Hello Uenters!

Uento is an affiliate of Waypedia LLC so all the privacy rules you need to know are under Waypedia’s name. Uento is under what Waypedia calls it “Reward Platforms”.

It’s important for you to learn how the whole platform works to know exactly where your personal information is used for. When you sign up into Uento’s app you’re not only accepting Uento’s terms and conditions, but you also will be accepting all Waypedia’s privacy policy as well.

Uento Terms and conditions: Rules about Uento app. Read them at https://uento.com/TOS
Waypedia’s Privacy policy: How your personal information is used in Uento.

If you have a problem or questions on how your personal information is used, then read all this carefully! If you want to delete all your personal information, you can do it by closing your account in the Uento app or by sending us an email at privacy@uento.com

This privacy policy explains Waypedia’s privacy practices in connection with information collected about you through your use of Waypedia services, including our ad platform, Reward Platforms (like Uento), our dashboard, and our website. (“Waypedia” means Waypedia LLC. and its subsidiaries and affiliates, and may also refer to our advertiser and publisher services, including our dashboard, and our website.)

This Privacy Policy can be also found at https://waypedia.com/legal/privacy

 

1. What is Waypedia?

Waypedia LLC operates a platform that enables advertisers to reach mobile in-app ad inventory, mobile app users to be compensated for their attention, and mobile app publishers to receive revenue from the ad space in their applications.

Publishers use Waypedia by adding our SDK to their apps; this allows us to display ads on behalf of our advertisers in ad space within the app (our advertising and monetization service).  (“SDK” is short for “software development kit”, meaning software that a publisher can include in its app to enable Waypedia services in the app.)

Users use Waypedia through engaging with ad offers we display through our ad placements in a participating publisher’s app. Waypedia ad placements include offerwall, which allows a user to choose from a page of various rewarded ad offers (“rewarded” meaning that the user receives a reward in the form of virtual currency for the app they’re using); video, which offers the user virtual currency reward in exchange for engaging with a video offer; and interstitial, which rewards the user with virtual currency or access to premium content in exchange for a short commercial break.

Marketers use Waypedia by placing orders for our ad services, and in turn, we pay publishers for the right to show ads in their apps.

To further support our publishers, we also offer related optional services, such as analytics, which helps publishers understand how their users use their apps, and virtual currency management services, which helps publishers manage in-app virtual currency.

We provide customer support for users who did not receive an expected in-app reward; this involves working with the advertiser, the user, and the publisher to identify and resolve the issue. 

Lastly, Waypedia owns a Rewards Platform called Uento App where it rewards users for playing mini games and interacting with our advertiser’s apps. You can access all Uento links here www.uento.com

 

2. What information does Waypedia collect and how is it used?

That depends on how you interact with Waypedia. Read on to learn about the following categories:

·        If you are an individual who uses a mobile app that uses Waypedia ad placements such as Uento App, go to the section 3 titled Information collected through our ad platform and Rewards platforms.

·        If you are an individual who submitted a customer support ticket relating to a Waypedia ad, go to Customer support information.

·        If you access Waypedia’s corporate website (www.waypedia.com), or if you use Waypedia’s dashboard to manage your Waypedia advertiser or publisher services, go to the section titled Website and dashboard user information.

·        All users should also review the section titled General privacy practices.

 

3. Information collected through our Ad and Reward platforms

3.1 What information is NOT collected?

Waypedia’s ad platform does NOT access, collect, or receive your name, your email address, your username, your physical address, your phone number, your credit card or other financial information.

EXCEPTION 1: If you sign up in any of our Reward Platforms see point 3.2.2 for what we collect.
EXCEPTION 2: If you submit a customer support request or sign up as an Advertiser, you provide us with additional information, such as your email address, and we use that information to respond to your request; see Customer support information below.

