Privacy Policy

Effective: 23.01.2024

1. Introduction

Businice S.R.L. ("Businice S.R.L." "us" or "we"), legal entity of Romanian nationality, with registered office in Bucuresti Sector 3, Strada Fetesti, nr. 52, Romania, with order number in the Register of Commerce J40/1905/03.02.2023, unique tax registration code RO47561697, is committed to protecting and respecting your privacy.

Wizzy operates a service that allows you to share your location with other users, which we make available through our apps (the "Service").

This Privacy Policy explains how we collect, use, and protect personal information. Please read it before using our Service, as different countries may have varying standards. We act as the data controller, committed to safeguarding your privacy. By downloading our free app, you agree to the processing, collection, and use of your Personal Data. This policy outlines our views and practices regarding your information. For undefined terms, refer to our Terms of Service.

We are dedicated to protecting and upholding your privacy as we are the controller of your personal data in accordance with Art. 4(7) of the General Data Protection Regulation ("GDPR"), other data protection or privacy laws in the Member State of the European Union, and other guidelines regarding data protection on the Service. To provide our services to you, we offer you a free app that you can download onto your mobile phone. This policy lays out the procedures for how we will process, gather, use, and disclose any Personal Data that you provide to us when you use our products, content, apps, and other services (together, the "Service"). To understand our views on your personal data, our procedures, and how we plan to handle it, please carefully read the following. Terms denoted with capital letters that are not defined in this policy have the definitions specified in the Terms of Service.

2. The Personal Data We Process Within Our Service

We collect and process Personal Data either directly from you (for example, when you provide us specific information) or indirectly (for example, through the technology of our Service). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, or an online identifier, or to one or more factors specific to that natural person's physical, physiological, genetic, mental, economic, cultural, or social identity. "Personal Data" refers to any information relating to an identified or identifiable natural person ("data subject").

Information you give us as a registered user.

If you register an account with us to use the Service, you must provide us with certain Personal Data, including your unique account name, your e-mail address and, if provided, your telephone number and your photograph. You may also be able to register using your user credentials to certain social media sites, such as Facebook. As a registered user of our service, we automatically gather information about your, such as any user-generated content and video content that you broadcast on our service, as well as unique device identifiers, mobile carrier, time zone and locale setting, mobile or device model, operating system, and platform. In addition, we gather behavioral data, such as marketing data on opt-ins and communication preferences. We also gather data when you use your phone number to link your activity on our service across all of your devices, or when you link your contact or subscriber information with your activity throughout our service.

Data that we obtain from your usage of the App and the Service.

We do not handle any Personal Data when you use our service through the app on your mobile device and you are not logged into our services. We obtain your account name, phone number, photos (if supplied), mobile phone type, and mobile phone system version if you have registered for our service. Additionally, when you use the Service on a mobile device, we process location data based on your IP address, the location settings on your device, and, if enabled, the use of a global positioning system (GPS) on your device. You may turn off your mobile device's GPS if you would prefer not to share your location with us.

Information from third parties.

If you use any of the other websites we run or other services we offer, we could get information from you. Additionally, we could get information—like GAID—from third-party SDKs, company directories, and other commercial or openly accessible sources, among other sources.

3. How We Use Your Personal Data

We will use your Personal Data for the following purposes:

Personal Data that we collect from your visit on our website without your registration is processed for system administration (e.g. to improve our Website and services to you), for statistical or security purposes (e.g. to guarantee the website's stability and security) of our website as well as to solicit your feedback. The processing of this Personal Data is necessary for the purposes of our legitimate interests pursuant to Art. 6 (1) lit. f GDPR.

In particular, we will process your Personal Data to be responsive to you and to ensure the proper functioning of our products and organization, Art. 6 (1) lit. f GDPR.

