PRIVACY NOTICE
Thank you for
choosing to be part of our community at Westward360, Inc
("
Company
,"
"we," "us," or "our"). We are committed to
protecting your personal information and your right to privacy. If you have any questions or
concerns about this privacy notice or our practices with regard to your personal information,
please contact us at [email protected] .
This privacy notice
describes how we might use your information if you:
- Download
and use our mobile application
— Atlas
- Engage with us in other related ways ― including any
sales, marketing, or events
In this privacy
notice, if we refer to:
- "App," we are referring to any
application of ours that references or links to this policy, including any listed
above
- "Services," we are referring to
our
The purpose of this
privacy notice is to explain to you in the clearest way possible what information we
collect, how we use it, and what rights you have in relation to it. If there are any
terms in this privacy notice that you do not agree with, please discontinue use of our
Services immediately.
Please read this privacy notice carefully, as it
will help you understand what we do with the information that we
collect.
TABLE OF CONTENTS
1. WHAT
INFORMATION DO WE COLLECT?
Personal information you
disclose to us
In
Short: We collect personal
information that you provide to
us.
We
collect personal information that you voluntarily provide to us when you
register on the
App,
express an interest in obtaining
information about us or our products and Services, when you participate in activities
on the
App
or otherwise when you contact
us.
The
personal information that we collect depends on the context of your interactions with us
and the
App
, the choices you make and the products and features you use.
The personal information we collect may include the following:
Personal Information Provided by You. We
collect
names ;
email addresses ;
and other similar information.
Social Media Login Data. We may provide
you with the option to register with us using your existing social media account
details, like your Facebook, Twitter or other social media account. If you choose to
register in this way, we will collect the information described in the section called
"HOW DO WE HANDLE YOUR SOCIAL
LOGINS?" below.
All
personal information that you provide to us must be true, complete and accurate, and you
must notify us of any changes to such personal information.
Information
automatically collected
In
Short: Some information —
such as your Internet Protocol (IP) address and/or browser and device
characteristics — is collected automatically when you visit our
App
.
We
automatically collect certain information when you visit, use or navigate the
App
. This information does not
reveal your specific identity (like your name or contact information) but may include
device and usage information, such as your IP address, browser and device
characteristics, operating system, language preferences, referring URLs, device name,
country, location, information about how and when you use our
App
and other technical
information. This information is primarily needed to maintain the security and operation
of our
App
, and for our internal
analytics and reporting purposes.
Like
many businesses, we also collect information through cookies and similar technologies.
The
information we collect includes:
- Log and Usage Data. Log and usage data is
service-related, diagnostic, usage and performance information our servers
automatically collect when you access or use our
App and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the App (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).
- Device Data. We collect device data such as
information about your computer, phone, tablet or other device you use to access the
App . Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
- Location Data. We collect location data such as
information about your device's location, which can be either precise or imprecise.
How much information we collect depends on the type and settings of the device you use
to access the
App . For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.
Information collected through our App
In
Short: We collect information
regarding your
mobile device,
when you use our App.
If you use
our App, we also collect the following information:
Google account
Google Sign-In
Google Analytics
Westward360, Inc
1464 W Webster Ave
Chicago
, IL
60614
United States
- Mobile Device Data. We automatically collect
device information (such as your mobile device ID, model and manufacturer), operating
system, version information and system configuration information, device and application
identification numbers, browser type and version, hardware model, Internet service
provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If
you are using our App, we may also collect information about the phone network
associated with your mobile device, your mobile device’s operating system or platform,
the type of mobile device you use, your mobile device’s unique device ID and information
about the features of our App you accessed.
This information is primarily needed to maintain the
security and operation of our App, for troubleshooting and for our internal
analytics and reporting purposes.
2. HOW DO
WE USE YOUR INFORMATION?
In Short: We
process your information for purposes based on legitimate business interests,
the fulfillment of our contract with you, compliance with our legal
obligations, and/or your
consent.
We
use personal information collected via our
App
for a variety of business
purposes described below. We process your personal information for these purposes in
reliance on our legitimate business interests, in order to enter into or perform a
contract with you, with your consent, and/or for compliance with our legal obligations.
We indicate the specific processing grounds we rely on next to each purpose listed
below.
We
use the information we collect or receive:
- To facilitate account creation and logon
process. If you choose to link your account with us to a third-party
account (such as your Google or Facebook account), we use the information you allowed
us to collect from those third parties to facilitate account creation and logon
process for the performance of the contract.
See the section below headed "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" for further information.
- To post testimonials. We post
testimonials on our
App that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at [email protected] and be sure to include your name, testimonial location, and contact information.
- Request feedback. We may use your
information to request feedback and to contact you about your use of our
App .
- To enable user-to-user communications.
We may use your information in order to enable user-to-user communications with each
user's consent.
- To manage user accounts. We may use
your information for the purposes of managing our account and keeping it in working
order.
- To send administrative information to
you. We may use your personal information to send you product, service and
new feature information and/or information about changes to our terms, conditions, and
policies.