 

3.2 What information is collected through Waypedia’s ad platform?

3.2.1  From publishers (you as a regular mobile or desktop user)

If you are an individual who uses a mobile app or desktop, and the app’s or website’s publisher uses Waypedia services, we receive and collect information about your device and the Waypedia ad offers that you view, and we use this information to reward you for offer engagement, to draw inferences about which offers may be more or less interesting to you, and to provide publishers with information about how their apps are used. This information is collected through our SDK, as integrated into the app you use to access Waypedia ad placements, and through your interactions with ads on our ad platforms.

Here are the types of information that we collect:

·        Device identifiers (a device identifier is a string of numbers and letters unique to your smartphone or tablet assigned by the manufacturer or platform provider), such as

·        Google Advertising ID (GAID), or Android ID in its absence (or MAC address, in the absence of both), for Android devices, and

·        ID for Advertisers (IDFA), for iOS devices

·        The publisher’s user identifier

·        Information about the device itself, including

·        Whether it is a smartphone or tablet

·        What operating system and version it uses (e.g., iOS, version 11.0)

·        Model and manufacturer (e.g., Apple iPhone X, Samsung Galaxy S8)

·        Screen size, screen density, and other information relevant to ad formatting and display

·        Information about the internet connection used to access our services, including

·        Mobile carrier

·        Network provider

·        Network type (e.g,. wifi)

·        IP address

·        Timestamp and duration (i.e., when the device connected to our services began and how long the connection lasted, for a given session)

·        Information about the app and our SDK, including 

·        Which version of our SDK is integrated in the app used to access our services

·        API key (identifier for application); Partner App version; list of installed apps (the applications and/or processes which are installed or run on your device while the Partner App is active or inactive).

·        Location-related information - We infer the perceived general location of the device based on:

·        The IP address used to access our services

·        Location-related device settings, such as the device’s country code, language setting, and time zone

·        Ad-related information - We collect information about the ads you view, such as: 

What the ad offer is about;

What type of ad it is (e.g., text, image, or video);

Which ad placement is involved (i.e., where the ad offer is displayed within the mobile app in which you accessed it); and

Whether you respond to the ad’s “call to action” - for example, did you click through to the advertiser’s website? 

·        Survey information

Waypedia surveys - We occasionally run ad offers for demographic surveys so we can learn more about the people who use Waypedia. If you opt to complete one of these surveys, we associate the responses with the device identifier for the device you used to access and complete the survey offer

Advertiser surveys - Advertisers occasionally run survey ad offers through Waypedia. If you complete one of those surveys, your responses go to the advertiser (not to Waypedia), and will be governed by the advertiser’s privacy policy.

·        Information from our advertisers or publishers. The advertisers and publishers using our services may provide us with information they have separately collected about you (for example, whether you already have the app that is being advertised), so that we can improve the relevance of the ads we serve on their behalf (for example, by not showing you ad offers for an app because you already have it).

 

3.2.2  From our Reward Platforms (you as a registered user)

In case you register for an account in one of the Rewards Platforms (like Uento app), we receive and collect information about you, your device and the ad offers that you view and engage with, and we use this information to provide and improve the services, reward you for offer engagement, and to draw inferences about which offers may be more or less interesting to you. This information is collected through the Waypedia, and through your interactions with ads.

Here are the types of information that we may collect from you:

 

·        Device identifiers (a device identifier is a string of numbers and letters unique to your smartphone or tablet assigned by the manufacturer or platform provider), such as

·        Google Advertising ID (GAID), or Android ID in its absence (or MAC address, in the absence of both), for Android devices

·        ID for Advertisers (IDFA), for iOS devices

Information about the device itself, including:

·        Whether it is a smartphone or tablet

·        What operating system and version it uses (e.g., iOS, version 11.0)

·        Model and manufacturer (e.g., Apple iPhone X, Samsung Galaxy S8)

·        User agent

·        Battery fill and temperature

·        System uptime

·        Screen size, screen density, and other information relevant to ad formatting and display

·        Memory and CPU information

Information about the internet connection used to access our services, including:

·        Mobile carrier

·        Network provider

·        Network type (e.g,. wifi)

·        IP address

·        Timestamp and duration (i.e., when the device connected to our services began and how long the connection lasted, for a given session)

·        Location-related information – We infer the perceived general location of the device based on:

·        The IP address used to access our services

·        Location-related device settings, such as the device’s country code, language setting

Ad-related information – We collect information about the ads you view, such as:

·        What the ad offer is about;

·        What type of ad it is (e.g., text, image, or video);

·        Which ad placement is involved (i.e., where the ad offer is displayed within the mobile app in which you accessed it); and

·        Whether you respond to the ad’s “call to action” – for example, did you click through to the advertiser’s website?