As it is in our legitimate interests, we may use your Personal Data to:
• improve the Service and to ensure content from the Service is presented in the most effective manner for you and your device;
• administer the Service and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• allow you to participate in interactive features of the Service, when you choose to do so;
• personalize the content you receive and provide you with tailored content that may be of interest to you (except in regard to personalized advertising, where we will obtain your consent before providing you with any personalized ads. You can also choose whether to allow personalized ads anytime by setting your preference);
• keep the Service safe and secure;
• develop our Service and conduct product development;
• measure and understand the effectiveness of the advertising we serve to you and others;
• make suggestions and recommendations to you and other users of the Service about goods or services that may interest you or them;
• provide you – or permit selected third parties to provide you – with information about goods or services we feel may interest you. 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.

It is in our legitimate interests to promote the Service and to use information that you give to us, such as user-generated content and video content that you may choose to broadcast on our Service, as part of our advertising and marketing campaigns to promote the Service in accordance with Art. 6 (1) lit. f GDPR.

If you choose to share your location with us, we will also use your data to provide you with location-based services, such as advertising and other personalized content.

If you choose to share your contact with us, we will also use the data to display your contacts within the app, making it easier for the user to connect with others. When you use our application, we do not store your contact list information, including names and phone numbers. We do not collect or process any personal data outside of your contact list.

How we use contact information

We use your contact information to provide you with our services, only including:
• Checking the invitation status of your friends within our app
• Detecting if your friends have registered with our app

We do not use your contact information for any other purposes, including but not limited to advertising or marketing. We also do not share your contact information with third parties.
We also comply with applicable data protection laws and regulations and regularly review our security policies and procedures to ensure they meet the latest privacy standards.
When you register as user of our services, we obtain personal data to create your user account, which is necessary to provide you with the Services according to Art. 6 (1) lit. b) of the GDPR.

We may further use your Personal Data from your registration in accordance with Art. 6 (1) lit. b GDPR to:
• notify you about changes to our Services;
• provide you with user support;
• enforce our terms, conditions and policies;
• communicate with you.

Wizzy may download additional resources from the installed app to improve the in-app experience.

4. How We Share Your Personal Data

We may share your personal data with selected third parties in or outside your country, including:
• our business partners so that we can make you special offers via the Service;
• with respect to on-screen advertisements, advertisers and advertising networks that require the data to select and serve advertisements to you and others. We will not share your contact details with our business parties so they will not contact you directly, but we will share other information so that they can make offers tailored to your requirements;
• our suppliers and subcontractors who help us run the Service;

We may share your information with any member or affiliate of our group, which includes our subsidiaries, our ultimate holding company and its subsidiaries, and companies that we control, are controlled or under common control, and our service providers and strategic business partners, and their respective subsidiaries, in each case in or outside your country, for the purposes set out above ("How We Use Your Personal Data"). For the purposes of developing and maintaining the product, we share your personal data with our group company Businice S.R.L.

We may share your information with law enforcement agencies, public or tax authorities or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
• comply with a legal obligation, process or request (including tax and related reporting requirements);
• enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;
• detect, prevent or otherwise address security, fraud or technical issues;
• protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).

We may also disclose your information to third parties:
• in the event that we sell or buy any business or assets, in which case we may disclose your data to the prospective seller or buyer of such business or assets;
• if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

5. Where We Store Your Personal Data

We will transfer and keep the Personal Data we acquire from you at a location inside the European Economic Area ("EEA"), namely on servers owned by a third party in France, OVH US LLC. Additionally, employees working for us, one of our suppliers, or one of our business partners who are based inside the EEA may process it. For information on the protection of your personal data in relation to storage, please see "The Security of Your Personal Data" below.

6. The Security of Your Personal Data

We take precautions to guarantee that this Privacy Policy is followed and that your information is handled securely. Unfortunately, information transmitted via the internet is not entirely safe. Despite our best efforts to safeguard your personal information, we are unable to ensure the security of any information you submit over the Service; you transmit at your own risk. We do, however, have the necessary organizational and technical safeguards in place to provide a degree of security suitable to the danger of variable probability and severity for the liberties and rights of you and other Users. We keep these organizational and technical safeguards in place and may occasionally make changes to them to improve the general security of our systems.

Because has certified itself under the EU-US-Privacy Shield, the transfer of your Personal Data to our host provider, OVH US LLC, is carried out under a sufficient degree of data protection as compared to the GDPR.

