer, and which authorized you to access and use the Roam App, while a “Guest” is only authorized temporarily to have access and use specific areas, features, or functionalities of the Roam App. We will refer to Authorized Users and Guests collectively as “you” or “your.”
In this Privacy Policy, we describe what kinds of personal information we may obtain online through your use of the Roam App and the related Services, how we may use and disclose that information, the steps we take to keep it secure, your choices regarding our use of this information, and how you how can contact us if you have any questions about our privacy practices.
Please read this Privacy Policy carefully before accessing and using the Roam App, because by using the Roam App, clicking “I Agree” below, or otherwise manifesting your assent to this Privacy Policy, you agree to be bound by its terms. If you do not agree to (or cannot comply with) all of the terms of this Privacy Policy, do not access or use the Roam App.
When we refer to the “Services,” we mean Wonder’s provision of access to and usage of the Roam App. We will refer to the personal information we obtain about you as “Your Data.” Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use.
I. The Information We Collect and/or Receive
In the course of operating the App, we will collect (and/or receive) the following types of information, which you authorize us to collect and/or receive.
If you would like to use the App on a mobile device, you will need to download it from an app store through which the App is made available to you. In order to access and use the App (whether on a mobile device or a computer), you will be asked to login using your email address (the “Login Information”).
When you create a profile, you will be asked to provide additional information, namely your name and a profile picture (the “Profile Information”).
We may, with your consent, automatically collect geolocation information from your mobile device, wireless carrier, and/or certain third-party service providers (collectively, the “Geolocation Information”). Collection of such Geolocation Information occurs only when the App is running on your device.
We use Geolocation Information in order to connect users with server infrastructure that is close to them, so we can ensure the best performance of the App. You can choose whether or not to allow the App to collect and use real-time information about your device’s location through the device’s privacy settings. Note, however, that opting out of the App’s collection of location information will disable its location-based features, and it may negatively affect the performance of the App.
“Your Content” is any data, media, documents, content, and other materials that you submit to the Roam App, or share or utilize internally by or through the App. This can include, for example, chats and messages shared between or among Authorized Users and/or Guests; and collaborative projects, presentations, and project notes. Your Content is used within the App only per its configuration (for example, if you send a chat, the recipients will receive the respective message, or if you upload a photo to a whiteboard, it will be there for other people in the room to see). We may only access Your Content in order to improve your experience on our Services, or for legal process purposes.
In addition to the above-mentioned kinds of information, we may collect additional information (the “Other Information”). Such Other Information may include:
From Your Activity. Information that we automatically collect when you use the App, including, without limitation:
IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the App you visit, etc.;
Information about a mobile device, including universally unique ID (“UUID”), App type and version (e.g., iOS or Android), carrier and country location, hardware and processor information (storage, chip speed, camera resolution, NFC enabled, and network type (WiFi, 2G, 3G, 4G); and
Activity and usage information occurring via the App, including tagging data, favorites, preferences, session lengths, traffic data, logs, and other communication data and the resources that you access and use on or through the App, and similar data.
From Cookies. We collect Other Information using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive so that your computer will “remember” information about your visit. The App uses cookies and similar technologies such as image loading, browser local storage, cookies, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our App, analyze trends, learn about our user base and operate and improve our Services. We use the following types of Cookies:
Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.
If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the App may not function properly.
If you do not want us to collect the information as described above, do not download or use the App, or delete it from your device.
II. How We Use and Share Your Data
We will take reasonable measures to require that any party receiving Your Data from us undertakes to: (i) retain and use such information only for the purposes set out in this Privacy Policy; (ii) not disclose Your Data except with your consent, as permitted by law, or as permitted by this Privacy Policy; and (iii) generally protect the privacy of Your Data.
We use the Login Information, Profile Information, Geolocation Information, and Other Information (collectively, “Your Data”) to: (i) provide you with access to specialized portions of the App (your “Account”) and to maintain, and secure such account; (ii) allow you to create a profile through your Account; (iii) store information about your preferences, allowing us to customize your Account according to your individual interests; (iv) notify you when App updates are available; (v) contact you to respond to inquiries related to the App; (vi) communicate with you to provide you with relevant information about us, including special promotions, discounts and newsletters; (vii) provide you with support, to respond to your inquiries, and to solicit feedback; (viii) identify, investigate, and respond to, and prevent fraudulent or illegal activity (such as incidents of hacking or misuse of our applications), and other liabilities; (ix) enhance or repair the functionality of the App or improve our Services, and (x) to inform you about our Services and those of our third-party marketing partners.
If you post Your Content to public areas of the App that are available to others, that information is transmitted to others at your own risk, and can be collected and used by third parties and by us without limitation. Although you may set certain privacy settings for such contributions, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share Your Content. Therefore, we cannot and do not guarantee that Your Content will not be viewed by unauthorized persons once you have posted it to public areas of the App.
You also authorize us to use and/or share Your Data as described below.