Other general information, such as:

·        Payment handling information. If you opt for a payout in one of the reward platforms or Apps you also opt to provide your email address or PayPal account address for Waypedia to be able to send your reward. To ensure greater security, Waypedia shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction. Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment

·        Registration and authentication. By registering or authenticating, You allow Waypediato identify you and give you access to dedicated services. Depending on your selected registration / authentication method, third parties (as laid out in section 3 of this policy) may provide registration and authentication services. In this case, this Waypedia will be able to access some Data, stored by these third party services, for registration or identification purposes.

·        Survey information. We occasionally run ad offers for demographic surveys so we can identify client survey opportunities that you may be eligible for through the Third Party Market Research (MR) companies. If you opt to complete one of these surveys, we associate the responses with the device identifier for the device you used to access and complete the survey offer. Waypedia may share your personal information and/or social-demographic information, including, without limitation, a unique identification number (“UID”), postal code, region, province, gender, marital status, education, ethnicity/race (where permitted by applicable law), employment related information, non-personally identifiable information on household members, consumer product and service usage and ownership (e.g., computers, cars, mobile devices, video games, etc.), home ownership, pet ownership, employment information (e.g., title, role, travel, industry, etc.), and social grade, with third party sample/market research companies (individually each a “Third Party MR Company” and collectively the “Third Party MR Companies”) for the following purposes:

Identifying client survey opportunities that you may be eligible for through the Third Party MR Companies; and

Disclosing such data elements to clients of the Third Party MR Companies for audience measurement services; and

Appending such data elements to completed client surveys and delivering the appended survey data to clients of the Third Party MR Company(ies) for analytical or research purposes; and

Other uses as set forth in their privacy policy.

If you are eligible for a client survey opportunity offered through a Third Party MR Company, the Third Party MR Company will provide your unique identification number and a survey link to us and we will invite you to participate in the client survey through our incentivized offer walls. We will not share your name, email address, or phone number with the Third Party MR Companies. In connection with the sharing of your information with a Third Party MR Company, your information may be transferred and stored outside of your country of residence, including, without limitation, in the United States, and by agreeing to this privacy policy you are agreeing to the processing and exportation of your personal information as set forth in this Section. If you complete one of those surveys, your responses go to the MR company (not to us), and will be governed by the MR company’s privacy policy. If you have any questions about this data sharing or if you want to opt-out, please contact support@waypedia.com. If you opt-out, it is the responsibility of us to inform the Third Party MR Companies. Please note that Waypedia is solely liable and responsible for managing all opt-out requests. Your participation in such survey opportunities does not entitle you to any benefits offered by, or membership with, the Third Party MR Companies.

Unless specified otherwise, all Data requested is mandatory and failure to provide this Data may make it impossible for Waypedia to provide its services. In cases where Waypedia specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.


3.3 How does Waypedia use information collected through the ad platform?

We use the information we collect through our ad platform:

·        To show you ads customized to what our system infers to be your interests, preferences, and locations, based on the information associated with your mobile device’s advertising identifier; this is referred to as behavioral or interest-based advertising

·        To show you ads based upon the context of the app you’re using instead of based on your inferred interests; this is called contextual advertising

·        To determine which ads are more or less effective

·        To target and filter ads for publishers and advertisers  - for example, an advertiser may want to reach an audience in a specific country, or a publisher may want to exclude some categories of ads from its app

·        To avoid showing you ads for an app you already use, or the same ad offer too many times

·        To track the ad offers you complete so we can provide you with the reward you earned

·        To respond to and resolve your customer support requests 

·        For analysis and research, both to improve our services and to report our services’ results to our advertisers and publishers

·        To prevent and detect fraud, and to maintain our services’ and systems security

We keep this collected information as long as it remains necessary to provide the Waypedia Services.

