We are Wondrwall Analytics Ltd (registered in England with company number 11077377) (as Data Collector and Data Processor), our trading subsidiary, Wondrwall MGA Ltd (registered in England with company number 11020801) and our parent company, Wondrwall Ltd (registered in England with company number 09259583) each of whom will be Data Processor) (collectively we or us). Our registered office and main trading address at 3 Hardman Square, Spinningfields, Manchester, England, M3 3EB.
We are committed to protecting and respecting your privacy.
Please read this policy, and any document referred to in it carefully to understand our approach to and use of your personal data and protection of your privacy. When downloading the Wondrwall app (the app or our app), we will ask you to provide clear consent to the various practices described in this policy, to our use of your personal data (and our reasons for doing so) and to our being able to contact you, in relation to the operation of the app, our devices and/or our services, our obligations to you (and your obligations to us) and to our contacting you with marketing messages.
For the purpose of the Data Protection Act 1998 (the Act), and from May 2018 the General Data Protection Regulation, Wondrwall Analytics Ltd is the Data Controller. Our Nominated Representative and Data Protection Officer is Dr. Muddasser Alam. Contact details are set out at the end of this policy.
Information which we collect from you
We will collect and process the following data about you:
– Information which you give to us. This is information about you that you give us by filling in forms on our app or by communicating with us by phone, e-mail or otherwise (including via social media). It includes information you provide when you register to use our app and our services, search for a product or place an order on our app, and when you report a problem with our app and/or our services. The information you give us may include, and is not limited to, your name, address, email address and phone number, financial and credit card information and internet protocol (IP) address used to connect your device to the internet and access our app.
On some pages, you can submit information about other people. For example, if you order a product online and want it sent directly to the recipient or you wish to add or link people to your account(s), you will need to submit the recipient’s address and contact details. In this circumstance, the types of personal information which we will collect are name, address, phone number, email address. We will not use any data which you may provide about any third party to send them any marketing or other communication unless and until they register to use our app and/or our services, save that we may send them an email to confirm they wish to be linked to your account.
– Information which we collect about you. With regard to your use of our devices and to each of your visits to our app we will automatically collect the following information from your device:
– technical information, including (without limitation) the type of mobile device you use, to access our app, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface, and/or the mobile phone number used by you device), mobile network information, your mobile operating system, the type of mobile browser you use, or time zone setting, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform etc;
– information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our app (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
– Information which we receive from other sources. This is information we receive about you if you use any of the websites or other applications we operate or the other services we provide or from manufacturers we work with or from other accounts (e.g. Amazon) you link to your Wondrwall account in respect of products purchased from them. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
Uses made of the information
We use information held about you in the following ways both to enable us to provide our app and other services to you, and based upon your providing us with consent to its use as set out above (which can be withdrawn at any time, please see the section entitled “Your Rights” below ):
– Information which you give to us. We will use this information:
– to complete orders, ensure that we maintain high levels of customer service to you and us and to provide you with the information, products and services that you request from us;
– to provide you with information on the performance of our app, our services and any products which you may purchase from us so that you can make better and informed decisions on how to get the best out of them;
– to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
– to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data;
– to notify you about changes to our app and our services;
– to ensure that content from our app is presented in the most effective manner for you and for your device.
The uses above include sharing data with our group companies to enable them to provide services related to the Wondrwall products and app.
Information we collect about you. We will use this information:
– to administer our devices and/or app and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
– to provide you with information on the performance of our devices and/or app, our services and any products which you may purchase from us so that you can make better and informed decisions on how to get the best out of them;
– to improve our app to ensure that content is presented in the most effective manner for you and for your device;
– to allow you to participate in interactive features of our app and our services, when you choose to do so;
– as part of our efforts to keep our app safe and secure;
– to create a profile relating to you and your property where our devices are installed based upon your use of our app and/or our services, as well as your demographic, age and gender to create user personas which allow us to refine and improve our app and our services, to improve user experience of our app and our services and to target marketing campaigns. You have the right to exclude yourself from this profiling process and other automated decision-making by contacting us at firstname.lastname@example.org
– to make suggestions and recommendations to you and other users of our app about goods or services that may interest you or them.
The uses above include sharing data with our group companies to enable them to provide services related to the Wondrwall products and app.
