Privacy Policy
WACHANGA ® PRIVACY POLICY
PLEASE READ THIS DOCUMENT CAREFULLY. IT CONTAINS IMPORTANT INFORMATION THAT YOU SHOULD KNOW BEFORE USING THE WACHANGA WEBSITE, WACHANGA APPS, AND SERVICES. BY USING THE WACHANGA WEBSITE, WACHANGA APPS AND SERVICES YOU WILL BE DEEMED TO HAVE ACCEPTED THIS PRIVACY POLICY.
Wachanga LTD, a company organized under the laws of Cyprus and its affiliates (collectively, “Wachanga” or “we”) has created this privacy statement (“Privacy Policy”) to inform you of its information gathering and dissemination practices for the Wachanga located at https://wachanga.com (“Website”), Wachanga’s mobile applications (“Wachanga Apps”), and the services available or enabled by or through the Website and Wachanga Apps (“Services”).
The Wachanga Services offered via the Website and Wachanga Apps allow parents to plan pregnancy, save information about their well-being and health during pregnancy planning, during pregnancy and after the birth of a child, save important information about the development and health of the child, share updates on the first years of their child’s life.
Your use of the Wachanga Website, Wachanga Apps and Services, including any privacy-related dispute, is subject to this Privacy Policy and Wachanga’s Terms of Service. By using the Website, Wachanga Apps and Services, you (the user) are accepting the guidelines and practices set out in this Privacy Policy and in Wachanga’s Terms of Service.
Upon reading this Privacy Policy, you will be informed regarding the following:
(1) description of personally identifiable information collected by the Website, Wachanga Apps and Services;
(2) how this information is used;
(3) with whom this information may be shared;
(4) choices available to you regarding the collection, use, and distribution of such information;
(5) security procedures that are in place to protect against the loss, misuse, or alteration of personally identifiable information under our control; and
(6) instructions on how you can access and correct inaccuracies in personally identifiable information collected from you.
To the extent that anything in this Privacy Policy conflicts with an existing written (including electronic) agreement between you and Wachanga regarding the use of the Website, Wachanga Apps or Services, including specific licenses, terms of use, or privacy disclosures relating to the Services (collectively, “Product Agreements”), the terms of the Product Agreements shall govern.
If you have questions regarding this Privacy Policy, or concerns relating to compliance with the policies outlined in this Privacy Policy, please contact Wachanga at team@wachanga.com.
A Word from Wachanga
Wachanga is committed to providing superior service to all of our customers and visitors, particularly with respect to their privacy concerns. In particular, we understand the sensitive nature of the content that our users share with their family, friends, and the general public. Accordingly, we consistently strive to secure your privacy and to be responsive to your privacy concerns. This Privacy Policy is designed to address and allay these concerns.
This Privacy Policy contains numerous general and technical details describing the steps we take to respect your privacy. We organized this Privacy Policy by major topic areas so that you can quickly refer to the information that is of most interest to you. Meeting your needs and expectations forms the foundation of everything that we do, including protecting your privacy.
Changes in the Privacy Policy
This Privacy Policy was last updated on January 23, 2020. Wachanga reserves the right to modify this Privacy Policy at any time by posting such changes on this page. Please check the revision date to determine if this Privacy Policy has been modified since you last reviewed it. Your continued use of any portion of the Website, Wachanga Apps or Services subsequent to the posting of an updated Privacy Policy will constitute your acceptance of all such changes. You will be deemed to have been made aware of, and will be subject to, the changes to this Privacy Policy by your continued use of the Website, Wachanga Apps or Services after such notice has been posted for thirty (30) days with the following exception: if at the time you provide your personally identifiable information to Wachanga you limit how such information may be used to communicate with you (either by Wachanga or by third parties), Wachanga will adhere to your preference in this regard unless you consent otherwise.