Agents, Affiliates, Providers and Other Third Parties. We may engage other companies and individuals to perform certain business-related functions on our behalf. Examples may include providing technical assistance, order fulfillment, customer service, and marketing assistance. These other companies will have access to Your Data only as necessary to perform their functions and to the extent permitted by law. We may also share Your Data with any of our parent companies, subsidiaries, or other companies under common control with us.
Marketing. As permitted by applicable law, we may use Your Data for marketing purposes, such as informing you about our products and services and those of our third-party marketing partners that could be useful, relevant, valuable, or otherwise of interest to you. We may also share Your Data with third parties that are not service providers or vendors, so that those third parties can send you information about their products and/or services. Where required under applicable law, we will obtain your prior opt-in consent to send you electronic marketing communications. If you do not wish to have Your Data shared directly with third parties as described above (other than our service providers and vendors), please submit your request to our email at privacy@wonder.inc.
Aggregated Information*. *In an ongoing effort to better understand users of the App, we might analyze Your Data in aggregate form in order to operate, maintain, manage, and improve the App. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners, and may share and sell this aggregate information to other unaffiliated third parties. We may also disclose aggregated user statistics in order to describe our App to current and prospective business partners and to other third parties for other lawful purposes.
Business Transfers. As we develop our business, we might sell or buy other assets or businesses. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, Your Data may be part of the transferred assets associated with such transaction.
Legal Requirements and to Enforcement of Our Policies. To the extent permitted by law, we may also disclose Your Data: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of us or others. We may disclose Your Data to enforce our rights arising from any contracts entered into between you and us, including our Terms of Use and this Privacy Policy or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Wonder, our customers or others.
Otherwise With Your Consent. We may also disclose Your Data to fulfill any purpose for which you provide it or for any other purpose disclosed by us when you provide the information.
III. Accessing and Modifying Information and Communication Preferences
If you have provided us any personal information, you may access, remove, review, and/or make changes to the same from the Settings section of the application, or contacting us at privacy@wonder.inc. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “Unsubscribe” link located on the bottom of any Wonder marketing e-mail. We will use commercially reasonable efforts to process such requests in a timely manner.
IV. External Sites
Our App may contain links to third-party websites (“External Sites”). Wonder has no control over the privacy practices or the content of these External Sites. As such, we are not responsible for the content or the privacy policies of those External Sites. You should check the applicable third-party privacy policy and terms of use when visiting any External Sites.
V. Do Not Track Signals
Some web browsers may give you the ability to enable a “do not track” setting that is an HTTP header field indicating your preferences regarding user tracking or cross-site tracking. We do not recognize web browser “do not track” signals at this time, and we do not alter our App’s data collection and use practices when we see a do not track signal from your browser. Instead, information collection and disclosure practices and the choices that we provide to users will continue to operate as described in this Privacy Policy, whether or not a “do not track” signal is received. For more information about “do not track,” please see http://donottrack.us/.
VI. Data Security and Retention
We take commercially reasonable steps to protect Your Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
We retain Your Data for as long as you have an account with us. In some cases we may retain Your Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally. For additional information about our data retention policy please contact us at privacy@wonder.inc.
VII. Children
We do not knowingly collect personal information from children under the age of 18 through the Roam App. If you are under 18, please do not use the App or provide us with any personal information. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information through the App without their permission. If you have reason to believe that a child under the age of 18 has provided personal information to us, please contact us, and we will delete that information from our databases.
VIII. Important Notice to Non-U.S. Residents
The App and its servers are operated in the United States, in Europe, and in other countries throughout the world. If you are located outside of the United States, please be aware that any information you provide to us maybe transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined in our GDPR Addendum (the “Addendum”) at the end of this Privacy Policy.
IX. California Privacy Rights
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact Wonder via email at privacy@wonder.inc. Please note, however, that we do not disclose personal information to third parties for such third parties’ direct marketing purposes.
X. Nevada Privacy Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties. You can exercise this right by contacting us at privacy@wonder.inc with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note, however, that we do not sell personal information.
XI. Changes to This Privacy Policy
This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time with or without notice to you. Any such changes will be posted on the App. In any event, you will be required to affirmatively accept the revised Privacy Policy prior to next logging-in to your account. Please be aware that, to the extent permitted by applicable law, our use of Your Data is governed by the Privacy Policy in effect at the time we collect the respective information. Please refer back to this Privacy Policy on a regular basis.
XII. How to Contact Us
If you have questions about this Privacy Policy or if you would like Wonder to either change, or discontinue use of, Your Data, please contact us via e-mail at privacy@wonder.inc, with “Privacy Policy” in the subject line.
GDPR Addendum
Effective as of: February 24, 2022
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined in this GDPR Addendum (the “Addendum”).
For this Addendum, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to identify a person, and “processing” generally refers to actions that can be performed on data such as its collection, use, storage or disclosure.