– Insurance services. We may provide, or partner with companies which provide, home insurance products to you. In such circumstances we will use the information we have collected about you and your property to check against information provided by you. In such circumstances we will use your information to check against information, and share your information with such insurance providers to enable them to check against information, provided by you in relation to such services, to monitor compliance with the terms of any insurance policy issued to you or in respect of the property where the Wondrwall products are installed. We, or a partner provider of insurance, may also use your information for the following reasons:-
– to assess your suitability for an insurance product
– to submit an application on your behalf to one or more insurance company to enable us to obtain a quote
– to assess your financial suitability
– to prevent fraud
– to verify the provided information
– to maintain your records with the insurers
– to advise you on available products
– for monitoring and compliance purposes
– Information which we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure of your information
You agree that we have the right to share your personal information with:
– Wondrwall Ltd, Wondrwall MGA Ltd and their related companies for product registration and commercial support purposes.
– Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 from time to time.
– Selected third parties including:
– business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
– the provider of any third party account which you link to your account, such as Amazon;
– the provider of any insurance policy, including underwriters of such policy, for the purposes of maintaining compliance with the terms of a relevant policy and/or advising you in respect of available insurance products;
– advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, persons within a certain age bracket in a specific geographic area). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
– analytics and search engine providers that assist us in the improvement and optimisation of our app and our services;
– credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
– In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
– If we or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
In respect of products ordered, to the manufacturer of such products.
We use the information you provide about someone else when placing an order only to deliver the product and confirm delivery. We do not share this information with outside parties except to the extent necessary to complete that order.
We use return email addresses to answer the email we receive. Such addresses are not used for any other purpose and are not shared with third parties other than our suppliers, subcontractors and members of our group and for the purposes expressly consented to by you by acceptance of this policy.
Finally, we never use or share the personal information provided to us online in ways unrelated to those described above without also providing you with an opportunity to confirm your consent to such use.
Where we store your personal data
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access our app and our services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our app and our services; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
To prevent unauthorised access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. Access to the information which you have provided will be limited to authorised employees as required for the purposes identified above as well as IT security and maintenance.
Any personal information you provide may be used to verify your identity and assist us in preventing or detecting fraud. As part of these checks your information may be disclosed to credit reference agencies, who may keep a record of that information.
Retention of your data
We will retain your personal data on our systems for as long as you continue to use our devices and services. This is based upon our need to maintain a record of your personal data for the purposes set out in this policy and based upon the period of limitation in any legal claim (in relation to which we may need access to or be compelled to disclose personal data relating to you) being a maximum of 12 years.
You have the right to be informed of how we make use of your personal data in a transparent form when we collect that data from you, which is set out in this policy.
You have the right to lodge any complaint relating to our processing of your personal data with the relevant supervisory authority, which is the Information Commissioner’s Office. Their website can be found at www.ico.org.uk
You have the right to have any personal data which we hold and which relates to you rectified or corrected if it is inaccurate or incomplete.
You have the right a right to have any personal data which we hold relating to you erased and to prevent its processing in specific circumstances, namely
– Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed;
– When you withdraw your consent to our processing of your personal data;
– When you object to our processing of your personal data and there is no overriding legitimate interest for that processing to continue;
– Where that personal data was unlawfully processed;
– Where that personal data has to be erased in order to comply with a legal obligation;
– Where that personal data is processed in relation to the offer of information society services to a child under the age of 16
You have the right to “block” or suppress our processing of personal data relating to you in the following circumstances:
– Where you contest the accuracy of the personal data, in which case we will restrict any further processing until we have verified its accuracy.
– Where you object to the processing of personal data and we are considering whether our legitimate grounds for its processing override that objection.
– When our processing of your personal data is unlawful and you ask for its processing to be restricted rather than deleted
– If we no longer need personal data, but you need the data to establish, exercise or defend a legal claim.
You have the right to obtain and reuse your personal data held by us for your own purposes across different services in a safe and secure way without any negative effect upon its usability via a structured, commonly-used and machine-readable form, free of charge. You can ask us to transmit that data either directly to another organisation (provided that it is technically-feasible), or to send it directly to you.
You have the right to object to our processing of your personal data based on our legitimate interest in doing so (in this case, our provision of our app and our services to you.
You also have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by writing to The Data Protection Officer, Wondrwall Ltd, 3 Hardman square, Manchester, England M3 3EB.
You can correct factual errors in your personal information that we hold by sending us a request that credibly shows that there is an error in our records. To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making corrections.
Access to information
The Act gives you the right to confirmation that we are processing your personal data and to access information held about you. Your right of access can be exercised in accordance with the Act by writing to The Data Protection Officer, Wondrwall Ltd, 3 Hardman Square, Spinningfields, Manchester, England M3 3EB. We use this procedure to better safeguard your information. Any access request will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.