All personally identifiable information we collect and maintain will be subject to the version of the Privacy Policy in effect at the time of such collection. If the Privacy Policy changes in any material respect, we will not use the personal data we have collected from you in a manner that is inconsistent with the Privacy Policy in effect at the time that such data was collected, without your prior consent.
If as the result of any such changes, you wish to alter the ways in which Wachanga is allowed to use your personally identifiable information, you may do so by following the steps described in the Choices Available to You section of this Privacy Policy.
Legal Issues
The Wachanga, Wachanga Apps and Services are United States-based services. However, because access to the Wachanga Website, Wachanga Apps and Services may use the internet infrastructure of different jurisdictions, use of the Wachanga Website, Wachanga Apps and Services may be subject to the laws of various jurisdictions, including the laws of the United States and the European Union. For example, personally identifiable information collected in the European Union and its Member States is subject to the General Data Protection Regulation (“GDPR”).
Wachanga may disclose your personally identifiable information without your prior affirmative consent if it has a good-faith belief that disclosure is reasonably necessary to meet any applicable law, regulation, legal process, or enforceable governmental request or to investigate or protect against harmful activities to Wachanga’s guests, users, associates, or property or to others. We may also disclose personally identifiable information when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be violating this Privacy Policy, the terms of their agreements with the Wachanga (such as the Terms of Service), or to protect the safety of our users and the public. We may also disclose personally identifiable information under confidentiality and licensing agreements with certain third parties who assist us in developing, operating and maintaining the Wachanga Website, Wachanga Apps and Services, including the content therein.
Wachanga may also be required by law enforcement or judicial authorities to provide personally identifiable information to appropriate governmental authorities. If requested by law enforcement or judicial authorities, Wachanga will provide this information upon receipt of appropriate documentation. Wachanga may also provide information to law enforcement to protect its property and the health and safety of individuals as permitted by statute.
A. INFORMATION WE COLLECT
Information We Collect Through the Wachanga Services
The Wachanga Services may be used by users with User Accounts (“Registered Users”) as well as users without User Accounts (“Unregistered Users”). However, the Wachanga Services functionality may be significantly limited for Unregistered Users.
The Wachanga Services collect information from both Registered Users and Unregistered Users. This information includes information that Registered Users and Unregistered Users voluntarily provide to Wachanga, including usernames, passwords, user profile information (the Registered User’s name, picture, phone number), User Content (as defined in this Privacy Policy), as well as communications between Registered Users and between Registered Users and Wachanga (for instance, as e-mails sent from Registered Users to Wachanga). When a Registered User logs into the Wachanga Services using an authorized third party social network account, such as a Facebook, Twitter, or Instagram account, Wachanga may collect certain information as to that Registered User’s activities and information in that third party social network. Additionally, Wachanga may collect certain technical information automatically from both Registered and Unregistered Users, including the model, manufacturer and OS version of the computer or mobile device used, MAC (Media Access Control) address, device identifiers, International Mobile Equipment Identity (IMEI), and time-stamped logs of messages sent and received, and network status (WiFi, etc.).
We may collect Personal Data about you such as:
PERSONAL DATA: Full name or nickname, email address, phone number, gender, date of birth, password, location, place of residence, time zone, service preferences, identifiers (profile ID attached to your profile data, IP address, analytics IDs, conversation/consultation ID, device ID, messenger ID).
HEALTH DATA: When you use the App, you may choose to provide personal information about your or your child's health such as weight, body temperature, menstrual cycle dates, symptoms, health goals,
other information about your health and activities.
TECHNICAL INFORMATION: Web browser type and version, device model, screen information, mobile service provider, installed app version, OS version, location (country and city), time zone, IP address at the time of usage, messenger identifier, logs on your usage of the Wachanga Services, which include such information as articles you have viewed in Wachanga.
ANALYTICAL INFORMATION. Hashed IP address, hashed profile ID or guest profile ID, hashed conversation/consultation ID, analytics provider's unique user ID (Firebase ID) or client ID (Google Analytics ID) or Messenger ID, third-party cookies.