 

3.4  How does Waypedia share information collected through the ad platform?

Waypedia does not buy, sell, or trade information with unrelated third parties. We collect the information we use through our ad platform, and we use it internally within our ad platform. This information is shared in only with authorized partners or vendors, as follows:

Publishers using Waypedia’s analytics service can access aggregated information about how their users interact with their apps. No information is provided on an individual basis.

Advertisers using Waypedia’s advertising service receive the device identifiers associated with those who view an ad offer via Waypedia and go on to buy the advertiser’s advertised product or service from its website or app.

Vendors and service providers working for Waypedia, or for our advertisers or publishers, have access to information collected via our ad platform as necessary for them to perform their services we engaged them to do. Under our agreements with our service providers, they can use this information only as needed to perform their services; they cannot use it for their own purposes. 

Our corporate family includes international subsidiaries; we provide each other with access to our shared resources as needed to fulfill our shared business responsibilities, including providing and supporting our ad platform. More about Waypedia ‘s corporate family is here -https://www.Waypedia.com/legal/#affiliates  

We may share your information, to the extent permissible by applicable laws, when we believe in good faith that such sharing is reasonably necessary to investigate, prevent, or take action regarding possible illegal activities, or to comply with legal process. We may also share your information in situations involving potential threats to the physical safety of any person, violations of this privacy policy or our terms of service; or to respond to the claims of violation of the rights of third parties and/or to protect the rights, property and safety of Waypedia, our employees, users, or the public and obtaining your consent is difficult. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations.

Business Transaction. We may share your information with another company if they merge with us or purchase our assets, or as part of due diligence for such a transaction.

Consent. We may share your information in any circumstances where we have your consent.

Aggregated Data. We may aggregate, anonymize and/or de-identify information collected through our ad platform so that the information can no longer be associated with you or your device in specific; our use and disclosure of information that is not identifiable to a specific person or device is not restricted by this Privacy Policy, and it may be used and disclosed to others without limitation.


3.5  How long does Waypedia keep information collected through the ad platform?

We keep information as long as necessary to provide our services, generally speaking. Information used for interest-based ad targeting is rotated out on a 90-day basis. Conversion data and non-production backups of production data are retained for longer due to financial records and disaster recovery requirements.

 

3.6  How can I opt out of interest-based advertising?

If you prefer not to receive ads and offers that are tailored to your perceived interests, you can enable device-based “opt-out” options in your device’s settings. If you do so, we will cease processing your personal data for such purposes. We collect these opt-out signals ourselves, and will also respect consent flags if passed by the publisher of the app you are using. To adjust your advertising preferences in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking. To adjust your advertising preferences in Android, visit Settings > Google > Ads > Opt out of interest-based ads. You can also request an opt-out specific to Waypedia by emailing us at optout@waypedia.com and following the directions we provide you.

Opting out of interest-based advertising does not mean opting out of advertising altogether. You will still receive advertising, but it will not be targeted based on your inferred interests.

 

3.7  Customer Support Information

To submit a request for Waypedia customer support (for example, for help with a missing Waypedia ad offer reward), you must submit a working email address; this is required for us to be able to communicate with you about investigating and resolving your support issue. Emails and other information submitted for support purposes are used only for support purposes; depending on the circumstances, this may require us to share your information with the advertiser and publisher whose advertisement and app are involved.

 

4. Website and dashboard user information

4.1  Waypedia dashboard

Our advertisers and publishers have access to a Waypedia dashboard, which allows them to manage their use of Waypedia services and review their results. When you create a dashboard account, you provide information such as your name, the name of your company, your username and password, your email address, postal address, phone number, and payment information, as well as any required financial information (e.g., tax ID, VAT, or sales tax registration number). We use Stripe to process Advertiser credit card payments. We use this information to provide you with Waypedia services and support. If you invite other users to your Waypedia dashboard account, we will collect the email address of the employee or other individual you wish to add and use it to send them a one-time email informing them they have been added. If they are not your employee, you must have their consent before providing us with their email address to invite them to join your dashboard account.