- To protect our Services. We may use
your information as part of our efforts to keep our
App safe and secure (for example, for fraud monitoring and prevention).
- To enforce our terms, conditions and policies
for business purposes, to comply with legal and regulatory requirements or in
connection with our contract.
- To respond to legal requests and prevent
harm. If we receive a subpoena or other legal request, we may need to
inspect the data we hold to determine how to respond.
- Fulfill and manage your orders. We
may use your information to fulfill and manage your orders, payments, returns, and
exchanges made through the
App .
- Administer prize draws and
competitions. We may use your information to administer prize draws and
competitions when you elect to participate in our competitions.
- To deliver and facilitate delivery of services
to the user. We may use your information to provide you with the
requested service.
- To respond to user inquiries/offer support to
users. We may use your information to respond to your inquiries and solve
any potential issues you might have with the use of our Services.
- For other business
purposes. We may use your
information for other business purposes, such as data analysis, identifying usage
trends, determining the effectiveness of our promotional campaigns and to evaluate
and improve our
App , products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information.
In Short: We only share
information with your consent, to comply with laws, to provide you with services,
to protect your rights, or to fulfill business
obligations.
We may process or share your data that we hold based
on the following legal basis:
- Consent: We may process your data
if you have given us specific consent to use your personal information for a
specific purpose.
- Legitimate Interests: We may
process your data when it is reasonably necessary to achieve our legitimate
business interests.
- Performance of a Contract: Where we
have entered into a contract with you, we may process your personal information to
fulfill the terms of our contract.
- Legal Obligations: We may disclose
your information where we are legally required to do so in order to comply with
applicable law, governmental requests, a judicial proceeding, court order, or
legal process, such as in response to a court order or a subpoena (including in
response to public authorities to meet national security or law enforcement
requirements).
- Vital Interests: We may disclose
your information where we believe it is necessary to investigate, prevent, or take
action regarding potential violations of our policies, suspected fraud, situations
involving potential threats to the safety of any person and illegal activities, or
as evidence in litigation in which we are involved.
More specifically, we may need to process your data or
share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Vendors, Consultants and Other Third-Party
Service Providers. We may share your data with third-party vendors,
service providers, contractors or agents who perform services for us or on our
behalf and require access to such information to do that work. Examples include:
payment processing, data analysis, email delivery, hosting services, customer
service and marketing efforts. We may allow selected third parties to use
tracking technology on the
App , which will enable them to collect data on our behalf about how you interact with our App over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
In Short:
We only share information with the following third
parties.
We only share and disclose your
information with the following
third parties. If we have processed
your data based on your consent and you wish to revoke your
consent, please contact us using the contact details provided in
the section below titled "HOW
CAN YOU CONTACT US ABOUT THIS
NOTICE?".
- Allow Users to Connect to Their Third-Party Accounts
- User Account Registration and Authentication
- Web and Mobile Analytics
In
Short: We may use cookies and other tracking
technologies to collect and store your
information.
We may use cookies and similar tracking
technologies (like web beacons and pixels) to access or store
information. Specific information about how we use such technologies and
how you can refuse certain cookies is set out in our Cookie Notice
.
In Short:
If you choose to register or log in to our
services using a social media account, we may have access to certain
information about you.
Our
App
offers you
the ability to register and login using your third-party social media
account details (like your Facebook or Twitter logins). Where you choose
to do this, we will receive certain profile information about you from
your social media provider. The profile information we receive may vary
depending on the social media provider concerned, but will often include
your name, email address, friends list, profile picture as well as other
information you choose to make public on such social media platform.
We will use the information we receive
only for the purposes that are described in this privacy notice or that
are otherwise made clear to you on the relevant
App
. Please
note that we do not control, and are not responsible for, other uses of
your personal information by your third-party social media provider. We
recommend that you review their privacy notice to understand how they
collect, use and share your personal information, and how you can set
your privacy preferences on their sites and apps.
7. HOW LONG DO WE KEEP YOUR
INFORMATION?
In
Short: We keep your information for as long as
necessary to fulfill the purposes outlined in this privacy notice
unless otherwise required by law.
We will only keep your personal
information for as long as it is necessary for the purposes set out in
this privacy notice, unless a longer retention period is required or
permitted by law (such as tax, accounting or other legal requirements).
No purpose in this notice will require us keeping your personal
information for longer than
three (3) months past the termination of the
user's account
.
When we have no ongoing legitimate
business need to process your personal information, we will either
delete or anonymize such information, or, if this is not possible (for
example, because your personal information has been stored in backup
archives), then we will securely store your personal information and
isolate it from any further processing until deletion is possible.
8. HOW DO WE KEEP YOUR INFORMATION
SAFE?
In
Short: We aim to protect your personal
information through a system of organizational and technical security
measures.
We have implemented appropriate technical
and organizational security measures designed to protect the security of
any personal information we process. However, despite our safeguards and
efforts to secure your information, no electronic transmission over the
Internet or information storage technology can be guaranteed to be 100%
secure, so we cannot promise or guarantee that hackers, cybercriminals,
or other unauthorized third parties will not be able to defeat our
security, and improperly collect, access, steal, or modify your
information. Although we will do our best to protect your personal
information, transmission of personal information to and from our
App
is at your
own risk. You should only access the
App
within a
secure environment.
