Privacy Policy

We are Wondrwall Analytics Ltd (registered in England with company number 11077377) (as Data Controller), our trading subsidiary, Wondrwall MGA Ltd (registered in England with company number 11020801), our trading subsidiary Wondrwall Ltd (registered in England with company number 09259583) and our parent company, Wondrwall Group Ltd (registered in England with company number 11077377) each of whom may be Data Processors or Data Controllers depending on the purpose) (collectively we or us). Our registered office and main trading address at 5 Parsonage, Manchester, England, M3 2HS.

We are committed to protecting and respecting your privacy.

This policy (together with our Terms Of Use https://wondrwall.co.uk/acceptable-use-policy/ and any other document referred to in it explains the basis upon which we use or “process” any personal data which we collect from you, which you provide to us or which may be provided to us from any third party accounts which you may link to our application, and the choices which you can make about the way in which that information is collected and used. To better protect your privacy and make this notice easy to find, we make it available from our app and at every point at which we may request personal information from you.

Please read this policy, and any document referred to in it carefully to understand how we and our trusted partners use your personal data and protect your privacy. When downloading the Wondrwall app (the app or our app), we will provide you with details of the data processing we undertake, this will be provided in this privacy policy and the other documents noted or linked to from this privacy policy and in the consents we request from you to process your data (for example, we may require your consent to use your location data and for certain marketing purposes).

Controller / Processor

Controller

Wondrwall Analytics Ltd will be a controller of personal data it obtains and processes as a business for its own means and purposes. This will include any data we obtain from you that we use for billing, managing our relationship with you, the data we obtain to help us improve our services and any data that we use for things like marketing and analytics (see the section below titled “Information which we collect from you” for further information).

Processor

In some circumstances, Wondrwall Analytics Ltd may be only a processor of your personal data on your behalf. This will arise where data is processed on your behalf for household purposes only and Wondrwall Analytics Ltd do not control the means and purposes of processing.

As noted above, other Wondrwall companies may also be processors of data on behalf of Wondrwall Analytics Ltd from time to time.

Third Party Controllers

In certain circumstances we may share your personal data with trusted third parties. We will only do this where we have a lawful basis to do so. The lawful basis we rely on include:

  • Where there is a legal requirement to share your personal data (e.g. because we are required to by law);
  • Where we have legitimate interests to share your personal data and you have been informed of the purpose for sharing the data.
  • Where you provide your consent to your data being shared with those third parties.

 

Where we share your personal data with third parties using one of the lawful basis mentioned above, those third parties will be independent controllers (or sometimes joint controllers) of your data, where they decide the means and purposes of processing your personal data (or jointly determine the means and purpose of the processing with Wondrwall Analytics Ltd).

Where we share data with landlords, property managers, local authorities and housing associations (who are independent controllers of your personal data), we require those third parties to provide you with separate notices in relation to the data being shared, the purposes for processing your personal data, the lawful basis for processing and your legal rights as they relate to that processing.

See the “Uses made of the information” and ” Disclosure of your information” sections below for further information.

Consents / Permissions

Where we require your consent to process personal data as a data controller or where we share that data with other data controllers (trusted third parties),  we will inform you of the data we wish to process and will always ask for your consent before processing that data.

It is important to note that device permissions (for example, permissions to access location data) are separate to the consents we obtain within the Wondrwall App to use this data as a data controller for our own purposes. Generally, you can tell the difference between a consent and a permission based on where you receive the request.

  • Device Permissions – A device permission will often appear before you enter the Wondrwall App or will be accessible in your devices privacy settings.
  • Wondrwall Consents – Where we require your consent to process data for our own purposes (as data controller), these will appear within the Wondrwall App and your consent settings will be provided within the Wondrwall App settings.

Where your device provides application permission controls, they can be utilised at any time to prevent / allow the Wondrwall app to access certain types of data and will effect the data accessible by the Wondrwall App as a whole, not just the data processed by Wondrwall as a data controller. For example, denying permission to access location data will restrict / remove the geofencing functionality within the Wondrwall App and prevent Wondrwall from obtaining this data for its our own purposes.

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 collect the following information from your device:

 

    • location data from your mobile device and any linked mobile devices, (where permission is provided for the Wondrwall App to access location data and you have provided your consent for Wondrwall to process this data for its own purposes). This data includes data in relation to how you use our geofencing services;
    • 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.

Cookies

Our app uses cookies to distinguish you from other users of our app. This helps us to provide you with a good experience when you browse our app and also allows us to improve our app. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy https://wondrwall.co.uk/cookie-policy/.

Uses made of the information

We use information held about you in the following ways both to enable us to provide the Wondrwall App and other services to you. These are categorised depending on our legal reasons for doing so:

  • Co – Consent – this is where you provide your permission for us to use this data;
  • LI – Legitimate Interests – this is where we have legitimate interests as a business in undertaking certain tasks;
  • PC – Performing our contract with you – this is where we undertake tasks to deliver the app, services and other responsibilities to you; and
  • LR – Where we have a legal requirement to process your data.

Where this is based on your consent, you can withdraw this any time, please see the section entitled “Your Rights” below but in some cases we will be unable to continue to provide the app and/or services to you).

