PRIVACY POLICY

Last updated October 16, 2018


Thank you for choosing to be part of our community at WiFi Transfer ("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 our policy or our practices with regards to your personal information, please contact us at contact@wifitransfer.io.

When you use the WiFi Transfer app, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek 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. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of the WiFi Transfer app and our services.

This privacy policy applies to all information collected through the WiFi Transfer mobile application (further referred to as "app"), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the "site").

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.


TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. DO WE COLLECT PERSONALLY IDENTIFIABLE INFORMATION (PII)?

3. DO WE COLLECT MEDIA FROM YOUR PHOTO LIBRARY?

4. HOW DO WE USE YOUR INFORMATION?

5. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

6. HOW LONG DO WE KEEP YOUR INFORMATION?

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

8. WHAT ARE YOUR PRIVACY RIGHTS?

9. DO WE MAKE UPDATES TO THIS POLICY?

10. HOW CAN YOU CONTACT US ABOUT THIS POLICY?


1. WHAT INFORMATION DO WE COLLECT?

Information collected through the site

In Short: Some information - such as IP address and/or browser and device characteristics - is collected automatically when you visit the site.

We automatically collect certain information when you visit, use or navigate the site. 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 the app and other technical information. This information is primarily needed to maintain the security and operation of our site and app, and for our internal analytics and reporting purposes.

Information collected through the app 

In Short: We may collect non-identifiable information regarding your mobile device when you use the app.

If you use the app, we may collect the following information:

  • Mobile Device Permissions.
    • Photo Library permission - To transfer photos and videos to and from your device, the app will ask permission to access your Photo Library.

    • Camera permission - This permission is used only to scan the QR code on web.wifitransfer.io for easy connect.

    • Push Notifications permission - This permission to receive push notifications from the WiFi Transfer team.

      If you wish to change these permissions, you may do so in your device's settings.
  • Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information. 

  • Behavioral data. We may automatically collect data about the state of the app (for instance, if a connection has been successfully created). We use this data to determine if the app is working correctly and to further improve the app.

  • 2. DO WE COLLECT PERSONALLY IDENTIFIABLE INFORMATION (PII)?

    In Short: No, we do not collect personally identifiable information.

    We do not collect personally identifiable information. The app does not have user accounts and neither social network connections or any other means to personally identify our users.


    3. DO WE COLLECT MEDIA FROM YOUR PHOTO LIBRARY?

    In Short: We do not collect media from your Photo Library.

    Any media from your Photo Library is only transferred to the device of your choice using a direct connection. The app does not collect, does not store and does not send any media (such photos, videos or albums) from your Photo Library to us or any other party.


    4. 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 the app for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests ("Business Purposes"), in order to enter into or perform a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the specific processing grounds we rely on next to each purpose listed below.

    We use the information we collect or receive:

  • 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.

  • 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 the app, products, services, marketing and your experience.

  • 5. WILL YOUR INFORMATION BE SHARED WITH ANYONE?  

    In Short:  We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.   

    We only share and disclose your information in the following situations: 

    • Compliance with Laws. 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 and Legal Rights. 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.  

    • 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: data analysis, email delivery, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Apps, which will enable them to collect data about how you interact with the Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. We do not share, sell, rent or trade any of your information with third parties for their promotional purposes.

    • 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.    

    • With your Consent. We may disclose your personal information for any other purpose with your consent.    

    6. 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 policy 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 policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 2 years. 

    When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, 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.


    7. 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, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from the app is at your own risk. You should only access the services within a secure environment.


    8. WHAT ARE YOUR PRIVACY RIGHTS?  

    In Short:  In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information.  

    In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws. 

    If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.   

    If you are resident in the European Economic Area 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:
    http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm       


    9. DO WE MAKE UPDATES TO THIS POLICY?  

    In Short:  Yes, we will update this policy as necessary to stay compliant with relevant laws.  

    We may update this privacy policy 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 policy, 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 policy frequently to be informed of how we are protecting your information. 


    10. HOW CAN YOU CONTACT US ABOUT THIS POLICY?  

    If you have questions or comments about this policy, you may email us at contact@wifitransfer.io.

    If you have any further questions or comments about us or our policies, email us at contact@wifitransfer.io.