 

4.2  Waypedia website and social media

Our corporate website, www.waypedia.com, provides general information about Waypedia and our products and services; we also maintain a blog and various social media channels. If you post information through one of these channels, you understand that we cannot control what other users do with any content (including without limitation images, ratings, captions, and comments) you voluntarily post. You should not post any sensitive personal data, such as details of your ethnicity, health or political preferences or photos of yourself to any Waypedia board, blog, social media channel, or forum, nor should you allow other users to have access to your content if you do not wish them to make your content publicly available to be collected and used by others, or to be redistributed through the Internet and other media channels.

 

4.3  Aggregated data

We may aggregate, anonymize and/or de-identify information collected through our website, dashboard, and social media channels so that the information no longer relates to you individually. As a result, our use and disclosure of aggregated and/or de-identified information is not restricted by this Privacy Policy, and it may be used and disclosed to others without limitation.

 

4.4  Cookies and Related Tracking Technologies.

When you use our website and dashboard, we may place and read cookies or access information on your device to obtain information about the performance of our site, enable you to move around the site, to record your preferences and to serve you with advertising that is relevant to your interests. This information may, where permitted by applicable law, then be combined with other information we hold about you. Information and technologies we may use include:

·        Device and usage information. When you interact with our website or dashboard, we may collect information such as (a) IP addresses, unique device identifiers, and other information about your device(s), browser types, browser language, operating system, the state or country from which you accessed the services; and (b) information related to the ways in which you interact with our website, such as: referring and exit pages and URLs, platform type, the number of clicks, internal Waypedia subdomain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the services, error logs, and other similar information. As described in Online Analytics below, we may use third party analytics providers and technologies, including cookies and similar tools, to assist us in understanding how the Waypedia Web Services are used.

·        Location information. We may market to you based on your location, inferred from the IP address you use to reach our website or dashboard. 

·        Cookies and other technologies. When you use the Waypedia website or dashboard, we use persistent and session cookies and other similar technologies to perform various tasks, such as: (a) storing your dashboard account username and password; (b) analyzing the usage of our website and dashboard; and (c) customizing our website and dashboard to your preferences. You can find more information about cookies and how to manage them at http://www.allaboutcookies.org/. Most browsers automatically accept cookies, but you can modify your browser settings to decline cookies by visiting your browser’s help page. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some features of the Waypedia Web Services. By using our website and dashboard with your browser set to accept cookies, you consent to our use of cookies in the manner described above. In addition to cookies, we may use a technology called clear gifs (a.k.a. web beacons) that help us better manage and analyze content. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages. Where permissible under applicable law, we may include web beacons in e-mail messages or newsletters to determine whether the message has been opened and for other analytics purposes.

 

4.5  Online Analytics

To help understand your use of our website and dashboard, we use third-party web analytics providers, such as Google Analytics, which in turn use the technology described above at Cookies and related tracking technologies. Our service providers collect and use this information to evaluate how websites are used. To opt out of tracking via Google Analytics, you may install the Google Analytics Opt-Out Browser Add-on.

 

4.6  How Waypedia uses information collected through our website and dashboard

We use the information we collect through your use of our corporate website and our dashboard to provide our services, to manage your publisher or advertiser account, to do business with you as a publisher or advertiser (including taking orders, reporting results, and so on), to communicate with you (including responding to your inquiries, informing you about products and services based on your marketing preferences, and notifying you of new features), to analyze our user base and usage patterns, and to provide and improve our services. We also use this information to improve our corporate website content and to personalize the dashboard for you. We keep the information we collect for so long as we continue to provide our website, dashboard, and services.