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 (PC and/or LI);
  • 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 (PC);
  • if you are a new customer who has not yet purchased from us and you did not opt out, 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 (LI);
  • to provide you with information about goods or services we feel may interest you and which are similar to those that you have already purchased or enquired about. 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 (LI);
  • to notify you about changes to our app and our services (PC);
  • to ensure that content from our app is presented in the most effective manner for you and for your device (PC and/or LI);
  • to comply with our legal and regulatory requirements (LR and/or LI);
  • to assist our trusted third parties to provide their services / fulfil their obligations to you (for example, landlords, property managers, housing associations and local authorities with whom we have a relationship). They will process your personal data for their own means and purposes (e.g. property energy management – luminosity, heating, etc.), however we will rely on our own lawful basis to share the information (see the “Controller / Processor” section above for further information) (CO and/or LI).
  • to allow selected third parties to provide you with marketing information about their services (if you do not want us to pass your details on to third parties for marketing purposes, please do not tick the relevant box situated on the form on which we collect your data) (Co).

 

The uses above include sharing data with our group companies to enable them to provide services related to the Wondrwall products and Wondrwall App.

Information we collect about you. We will use this information:

  • to provide our app’s location-based services including geofencing, based on your device permissions relating to the Wondrwall App (as a processor on your behalf) AND/OR (Co);
  • to administer our devices and/or app and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes (LI);
  • 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 (PC);
  • to improve our app to ensure that content is presented in the most effective manner for you and for your device (PC and/or LI);
  • to allow you to participate in interactive features of our app and our services, when you choose to do so (PC);
  • as part of our efforts to keep our app safe and secure (LI);
  • 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 hello@wondrwall.co.uk (LI);
  • to make suggestions and recommendations to you and other users of our app about goods or services that may interest you or them (LI);
  • to comply with our legal and regulatory requirements (LR and/or LI);
  • to assist our trusted third parties to provide their services / fulfil their obligations to you (for example, landlords, property managers, housing associations and local authorities with whom we have a relationship). They will process your personal data for their own means and purposes (e.g. property energy management – luminosity, heating, etc.), however we will rely on our own lawful basis to share the information (see the “Controller / Processor” section above for further information) (CO and/or LI).
  • to allow selected third parties to provide you with marketing information about their services (if you do not want us to pass your details on to third parties for marketing purposes, please do not tick the relevant box situated on the form on which we collect your data) (Co).

The uses above include sharing data with our group companies to enable them to provide services related to the Wondrwall products and app.

Social Login details. We may allow you to create, authorise and sign into our app using a third party platform such as Amazon, Twitter and/or Facebook. By using those third-party services to do so, you confirm that you agree to their terms of use, privacy policy and any other agreements or documents which set out the terms of your relationship with them and use of their services, which is separate from your relationship with us and your use of our app and authorise us to share your personal data with any third party website or app provider to which your account is linked. You also authorise us to retrieve and/or receive and/or access your personal data held by any third party website or app provider to which your account is linked which is relevant to our app and services, and agree to the transmission, storage, processing and use by us of your personal data retrieved and/or received from any third party website or app provider to which your account is linked in the manner set out in this Privacy Policy. This paragraph of this policy applies in relation to personal data that is held by any third party website or app provider and that is retrieved and/or received by us or is otherwise transmitted to us and such personal data constitutes user submitted or generated content which is uploaded, posted or otherwise transmitted to us.

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, and share your information with such insurance providers to enable them to check against information provided by you in relation to the tailoring of quotes for and provision of 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 based on the information Wondrwall has about your property and its use;
  • 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; and
  • 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

We will share your personal information or derivatives of it 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, payment service providers, 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.
    • Trusted third party landlords, property managers, housing associations and local authorities, in order for them to provide their property management services (for example property energy management – luminosity, heating, etc.) and fulfil their obligations to you and the wider community (for example, to monitor for fuel poverty, damp, humidity levels, etc.).

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.
  •  If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of sale and other agreements; or to protect the rights, property, or our safety or the safety of our customers, our customers, staff and suppliers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
  • In respect of products ordered, to the manufacturer of such products.
  • In order for those third parties to provide their services / fulfil their obligations to you (for example, landlords, property managers, housing associations and local authorities).
  • In order to market either our or our trusted third party products and services, or for those third parties to market directly to you where you have provided your consent.

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 third 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 set out in this policy.

Finally, whilst we may use your personal information for related purposes to those above, we never use or share the personal information provided to us 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

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”), including the United States of America. It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Security

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 6 years after last use of the services or app or contact with us.

Your rights

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.  However if you do have any concerns we would welcome the opportunity to resolve them with you first – please get in touch at hello@wondrwall.co.uk and we will do our best to resolve them.

You have the right to withdraw your consent to any of the processing of your personal data as described in this privacy policy at any time, either by changing your privacy settings or by contacting our Data Protection Officer, who can be contacted at the details set out below.  As we note above, withdrawing your consent for certain processing may mean we are unable to continue to provide the services and/or app to you.

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; and
  • 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 (in certain circumstances). 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 (i.e. where we set out “(LI)” above. 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 or unchecking 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, 5 Parsonage, Manchester, England M3 2HS.

You have the right to exclude yourself from profiling and other automated decision-making by contacting us at hello@wondrwall.co.uk

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 your information

Data protection law gives you the right to confirmation that we are processing your personal data and to access information held about you, subject to some exceptions. Your right of access can be exercised by writing to The Data Protection Officer, Wondrwall Ltd, 5 Parsonage, Manchester, England M3 2HS. Any access requests are usually free of charge, however we reserve the right to charge a fee where we are entitled to do so by data protection law.

Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to hello@wondrwall.co.uk.

Version number and date

Privacy Policy version number 2020 Wondrwall Privacy Policy V2