9. DO WE COLLECT INFORMATION FROM
MINORS?
In Short:
We do not knowingly collect data from or market to children under 18
years of age.
We do not knowingly solicit data from or
market to children under 18 years of age. By using the
App
, you
represent that you are at least 18 or that you are the parent or
guardian of such a minor and consent to such minor dependent’s use of
the
App
. If we
learn that personal information from users less than 18 years of age has
been collected, we will deactivate the account and take reasonable
measures to promptly delete such data from our records. If you become
aware of any data we may have collected from children under age 18,
please contact us at
[email protected]
.
10. WHAT ARE YOUR PRIVACY
RIGHTS?
In Short:
You may review, change, or terminate
your account at any time.
If you are a resident in the EEA or UK and
you believe we are unlawfully processing your personal information, you
also have the right to complain to your local data protection
supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are a resident in Switzerland, the
contact details for the data protection authorities are available here:
https://www.edoeb.admin.ch/edoeb/en/home.html.
If you have questions or comments about
your privacy rights, you may email us at
[email protected]
.
Account
Information
If you would at any time like to
review or change the information in your account or terminate
your account, you can:
-
Contact us using the contact information provided.
Upon your request to terminate your
account, we will deactivate or delete your account and information
from our active databases. However, we may retain some information in
our files to prevent fraud, troubleshoot problems, assist with any
investigations, enforce our Terms of Use and/or comply with applicable
legal requirements.
Cookies and similar
technologies: Most Web browsers are set to accept
cookies by default. If you prefer, you can usually choose to set your
browser to remove cookies and to reject cookies. If you choose to remove
cookies or reject cookies, this could affect certain features or
services of our
App
. To
opt-out of interest-based advertising by advertisers on our
App
visit
http://www.aboutads.info/choices/.
Opting out of email
marketing: You can unsubscribe from our marketing email
list at any time by clicking on the unsubscribe link in the emails that
we send or by contacting us using the details provided below. You will
then be removed from the marketing email list — however, we may still
communicate with you, for example to send you service-related emails
that are necessary for the administration and use of your account, to
respond to service requests, or for other non-marketing purposes. To
otherwise opt-out, you may:
-
Contact us using the contact information provided.
11. CONTROLS FOR DO-NOT-TRACK
FEATURES
Most web browsers and some mobile
operating systems and mobile applications include a Do-Not-Track ("DNT")
feature or setting you can activate to signal your privacy preference
not to have data about your online browsing activities monitored and
collected. At this stage no uniform technology standard for recognizing
and implementing DNT signals has been finalized. As such, we do not
currently respond to DNT browser signals or any other mechanism that
automatically communicates your choice not to be tracked online. If a
standard for online tracking is adopted that we must follow in the
future, we will inform you about that practice in a revised version of
this privacy notice.
12. DO CALIFORNIA RESIDENTS HAVE
SPECIFIC PRIVACY
RIGHTS?
In
Short: Yes, if you are a resident of California,
you are granted specific rights regarding access to your personal
information.
California Civil Code Section 1798.83,
also known as the "Shine The Light" law, permits our users who are
California residents to request and obtain from us, once a year and free
of charge, information about categories of personal information (if any)
we disclosed to third parties for direct marketing purposes and the
names and addresses of all third parties with which we shared personal
information in the immediately preceding calendar year. If you are a
California resident and would like to make such a request, please submit
your request in writing to us using the contact information provided
below.
If you are under 18 years of age, reside
in California, and have a registered account with
the App
, you have
the right to request removal of unwanted data that you publicly post on
the
App
. To
request removal of such data, please contact us using the contact
information provided below, and include the email address associated
with your account and a statement that you reside in California. We will
make sure the data is not publicly displayed on the
App
, but
please be aware that the data may not be completely or comprehensively
removed from all our systems (e.g. backups, etc.).
13. DO WE MAKE UPDATES TO THIS
NOTICE?
In Short: Yes, we
will update this notice as necessary to stay compliant with relevant
laws.
We may update this privacy notice from
time to time. The updated version will be indicated by an updated
"Revised" date and the updated version will be effective as soon as it
is accessible. If we make material changes to this privacy notice, we
may notify you either by prominently posting a notice of such changes or
by directly sending you a notification. We encourage you to review this
privacy notice frequently to be informed of how we are protecting your
information.
14. HOW CAN YOU CONTACT US ABOUT
THIS
NOTICE?
If you have questions or comments about
this notice, you may
email us at [email protected]
or by post
to:
15. HOW CAN YOU REVIEW, UPDATE, OR
DELETE THE DATA WE COLLECT FROM
YOU?
Based on the applicable laws of your
country, you may have the right to request access to the personal
information we collect from you, change that information, or delete it
in some circumstances. To request to review, update, or delete your
personal information, please submit a
request form by clicking here
.