 

4.7  How does Waypedia share information collected through the website and dashboard?

We don’t buy, sell, or trade in information collected through our website and dashboard. We share it only as described here:

·        Vendors and service providers working for Waypedia, or for our advertisers or publishers, have access to information collected via our ad platform as necessary for them to perform their services we engaged them to do. Unless we tell you otherwise, under our agreements with our service providers, they can use this information only as needed to perform their services; they cannot use it for their own purposes. These service providers include analytics providers, payment processors, product fulfillment providers, providers of technical infrastructure, technical support, email providers, and customer support vendors.

·        Our corporate family includes international subsidiaries; we provide each other with access to our shared resources as needed to fulfill our shared business responsibilities, including providing and supporting our ad platform. More about Waypedia ‘s corporate family is here - https://www.waypedia.com/legal/affiliates 

·        We may share your information, to the extent permissible by applicable laws, when we believe in good faith that such sharing is reasonably necessary to investigate, prevent, or take action regarding possible illegal activities, or to comply with legal process. We may also share your information in situations involving potential threats to the physical safety of any person, violations of this privacy policy or our terms of service; or to respond to the claims of violation of the rights of third parties and/or to protect the rights, property and safety of Waypedia, our employees, users, or the public and obtaining your consent is difficult. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations.

·        We may share your information in connection with any merger, reorganization, a sale of some or all Waypedia assets, or a financing or acquisition of all or a portion of our business by another company (including in the course of due diligence for any such transaction).

·        We may share your information in any circumstances where we have your consent.


4.8  What choices do I have about use of information related to Waypedia’s website or dashboard?

4.8.1 Commercial Marketing

We will comply with applicable marketing laws; for example, where applicable law requires prior consent, Waypedia will only send you marketing email if you have opted in. To opt out of receiving marketing emails or other commercial communications from us, use the “unsubscribe” option in a commercial email from us or send us an email at privacy@Waypedia.com. It may take several days for us to process your request, consistent with applicable law.

 

4.8.2 Publisher and Advertiser Accounts.

If you have access to a dashboard publisher or advertiser account and do not want your email address used, contact us at privacy@waypedia.com.

 

4.8.3 Dashboard Account Deactivation.

To request deactivation of your dashboard account, email us at privacy@waypedia.com. Some information may remain in our records after deactivation of your account based on business needs. After deactivation, we may continue to use aggregated data derived from or incorporating your personal information but not in a manner that would identify you personally.

 

4.9.4 Waypedia Apps

Under Reward Platforms we currently manage Uento app. If you want to erase any personal information from our Reward Platforms we will need to delete your account and you can request that at privacy@uento.com

 

5. General Privacy Practices


5.1  How does Waypedia secure personal information?

We use physical, electronic, and managerial procedures designed to safeguard your information and data security, and to prevent unauthorized access to. These safeguards take into account the sensitivity of the information that we collect, process, and store and the current state of technology. Although we take such measures to safeguard against unauthorized disclosures of information, the Internet and the services are not 100% secure so we cannot assure you that all information we collect or store will be protected from all unauthorized access.

 

5.2  International Users

If you are located outside the United States and choose to use our services or provide information to us, your information is provided to Waypedia in the United States, and may be and processed and stored in the United States and otherwise outside of your country of residence, by Waypedia and by third parties with whom we share in accordance with this privacy policy.

 

5.3  Child and youth users

If you are under the locally applicable minimum age of consent to data use, please do not register for or use any Waypedia service or send us any information about yourself. (In the US, your minimum age is 13; in the EEA and Switzerland, it is age 16 unless your country has adopted a lower age.) Please inform us by emailing privacy@waypedia.com if you learn that we have been provided with personal information from a child under the applicable minimum age without verified parental consent, so that we may take appropriate steps to delete that personal information.

 

5.4  Changes to Our Privacy Policy

We reserve the right to update (amend) this Privacy Policy from time to time to reflect changes in the law, our data collection and use practices, the features of our services, or advances in technology. Please check this page periodically for changes and review them carefully, as our use of information at a given point is governed by the Privacy Policy that is then in effect. Your continued use of our services after a Privacy Policy update means that you consent to the updated policy. 

