Category of personal data

Description of personal data

Profile Data

We collect personal data about you when you register to access the services including:

- Complete Name

- Email address

- Login credentials (username, password etc.)

- Phone number

- Profile photo (optional)

- Online alias (optional)

- Vehicle and equipment details (optional)

- Billing and correspondence address (optional)

- Saved routes (optional)

- Date of birth (optional)

- Preferences and settings related to the account, such as language preferences, communication preferences and notification settings 

Identification / Verification Data

Identification documents including government-issued or national identity documents (such as passports, driver’s licenses or national ID cards) and photographs/pictures (such as a selfie) may be collected and processed by trusted third-party verification partners.

Payment Data

Details of your payment methods such as card type, bank name, bank account number and related payment verification information may be collected by our trusted third-party payment service providers to which this Privacy Policy does not, therefore apply. However, we may keep track of your transaction history.

Demographic Data

We collect demographic data such as your age and gender.

Survey, Interview and Testimonial Data

We collect the content of your replies or attachments you may send us, during the course of surveys and interviews that we conduct and for feedback on events which we may (subject to your consent) display on the WRWR Website and App.

Geolocation Data

We may collect data about your precise and/or approximate geolocation (including GPS, and IP address) from your mobile device in accordance with your device permissions, when you use the services. This may also include location history. Failure to permit processing of geolocation data may affect some features of the services and render you ineligible to participate in certain events.

Usage Data

We collect personal data via devices that you use for the services. This includes dates and times you log-in and log-off the services, app features or pages viewed, browser type, WRWR App crashes and other system activity.

Communication Data

We collect communication and correspondence data when you engage with customer support via the WRWR Website or WRWR App, report an incident, communicate via emails, web forms, or speak with our customer support agents. We record the date and time of the communications and their content. We will record calls, only when you are notified in advance that the call may be recorded such as before initiating communication with a customer support agent. As far as communication between users is concerned, this is stored but not automatically visible to or accessible by us.

User Generated Data

We collect personal data when you use certain features. For example, to provide recordings or to submit content like pictures, videos or files in connection with a customer support request. This also includes metadata relating to the method you use to communicate with the services.

Feedback and Ratings Data

We collect details of feedback provided to and by users. This includes both positive and negative feedback and the details thereof such as date, time, interaction event, source of feedback and follow-up action.

Device Data

We collect data about the devices you use to access the services, including the hardware model, device IP address and other unique device identifiers (such as your UUID and advertising identifiers), device operating system, browser version, device vendor name, app version, identity of carrier, manufacturer and preferred languages.

Cookies, Web Beacons, SDKs, HTTP Referrers, and Third-Party Technologies Data

We collect information through the use of cookies, web beacons, data analytics tools, SDKs, and other third-party technologies which includes IP address, location, age, gender, pages you view on the WRWR Website, duration of your visit, pages you view immediately before and after you access the WRWR Website, search terms you enter on the WRWR Website, and information about your browser type, language and operating system. 

Data from Social Media, Linked Apps/Platforms

We collect contact data about you: when you connect to the services via external applications and websites such as Instagram, Facebook, Twitter and calendar apps. This includes your:

- Full name

- Email address

- Phone number

Purpose of processing

Legal Basis(es)

Class(es) of Personal Data

To create, update and maintain your profile

Performance of a Contract

Profile Data

Device Data

To authenticate your account and verify your identity

We enable the collection of information through our third-party service providers to verify who you say you are and to verify your age and eligibility for using the services. If we ask you to verify your identity (either upon registration or in connection with your desire to avail certain services) and you are not able to verify, your account may be limited, and you may be rendered ineligible to partake in certain services such as physical events and meet ups to ensure the safety and security of our other users. As part of the verification process, you may be asked to prove your identity through one of our third-party verification partners.

Performance of a Contract

Compliance with Legal Obligations

Legitimate Interests

- It is in our interest and in the interest of our users to limit unverified users’ permission or label users as ‘verified’ or ‘unverified’ (or words of similar connotation) to ensure the comfort and safety of our general user base.

Consent

- Your opt-in consent will be required for biometric verification checks.

Profile Data

Identification / Verification Data

Demographic Data

Device Data

Geolocation Data

Usage Data

To allow for event registration and participation, to ensure optimal challenge and event experience and to assess eligibility for sponsorships

We use Profile Data and other associated data to enable users to register for and participate in events.

We use Geolocation Data to make sure that your planned routes are suitable for travel and to help you connect with users in your vicinity. This lets us improve recommendations to users about preferred routes and facilitate the enhancement of user experience such as in connection with rides and baton passes. We also collect Usage Data to resolve quality issues related to your use of the services.