INFORMATION ON HOW YOU USE WACHANGA SERVICES: general activity, sessions information, app info, authentication, acquisition channel, notification activity, activity within our Services and features
APP DATA FROM THIRD-PARTY SERVICES. Data from services such as Apple HealthKit, Google Fit, and others. Such imported information may include: sports activities, weight, calories burnt, heartbeat rate, number of steps/distance traveled, and other information about your health.
Information We Collect Through the Website
The Website does not automatically collect personally identifiable information from your computer when you browse the Website and request pages from our servers. This means that, unless you voluntarily and knowingly provide us with your personally identifiable information (such as by registering for a User Account for the Services or sending an e-mail to Wachanga), Wachanga will not know your name, your e-mail address, or any other personally identifiable information when you browse the Website.
When you use the Website, Wachanga Apps or Services, Wachanga or trusted third parties authorized by Wachanga may collect certain technical and routing information about your computer (also known as environmental variables). When you browse the Website, Wachanga Apps or Services, your Internet browser (such as Mozilla Firefox, Google Chrome, or Microsoft Internet Explorer) automatically transmits information to Wachanga each time you access content on one of our internet domains. Examples of such information include the URL of the particular web page you visited, your computer’s IP (Internet Protocol) address, and your Internet browser version. We collect this information in order to make the Website, Wachanga Apps and Services function properly and provide you the Website’s functionality. We also use this information to better understand how visitors use the Website, Wachanga Apps and Services and how we can better adjust the Website, Wachanga Apps or Services, their contents, and functionality to meet the needs of our users. However, this information is not associated with any personally identifiable information.
Providing Information to Wachanga
You never have to provide personally identifiable information to Wachanga. However, should you choose to withhold certain required information, Wachanga may not be able to provide you with some or all of the Services. For instance, a User Account is necessary to enjoy all of the Wachanga Services features. Some of the information we ask you to provide may be identified as mandatory or optional. If you do not provide the mandatory information with respect to a particular activity, you may not be able to engage in that activity. Wachanga will inform you of the mandatory or optional nature of the requested or required information.
When you submit personal identifiable information to Wachanga through the Website, Wachanga Apps or Services, you understand and agree that this information may be transferred across international boundaries and may be stored and processed in any of the countries in which Wachanga and its affiliates and subsidiaries maintain offices or web hosting servers. You also acknowledge that in certain countries or with respect to certain activities, the collection, transferring, storage, and processing of your information may be undertaken by trusted vendors of Wachanga. Such vendors are contractually bound not to use your personal information for their own purposes or provide it to any third parties.
Wachanga may establish relationships with various partners whose services may become available to you via the Website, Wachanga Apps, or Services, or third party websites. Typically, these partners will offer services that Wachanga users may find useful, such as those that can be used in conjunction with the Website, Wachanga Apps or Services. In order to use these third-party services, you may be required to provide personal information to the partner providing the services. Unless expressly provided to the contrary, personal information that you provide a Wachanga partner will be subject to the privacy policy posted on that partner’s website, and personal information that you provide while using the Website, Wachanga Apps or Services in conjunction with a partner’s service will be subject to this Privacy Policy. For instance, credit card or PayPal® information entered as part of the filling out a purchase form or registration process collected by a third party’s registration and/or merchant services is subject to the third party’s privacy policy. You should be aware that Wachanga’s agreements with its partners often provide that they will share with Wachanga personally identifiable information collected from you. In such instances, Wachanga may use this information in a manner consistent with this Privacy Policy.