 

5.5  Third Party Sites and Services

Our services and communications may contain links to third-party websites, including social media services. Your use of these links, websites, or services may result in the collection, processing or sharing of information about you, depending on what you use. We are not responsible for the content or privacy practices of other websites or services that may be linked on our services. We do not endorse or make any representations about third-party websites or services. Any information you choose to provide to these services, or that they collect, is covered by their privacy policy rather than ours, so please make sure to read it.

 

5.6  Notice to California Users

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. As explained above, we do not sell or share your personal information (as that term is defined under California law) with third parties for use for their own marketing purposes.

 

5.7  Accessing and Deleting Your Information.

You may, under applicable European law, have the right to access, correct, update or delete personal information Waypedia holds about you.  Please see Exercising your rights as a data subject below for more information about those rights. 

If you have a Waypedia publisher or advertiser dashboard account, you may use your account settings to access and update your account information. You may also email us at privacy@waypedia.com to request access to or removal of personal information we have about you. In some cases, we may not be able to remove your personal information (e.g., for legal reasons), in which case we will let you know if we are unable to do so and why.

 

6.  The EU GDPR

The EU General Data Protection Regulation (“GDPR”), effective May 25, 2018 in the EEA countries and Switzerland, requires Waypedia and the publishers and advertisers using our services to provide data subjects with information about the processing of personal data. (“Personal data”, as used in the GDPR, means information relating to an identified or identifiable natural person, including name, address, cookie identifiers, mobile device identifiers, and more; “data subject” here means the person involved; and “processing” of data includes collection, storage, and use.) 

This section provides representations and information in compliance with our GDPR obligations, for the benefit of our users located in the EEA countries and Switzerland only.

 

6.1  Legal grounds for processing your personal data

The GDPR requires us to identify the legal ground we’re relying on to process personal data about you.  See our legal grounds for processing your personal data as described in this Privacy Policy below.

 

6.1.1  You provided your consent

To store and access information on your device, we rely on your consent.  For this “cookie consent” (which applies not only to “cookies” but also to mobile ad identifiers), to fulfill our obligations under the ePrivacy Directive, we rely on mobile app developers and oblige them contractually to pass on only legally obtained data. We may choose to obtain consent in other cases as well, in which case we will adhere to applicable laws relating to consent and its withdrawal.

6.1.2  The processing is in our legitimate interest

In some cases, we use legitimate interest as a legal basis for processing personal data to provide our and our commercial partners’ services. A legitimate interest we rely on, for instance, is the tailoring of offers and opportunities to obtain in-game rewards to users of mobile applications and services, which is beneficial to users and offers them a value exchange and goes beyond the original collection of mobile ad identifiers and also includes providing analysis of and reporting about ad campaigns. We also rely on legitimate interest when we use personal data to maintain the security of our services, including fraud detection and identifying and fixing bugs.

6.1.3  Contractual Relationships

Sometimes, we process personal data as necessary under a contractual relationship we have, such as our customer records and contact information).

6.1.4  Legal Obligations

Finally, some processing of data may be necessary for us to comply with our legal or regulatory obligations.

 

6.2  Transfers of personal data

We operate globally from our headquarters based in the United States with offices around the world, and work with other global companies and technologies. As a result, we may need to transfer your personal data outside of its country of origin. For instance, we may transfer your personal data to commercial partners or service providers located in jurisdictions outside the EEA and Switzerland, which have data protection laws less strict than those in Europe. 

When we transfer personal data outside of the EEA or Switzerland, we take steps to make sure that appropriate safeguards are in place to protect it; we use European standard contractual clauses and data processing agreements where required by European Data Protection Law, and are in the process of certifying to EU-U.S. and Swiss-U.S. Privacy Shield Frameworks.  Contact us at privacy@Waypedia.com for more information about the safeguards we use to protect your personal data and privacy rights.

 

6.3  Personal data retention

As a general matter, we retain your personal data for as long as necessary to provide our services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. We generally rotate through personal data used for ad personalization on a 90-day timetable, provided that we may retain data if we have a legal or significant operational need to do so, such as for auditing, corporate record-keeping, compliance, accounting or bug-fixes.    