Performance of a Contract

Legitimate Interests

- It is in our legitimate interests and in the interests of our users to offer you the most convenient routes and forewarn users of any potential dangers or hurdles on a planned route. Additionally, it is in the legitimate interest of us and our users to assess their eligibility for sponsorship especially in the case of high-ranking users, ambassadors etc.

Profile Data 

Geolocation Data

Usage Data

Feedback and Ratings Data

Device Data

To make sure the services work optimally

We use your Profile Data to notify you of updates to the services so you can keep using the services. We also use Device Data and Usage Data to ensure you can help keep your account safe through authentication and verification checks, if required.

Performance of a Contract

Consent

- Your opt-in consent is required for the use of Cookies, Web Beacons, SDKs, HTTP Referrers, and Third-Party Technologies Data.

Profile Data

Device Data

Usage Data

Identification / Verification data

Cookies, Web Beacons, SDKs, HTTP Referrers, and Third-Party Technologies Data

To maintain Leaderboards and data regarding challenges and baton passing

We use your personal data in order to maintain leaderboards whereby users are ranked based on their usage of the WRWR App and performance in challenges. Additionally, with respect to baton passing and other physical events we record and maintain imprecise Geolocation Data in order to map out worldwide impact of the WRWR user community.

Consent

- Your opt-in consent is required for the tracking and mapping of Geolocation Data and publication of your Profile Data on our leaderboards.

Legitimate Interest

- Challenges and events, particularly the baton passing events, are the cornerstone of WRWR’s mission and crucial to mapping out and recording WRWR’s user base for the purposes of growth and industry engagement.

Profile Data

Geolocation Data

Device Data

Usage Data

Data from Social Media, Linked Apps/Platforms

To suggest new rides and destinations and to notify regarding upcoming events and challenges

We use your previous journey history, your saved favorite locations and real-time Geolocation Data (even when the WRWR App is closed, provided you have consented to enable location services in the background) to provide suggestions on new rides and notify you of any challenges or events that may be of interest to you. You can always disable these specific notifications, without disabling all WRWR App notifications.

We may provide an integration with your calendar app, allowing you to add your scheduled challenge, meet up or other event to your calendar of choice. However, please note that once such information is provided to your calendar app, it is the privacy policy of such service provider that shall govern the processing of your personal data.

Consent

- Your opt-in consent is required to use access Geolocation Data and to allow access to your calendar.

Legitimate Interests

- It is in our legitimate interests and in the interests of our users to enhance experience by, among other things, notifying users of upcoming events and challenges.

Profile Data

Usage Data

Geolocation Data

Data from Social Media, Linked Apps/Platforms

To get your feedback and testimonials in connection with the services

We may reach out to you via questionnaires and email to gather your input regarding your experience with the services. We may also display such feedback on various areas on our platform or use the same for business and marketing purposes.

Consent

- Your opt-in consent will be required for receipt of in-app, email or other communications and for the publication of your responses.

Legitimate Interests

- It is in our interest and in the interest of our users for feedback on the services to be given to allow us to address user concerns, as well as to provide better opportunities and experiences to our users by attracting a wider user base and garnering industry support. 

Feedback and Ratings Data 

Survey, Interview and Testimonial Data 

Profile Data

Geolocation Data

Demographic Data

To integrate the services with users’ social media and other third-party platforms

We may enable users to integrate their social media and other third-party accounts or profiles with the services in order to provide an optimized ecosystem. 

Consent

- Your opt-in consent will be required for integration of third-party and social media profiles and accounts.

Legitimate Interests

- It is in the legitimate interest of our users to enable wider outreach of WRWR activities and provide easy and seamless access to the services via third-party/social media accounts and profiles to our users.

Data from Social Media, Linked Apps/Platforms

Profile Data

Geolocation Data

Purpose of processing

Legal Basis(es)

Class(es) of Personal Data

To provide customer support services and receive and process feedback

We process your personal data to investigate and address your queries including reported safety incidents, criminal complaints and issues with information provided via the platform. We also use the data you share to address quality issues and to improve our services.

Performance of a Contract

Legitimate Interests

- It is in our interest and in the interest of our users to support them throughout their use of the services and continuously improve and develop the customer support we provide. In addition, it is in our interest and the interest of our users to address threats, harassment or abuse and promote safety, integrity and security on the WRWR platform and in the use of the services.

Compliance with Legal Obligations

- We process personal data to comply with our legal obligation to cooperate with law enforcement.

Profile Data

Communication Data

User Generated Data

Feedback and Rating Data

Device Data

Purpose of processing

Legal Basis(es)

Class(es) of Personal Data

To enable and provide safety features

We may use data to ensure the services are secure and have implemented a variety of safety features to enhance the safety of our users, for example:

Emergency Assistance Features

- enabling you to call the Police, the local authorities or emergency services, or for issuance of distress calls to relevant authorities on your behalf via in-app features.