The partners may also use User Content in connection with commercial, sponsored, or related content, within the Website, or Services (such use referred to as “Sponsored Content”). If your User Content (including your name, username, profile picture, content, photograph, or other likenesses) is used on the Website, Wachanga Apps or Services for purposes of Sponsored Content, Wachanga will notify you of this use and provide you the option to “opt-out” of having your User Content used in this way. Also, you may choose to prevent all future use of your User Content for purposes of Sponsored Content within the Website, Wachanga Apps and Services. If you are under the age of eighteen (18) or under any other legal age of majority, you represent that at least one of your parents or legal guardians has also agreed to the terms of this section (and the use of your name, username, profile picture, content, photograph, or other likenesses) on your behalf. Parents or legal guardians of minor children whose User Content appears in Wachanga’s Sponsored Content may choose to “opt-out” and prevent all future use of a minor’s User Content in this way. If you are unsure whether your User Content has been used as part of Wachanga’s Sponsored Content and would like to find out, please contact us at team@wachanga.com. Wachanga will need to verify your identity before responding to any requests so please be prepared to provide certain information such as your username, password, or other information as requested by Wachanga.
Wachanga also reserves the right to use User Content in connection with its commercial activities within the Website, Wachanga App or Services, and to offer you additional Services either for a fee or without. If your User Content (including your name, username, profile picture, content, photograph, or other likenesses) is used by us in this manner, Wachanga will notify you of this use and provide you the option to “opt-out” of having your User Content used in this way.
Email Communications
You may be provided an opportunity to subscribe to periodic newsletters from Wachanga or product updates from Wachanga’s advertisers. The newsletters and product updates are marketing tools that allow Wachanga and its advertisers to inform you of services, products, and updates, as well as other news that may be relevant to you. Subscription may require you to provide your first and last name, your email address, and other information. You will be given the opportunity to choose the type of information Wachanga or its advertisers provide to you and you can opt-out from receiving updates by unsubscribing via the “Unsubscribe” link contained in the email or by either making the corresponding selection in your User Account or by request at team@wachanga.com. Opting-out of these emails will not end the transmission of important service-related emails that are necessary to your use of the App.
In order to provide communication services, we engage third-party service providers to carry out such newsletter services, surveys or notifications campaigns.
This Privacy Policy does not apply to information, content, business information, ideas, concepts or inventions that you send to the Company by email. If you want to keep content or business information, ideas, concepts or inventions private or proprietary, do not send them to the Company in an email.
User Account
Wachanga encourages all of its users to sign up for User Accounts in order to access the full range of features offered by the Website, Wachanga Apps and Services. When registering for a User Account, Wachanga will ask you to provide certain information. Such information may include your name, e-mail, gender, age group, and other personally identifiable information. Additionally, you may log into the Services using an authorized third party social network account, such as a Facebook, Twitter, Google + or Instagram account. In the event that you log into the Services using a third party social network account, Wachanga may collect certain information from your third party social network account profile as well as information regarding your activities on the third party social network. It is completely optional for you to register for a User Account or engage in activities requiring a User Account.
Once you create a User Account, you will be deemed a Registered User and will be able to access, review and update your User Account information through the Services. You may also request to access and change your personal information and privacy preferences by contacting us at team@wachanga.com.
If you wish to deactivate your User Account, you can do so by selecting the corresponding option in your User Account or contacting Wachanga at team@wachanga.com. When you deactivate your User Account, some or all of the information stored and maintained as part of your account may be retained on our servers, including the User Content uploaded via the Services.
Third Party Websites and Mobile Apps
The Website, Wachanga Apps and Services may contain links to websites and mobile apps (“third-party services”) owned and operated by third parties. Such links are presented for your convenience and information. Wachanga does not control these third-party services and is not responsible for their privacy practices or content. Wachanga does not control the information collection and distribution policies on such services other than those that are under the control of Wachanga itself. Content on third-party services may not reflect products, services, and/or information provided by Wachanga. Third parties may also set their own cookies and/or use web beacons, which may be used to identify some of your preferences or to recognize you if you have previously had to contact these third parties. Wachanga does not control the use of such technology by third parties, the information they collect, or how they use such information. You should direct all concerns regarding any third party service to the site administrator or webmaster of such service.
