We-Connect App Privacy Notice
March 22, 2021
At WOW Tech USA Ltd. (WTU), we know privacy and security is important to you.
This Privacy Notice describes our privacy and data practices on the We-Connect™ application (the “We-Connect app”). The We-Connect app is owned and operated by WTU, and we can be contacted at the contact information set out below.
Collection and Use of Information
You can use We-Vibe® products without the We-Connect app. No information related to your use of We- Vibe products is collected from you if you don’t install and use the app.
We collect and use information for the purposes identiﬁed below.
To access and use certain We-Vibe product features, the We-Connect app must be installed on an iOS or Android enabled device and paired with a We-Vibe product.
To connect to your partner through the Connect Lover feature, the We-Connect app uses your IP address and a token it creates to connect you and your partner’s smartphones, to let your partner know you are online, and to share control of your We-Vibe product with your partner.
Certain We-Vibe products are equipped with tactile sensors that respond to your unique movements to generate vibrations. When you select sensor mode in the We-Connect app, these interactive products can send vibration controls to, or receive such controls from, your partner’s device through the Connect Lover feature of the We-Connect app.
As with many applications, certain limited data is required for the We-Connect app to function on your device. This data includes the type of device hardware and operating system, unique device identiﬁer, IP address, language settings, and the date and time the We-Connect app accesses our servers.
We also use certain information to facilitate the exchange of messages between you and your partner, and to enable you to adjust vibration controls.
If the We-Connect App is installed on an Android smartphone we would, furthermore, need the authorization to access the location. This shall only enable a Bluethooth-connection of the We-Vibe-Product with such smartphone. The location data will neither be retrieved, saved nor otherwise processed.
We use third-party service providers (such as Google) to collect certain analytical information to help us better understand activity on the We-Connect app, and improve our products and the quality of the We-Connect app.
We receive this data in an aggregated, anonymous form that does not personally identify any individual We-Connect app user. This anonymous analytical data includes the vibration modes, app features used, screens viewed, time spent on the app, and We-Vibe product paired with the app.
We will use Google Analytics only with your specific consent, which you will be able to withdraw at any time through the We-Connect app Settings under Privacy.
You can obtain additional information on Google Analytics’ collection and processing of data and data and privacy and security by clicking on the links provided.
When you use the contact us feature, you leave the We-Connect app. We collect your name and email address to communicate with you and respond to your comment, question or complaint. We also collect certain technical information about your device to help us provide you with support including the operating system and version, type of device hardware, and unique device identifier you are using to access the We-Connect app. We may retain this information to assist you in the future and to improve our customer service. This data is collected outside of the We-Connect app and is not associated with an individual We-Connect app user.
Sharing and Transfers of Information
We do not sell or share information relating to the use of the We-Connect app with third parties, except as described in this notice or as otherwise may be required by law or legal process.
We use service providers to facilitate the exchange of messages and vibration controls when using the Connect Lover feature of the We-Connect app, to provide you with customer support you request, and for analytics purposes.
We, and the service providers with whom we share information (as set out above), may transfer to and store information in the United States and other destinations outside of the European Economic Area (“EEA”). By using the We-Connect app, you acknowledge that certain information described in this Privacy Notice will be collected, stored, processed and transferred in and to the United States or other foreign jurisdictions, pursuant to the laws of the United States or such other foreign jurisdictions, and may be disclosed to or accessed by the courts, law enforcement, and governmental authorities in accordance with those laws. While the United States and other jurisdictions may not offer the same level of privacy protection as your own country, we commit to uphold the privacy protections as explained in this Privacy Notice. We take steps to comply with applicable legal requirements providing an appropriate level of protection for the transfer of information to countries outside the EEA, and ensure that recipients of your information are bound to duties of confidentiality.
Safeguarding and Retention of Personal Information
We have implemented administrative, technical and physical measures designed to safeguard the information in our custody and control against theft, loss and unauthorized access, use, modiﬁcation and disclosure.
We restrict access to information on a need-to-know basis to employees and authorized service providers who require access to fulﬁll their job requirements.
We have information retention processes designed to ensure that we will retain your personal information only for as long as reasonably necessary for the purposes set out above, considering criteria such as applicable statutes of limitations, legal requirements and the duration of your use of the We-Connect app.
Users from the European Union
This section of the Privacy Notice applies only if you use the We-Connect app from a country that is a Member State of the European Union and supplements the information in this Privacy Notice. WOW Tech USA Ltd. is the data controller for processing of information defined as personal data under applicable data protection law (“Personal Data”).
We process Personal Data for the purposes set out in this Privacy Notice, as described above. Our legal basis to process Personal Data includes processing that is: necessary for the performance of the contract between you and WOW Tech USA Ltd. (for example, to provide you service through the We-Connect app); necessary to comply with legal requirements (for example, to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you); and based on your consent (for example, to connect to your partner through the Connect Lover feature), which may subsequently be withdrawn at any time (by contacting us at the email address below) without affecting the lawfulness of processing based on consent before its withdrawal.
In some instances, you may be required to provide us with Personal Data for processing, as described above, in order for us to be able to provide you all of our services, and for you to use all the features of the We-Connect app.
Subject to applicable law, you have certain rights with respect to the processing of your Personal Data. You may be entitled to object to or request the restriction of processing of your Personal Data, and to request access to, rectification, erasure and portability of your own Personal Data. Requests should be submitted by contacting the email or mailing address below.
If you are aware of changes or inaccuracies in your Personal Data, you should inform us of such changes so that our records may be updated or corrected. If you consider that our processing of your Personal Data infringes applicable law, you may lodge a complaint with a competent supervisory authority, which may be the authority in your jurisdiction of residence or work.
Updates to the Privacy Notice
We may update this Privacy Notice to reﬂect changes to our privacy and data practices. You should check this notice occasionally to ensure you are familiar with those changes. If the changes made to the Privacy Notice are material, we will also post a notice on the We-Connect app prior to the effective date of the change.
We welcome your comments and questions regarding this Privacy Notice. If you have questions or concerns, please contact our Privacy Officer at firstname.lastname@example.org or at:
Attn: Privacy Officer
WOW Tech USA Ltd.
103 Foulk Rd Ste 202,
Wilmington DE 19803-3742
For EU residents, WTU’s representative in the EU can be reached at:
Attn: WOW Tech USA Ltd. EU Representative
WOW Tech Europe GmbH
10 249 Berlin