In most situations, Wonder will be the controller of your Personal Data processed in connection with the Services. Where applicable, this Addendum is intended to supplement, and not replace, our Privacy Policy. If there are any conflicts between the Addendum and the other parts of the Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict.
I. Our Contact Information
Please contact privacy@wonder.inc for any questions, complaints, or requests regarding this Addendum, and include in the subject line “GDPR Request.”
II. Types of Personal Data we Collect
We currently collect and otherwise process the kinds of Personal Data listed above in Section I of the Privacy Policy.
III. How we get the Personal Data and why we have it
We receive the Personal Data in the ways and for the purposes listed above in Sections I and II of the Privacy Policy. Under the GDPR, the lawful bases we rely on for processing this information are:
a. Your consent
You can remove your consent at any time. You can do this by contacting us via email at privacy@wonder.inc with the subject line “GDPR Request.”
b. We have a contractual obligation
We process Personal Data as necessary to provide our services in accordance with the Terms of Use.
c. We have a legitimate interest
Information Security: We process Contact Information, and the information collected through cookies and when you use the App in order to maintain an audit log of activities performed. We use this information pursuant to our legitimate interests in tracking App usage, combating distributed denial-of-service (DDOS) or other attacks, and removing or defending against malicious individuals or programs.
App Operation and Improvement: We process server log information and information collected through cookies pursuant to our legitimate interest in operating and improving our App.
Audience Measurement and Retargeting: Pursuant to an App user’s consent, we use analytics cookies, and collect identifiers through such cookies, for purposes of audience measurement, analytics, audience reaction to the App, and creating relevant App user experiences.
General Business Development and Management: We process Personal Data pursuant to our legitimate interest in creating and managing our business relationships with European Individuals, including without limitation:
To respond to inquiries from European Individuals;
To provide European Individuals with information about our products and services; and
To assist European Individuals with any issues while using the App.
Direct Marketing: Generally, we send email marketing to European Individuals pursuant to their consent. When you use the App, email marketing may be sent to you pursuant to our legitimate interest in sending marketing communications to you in the context of such engagement.
Protection of Rights: We may also disclose Personal Data to respond to claims of violation of third party rights or to enforce and protect our rights.
d. We have a legal obligation
We may be required to disclose personal data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal data to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
IV. How we store your personal information
We use commercially reasonable administrative, technical, and physical safeguards to protect your Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, for which we take into account the nature of the Personal Data, its processing, and the threats posed to it. Unfortunately, no data transmission or storage system can be guaranteed to be secure at all times. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us via email at privacy@wonder.inc.
We retain your Personal Data for as long as needed to fulfill the purposes for which we obtained it, as further described in this Privacy Policy. We will only keep your Personal Data for as long as allowed or required by law.
V. Your data protection rights
Under data protection law, you have rights, which include:
Right of access: You have the right to ask us for copies of your Personal Data.
Right to rectification: You have the right to ask us to rectify Personal Data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Right to erasure: You have the right to ask us to erase your Personal Data in certain circumstances.
Right to restriction of processing: You have the right to ask us to restrict the processing of your Personal Data in certain circumstances.
Right to object to processing: You have the the right to object to the processing of your Personal Data in certain circumstances.
Right to data portability: You have the right to ask that we transfer the Personal Data you gave us to another organisation, or to you, in certain circumstances.
Right to withdraw consent: You have the right to withdraw your consent where consent is used as the legal basis for processing your Personal Data.
Objecting to Legitimate Interest/Direct Marketing: You may object to Personal Data processed pursuant to our legitimate interest. In such case, we will no longer process your Personal Data unless we can demonstrate appropriate, overriding legitimate grounds for the processing or if needed for the establishment, exercise, or defense of legal claims. You may also object at any time to processing of your Personal Data for direct marketing purposes by clicking “Unsubscribe” within an automated marketing email or by submitting your request to privacy@wonder.inc with the subject line “GDPR Request.” In such case, your Personal Data will no longer be used for that purpose.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us at privacy@wonder.inc with the subject line “GDPR Request” if you wish to make a request.
VI. How to complain
If you have any concerns about our use of your Personal Data, you can make a complaint to us at privacy@wonder.inc with the subject line “GDPR Request.”
You also have the right to lodge a complaint about the processing of your personal data with a supervisory authority of the European state where you work or live or where any alleged infringement of data protection laws occurred. A list of most of the supervisory authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
VII. Corporate Restructuring
In the event of a merger, reorganization, dissolution, or similar corporate event, or the sale of all or substantially all of our assets, the information that we have collected, including Personal Data, may be transferred to the surviving or acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such Personal Data as set forth in this Addendum.
VIII. Updates to this Addendum
If, in the future, we intend to process your Personal Data for a purpose other than that which it was collected, we will provide you with information on that purpose and any other relevant information at a reasonable time prior to such processing. After such time, the relevant information relating to such processing activity will be revised or added appropriately within this Addendum, and the “Effective Date” at the top of this page will be updated accordingly.