In addition to Wachanga’s own advertising on the Website, Wachanga Apps, or Services, Wachanga also uses third-party advertising companies to serve ads when you visit the Website, use Wachanga Apps or Services. These companies may use general information about your visits to the Website, Wachanga Apps and Services as well as other websites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and your choices as to not having your information used by these companies, please direct such concerns to the respective company’s administrator or webmaster.
Third Party Applications
Wachanga may make third-party applications available to you through the Website, Wachanga Apps and Services. The information collected by Wachanga when you enable a third party application is processed under this Privacy Policy. Information collected by the third party application provider is governed by the provider’s privacy policies.
Information Relating to Children
The Children's Online Privacy Protection Act (COPPA) was passed by the U.S. Congress in November 1998. COPPA provides parents with specific rights regarding their children's privacy. For additional information and resources on COPPA, please visit the Federal Trade Commission Web site at http://www.ftc.gov/. The Wachanga Website, Wachanga Apps and Services are not directed at children under 13 years of age and, therefore, COPPA does not apply. However, we recognize that children under the age of 13 may access the Wachanga Website, Wachanga Apps and Services. The collection of information from such users is covered above. Parents and legal guardians may request that we review, delete, or stop the collection of personally identifiable information of their child. You may do so by contacting us at to team@wachanga.com.
If you are aware of anyone under 13 using the Wachanga Services, please contact us at team@wachanga.com and we will take required steps to delete such information and (or) delete their account.
Age limitation for EU residents. Due to requirements of the GDPR, you shall be at least 16 years old in order to use the App. To the extent prohibited by applicable law, we do not allow use of the App by the EU residents younger than 16 years old. If you are aware of anyone younger than 16 using the App, please contact us at team@wachanga.com and we will take steps to delete such information and (or) delete their account.
Cookies and Web Beacons
The Website uses “cookie” and “web beacon” technology. “Cookies” are short pieces of data generated by a web server that a website stores on a user’s computer. Certain pages on our Website may require the use of a cookie for purposes of keeping information you enter on multiple pages together. Cookies also enable us to customize our Website and offerings to your needs and provide you with a better online experience with us. In addition, cookies are used to:
• measure usage of various pages on our Website to help us make our information; more pertinent to your needs and easy for you to access;
• identify and categorized the internet webpages from which the visitor came to the Website and observe the browsing patterns; and
• provide functionality such as online orders, Wachanga services and other functionality that we believe would be of interest and value to you.
The types of cookies that we use are referred to as “session” cookies and “persistent” cookies. Session cookies are temporary and are automatically deleted once you leave the Website. Persistent cookies remain on your computer hard drive until you delete them. We do not use cookies to gather information concerning your visits to other websites, nor ascertain any personally identifiable information about you apart from what you voluntarily provide us in your dealings with Wachanga. Cookies do not, under ordinary circumstances, corrupt or damage your computer, programs, or computer files.
In addition, the service providers we use to serve and host our advertisements, and/or deliver our e-mails use session and persistent cookies, to track the number of times the Website is accessed and whether the site was accessed from an advertisement. There are no cookies in advertisements or e-mails. The cookie generated from the advertisement or e-mail does not contain any personally identifiable information and will remain on your hard drive until you delete it.
You may set your browser to block cookies (consult the instructions for your particular browser on how to do this), although doing so may adversely affect your ability to perform certain transactions, use certain functionality and access certain content on our Website.
Web beacons are used in combination with cookies to help website operators understand how visitors interact with their websites. A web beacon is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site. As opposed to cookies, which are stored on a user’s computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. These web beacons are not tied to personally identifiable information. The use of web beacons allows the site to measure the actions of the visitor opening the page that contains the web beacon. It makes it easier to follow and record the activities of a recognized browser, such as the path of pages visited at a website. Wachanga uses the information provided by web beacons to develop a better understanding of how the Website’s visitors use the Website and to facilitate those visitors' interactions with the Website. Wachanga may make the aggregate data obtained from web analytics (including from our third-party analytics providers, if applicable) publicly available. If this data is made available, none of the information will be personally identifying information or potentially-personally identifying information.