 

If you are a Waypedia advertiser or publisher, we retain your information as long as your account is active and for as long as necessary for legal or operational purposes, such as auditing, corporate record-keeping, compliance, or accounting, after its closure.

 

6.4  Exercising your rights as a data subject

As a data subject covered by the GDPR, you have certain rights about the personal data that data controllers hold about you, including right of access, right to request correction, right to be forgotten (i.e., deletion), and right to object to processing (including profiling for online ad targeting). 

6.4.1  Right to Access

If you are a consumer and wish to exercise your right to access personal data we process as a data controller, you may do so by requesting access through the e-mail address gdpr-access@Waypedia.com and following the instructions we provide you to authenticate your request and obtain access. We will assess requests to exercise data access rights on a case-by-case basis, factoring in the difficulty of verifying whether a mobile device identifier, and the data we have linked to it, truly and solely belongs to the person making the request, as well as the potential risk of harm through disclosure of personal data to the wrong individual. Because improper disclosure would likely harm the privacy rights and freedoms of the person involved, we may limit the personal data we make available. We only grant requests where we are the data controller, as explained further, below. Where we act as a processor for one of our advertisers or publishers, we will refer your request to that company; if your request involves an advertiser or publisher, please identify them (if possible) to simplify this process.

If you have a Waypedia publisher or advertiser dashboard account, you may use your account settings to access and update or delete account information. You may also request access by emailing us at privacy@waypedia.com.

6.4.2  Right to Correct

If you wish to exercise your right to correct Personal Data, you may do so by contacting us at the contact information below.

6.4.3  Right to Object to Processing or to Withdraw Consent

By enabling device-based “opt-out” options in your device’s settings, you may withdraw consent for processing where we rely on consent. If you do so, we will cease processing your personal data for such purposes within 30 days. We collect these opt-out signals ourselves, and will also respect consent flags if passed by the publisher of the app you are using. To adjust your advertising preferences in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking. To adjust your advertising preferences in Android, visit Settings > Google > Ads > Opt out of interest-based ads. You can also request an opt-out specific to Waypedia by emailing us at optout@waypedia.com and following the directions we provide you.

6.4.4  Right to Erasure

You also have the right to request erasure of personal data that we hold as a controller. The above opt-out process satisfies this right, because when a user opts-out (whether through device settings or by submitting a request to gdpr-optout@Waypedia.com and following our instructions), we stop using your personal data to provide our services to you; the data is permanently rendered disconnected to your device and will be automatically deleted from our production system. We may retain copies of some personal data for our own internal and necessary purposes, such as auditing, accounting and billing, legal, bug-detection, backups, and (if applicable) to ensure that you receive and that we are able to track the rewards you have received.  

6.4.5  Right to Lodge Complaints. 

You have the right to lodge a complaint with a supervisory authority.vHowever, we hope that you will first consult with us, so that we may work with you to resolve any complaint or concern you might have.


6.5  Waypedia: a data controller and a data processor

EU data protection law makes a distinction between organisations that process personal data for their own purposes (known as “data controllers”) and organisations that process personal data on behalf of other organisations (known as “data processors”).  If you have a question or complaint about how your personal data is handled, we encourage you to direct your inquiry to the relevant data controller, since data controllers have primary responsibility for your personal data.

Waypedia may act as either a data controller or a data processor in handling your personal data, depending on the precise circumstances. For instance, for personal data that we use internally to create our data-related services, such as interest-based ad targeting, and for personal data that we collect about our publisher and advertiser customers for use in marketing to them, we are a data controller. But when we handle personal data strictly on behalf of our customers to provide our services to them (for example, if they provide us with a list of device identifiers to use for targeting or suppression), we are a data processor. If you have questions about data that is used primarily on behalf of one of our publishers or advertisers, you should contact them.

 

7.  Questions or Concerns

If you’re an Uento user please reach us at privacy@uento.com.
If you have any questions or concerns regarding our privacy policies, please send us a message to privacy@Waypedia.com.

 

Waypedia Privacy Policy - Last updated May 25, 2018