We could occasionally include links to and from the websites of our affiliates, advertisers, and partner networks. Please be aware that these websites have their own privacy policies, and that we do not assume any responsibility or obligation for them, if you follow a link to any of these websites. Before providing any personal information on these websites, please review these policies.

7. Data Retention

Your information will be kept on file for as long as necessary to comply with legal requirements. We could keep your information even after you stop using our services. Despite the aforementioned, we reserve the right to keep any personal data that is deemed legitimately required to uphold our agreements, fulfill our legal duties, and settle legal disputes.

8. Information Relating to Children

Children under the age of 13 are not intended audience for the Platform. Without parental or guardian permission, those who are younger than the legal age limit are not permitted to use the service or create an account. We shall remove the information and close the user's account if we learn that personal data was obtained from a child under that age in the applicable jurisdiction without the agreement of their parents or guardians. Please email us at [email protected] if you think we may have obtained personal information from a child under the legal age in the relevant jurisdiction without that child's parent or guardian's consent.

9. Your Rights

You have the right to access your Personal Data that we hold about you and to correct, update, amend, suppress, delete or otherwise modify any Personal Data where it is inaccurate, or has been processed in violation of the applicable data protection regulations, unless we have to keep the Personal Data for legitimate business or legal purposes. Prior to the fulfilment of your request concerning your Personal Data, we may ask you to verify your identity before we can act upon your request. You may object to the use or processing of your Personal Data or withdraw consent to use your Personal Data at any time.

You have the following rights:
• The right to require free of charge (i) information whether your Personal Data is retained and (ii) access to and/or (iii) duplicates of the Personal Data retained. However, if the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request;
• The right to request proper rectification, removal or restriction of your Personal Data;
• Where processing of your Personal Data is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the Personal Data concerning you in a structured, commonly used and machine-readable format or to have your Personal Data transmitted directly to another company, where technically feasible (data portability);
• Where the processing of your Personal Data is based on your consent, the right to withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal or to any other existing legal justification of the processing activity in question;
• The right not to be subject to any automatic individual decisions which produce legal effects on you or similarly significantly affects you;
• The right to take legal actions in relation to any breach of your rights regarding the processing of the Personal Data, as well as to lodge complaints before the competent data protection regulators.

As far as we process your Personal Information on the basis of our legitimate interests (Art. 6(1) lit. f) GDPR), you may object to processing (Art. 21(1) GDPR) at any time. You may find a detailed description of our processing activities and the legal basis in the section before. If you object to such processing, we ask you to state the grounds of you objection in order for us to examine the processing of your personal data and decide whether to adjust the processing accordingly.

Please note that the processing of your personal data may involve direct marketing activities as described above. If you do not want to have your activity on Wizzy's Services processed for direct marketing activities, you can object to any data processing free of charge at any time via e-mail (Art. 21(2) GDPR).

Please send an e-mail to us if you would like to exercise any of your rights ([email protected]).

10. Complaints

If you would like to file a complaint regarding our handling of your personal data, contact us at [email protected]. We will do our best to address your request as quickly as possible. This does not affect your ability to file a complaint with your data protection authorities or use the procedures outlined in the Terms of Service for resolving disputes.

11. Changes

Any significant changes to this Policy will normally be communicated to all users by commercially reasonable means, such as a notice on our Service. But, you have to review this Policy frequently to make sure that any modifications have occurred. Additionally, we will update this policy's "Effective" date, which indicates when it went into effect. You agree to the revised Policy if you keep using the Services or have access to them after its effective date. You must cease using the Services and gaining access to them if you disagree with the revised Policy.

12. Contact

Requests, queries, and remarks about this policy are appreciated and should be sent to [email protected].

13. Data Protection

We remind you that you can contact the Wizzy Data Protection Officer at any time by sending your request to the e-mail address: [email protected]

13. Account Deletion

Under EU law, users have the right to request their data be removed permanently from the platform. You can do this at any time by sending your request to the e-mail address: [email protected]