Legitimate Interests

- It is in our interest and in the interests of our users to enhance the safety and security of the services by offering safety functionalities as part of the services

Vital Interests

- We process this personal data where your vital interests require protection, such as in the case of emergencies and safety incidents.

Identification / Verification Data

Device Data

Geolocation Data

Profile Data

Usage Data

User Generated Data

To prevent, detect and investigate fraudulent accounts, fraudulent payments or other unlawful use of the services and apply suspensions and blocks as needed

We may use personal data to investigate any potential fraudulent accounts, payments and other malicious activity on the WRWR platform such as impersonation. To enable us to investigate, a temporary suspension may be applied to a user profile.

Legitimate Interests

- It is in our interest and in the interests of our users to detect, prevent and address fraud, unauthorized use of services or other harmful or illegal activity and maintain the safety and security of our systems, by responding to suspected or actual criminal acts. 

Profile Data

Identification / Verification Data

Device Data

Geolocation Data

Usage Data

Payment Data

Communication Data

Purpose of Processing

Legal Basis

Categories of Personal Data

To market and advertise the services according to your preferences and measure the effectiveness of WRWR’s ads.

This includes using your personal data to send and personalize emails, text messages (including WhatsApp messages), push notifications, in-app messages, and other communications marketing the services, features, offers, promotions and events. We may also use the platform to advertise products and deals provided to us by, inter alia, sponsors, industry partners etc. according to your preferences obtained from your Profile, Usage and Cookies, Web Beacons, SDKs, HTTP Referrers, and Third-Party Technologies Data

Consent

- Your opt-in consent will be required for marketing and advertising and for certain tracking technologies.

Legitimate Interests

- It is in our interest and in the interest of our users to inform them about services and products that may be available to them due to their status as WRWR users. It is also in our interest to promote and advertise our services, including engaging in contextual (non-data driven) and personalized direct marketing and advertising, analytics, and measurement of ad performance, in order to expand our user base by deepening relationships with existing users and expanding our user base. 

Profile Data

Usage Data

Device Data

Payment card type

Cookies, Web Beacons, SDKs, HTTP Referrers, and Third-Party Technologies Data

Purpose of Processing

Legal Basis

Categories of Personal Data

To communicate with you, including sending you service-related communications and to keep you informed

Your name, phone number, email address and third-party platform data will be used to communicate with you to inform you of the conclusion of your ride, event or challenge, and to let you know about important service updates.

Performance of a Contract

Legitimate Interest

- Activities such as events, rides and challenges tend to involve several users simultaneously and may require coordinated movement among users. It is, therefore, in the interest of our users that real-time communication be conducted to inform users of the status of their respective events to foster safety and coordination.

Profile Data

Geolocation Data 

Data from Social Media, Linked Apps/Platforms

Purpose of Processing

Legal Basis

Categories of Personal Data

To perform research, testing, and analytics to better understand and improve our business and services

For example, we use Geolocation Data and Usage Data to perform research and improve our algorithms and other modelling. We use Communication Data related to incidents to monitor our security practices and improve our operations and processes.

Legitimate Interests

- It is in our interest to measure the use of our services in order to inform business decisions, enable provision of accurate and reliable reporting and to continuously improve the services we provide.

Consent

- For certain analytics we may require your consent. If so, you'll be prompted to provide consent for specific purposes and processing activities, with details on how to withdraw consent, including through your profile settings.

Geolocation Data

Usage Data

Communication Data

User Generated Content

Device Data

Survey, Interview and Testimonial Data

To develop new products, features, partnerships and services

Legitimate Interests

- It is in our interest and in the interest of our users that WRWR develop and adopt new features, engage new partners, sponsors and collaborators to improve the services and expand the WRWR Platform.

Profile Data

Geolocation Data

Usage Data

Communication Data

User Generated Content

Device Data

To prevent, find, and resolve software or hardware bugs and issues

Legitimate Interests

- It is in our interest and in the interest of our users to provide a hassle-free and reliable service.

Profile Data

Geolocation Data

User Generated Content

Communication Data

Device Data

Usage Data

Purpose of Processing

Legal Basis

Categories of Personal Data

To investigate and respond to claims and disputes relating to the services, and/or necessary for compliance with applicable legal requirements or with requests from government/law enforcement bodies

Depending on the claim, All Data may be processed for establishing, exercising or defending legal claims, including:

- supporting our own internal investigations;

- the assignment of claims and the use of debt collecting agencies; and

- the use of legal advisors.

In some circumstances, we are legally obliged to share information with external recipients. For example, under a court order or where we cooperate with a data protection supervisory authority in handling complaints or investigations. We will take steps to ensure that we have a lawful basis on which to share the information, and we’ll make sure that we document our decision.

Compliance with Legal Obligations

- We process personal data to comply with an obligation, when there is a request from a court, regulator, law enforcement authority or other governmental body of competent jurisdiction.

Legitimate Interests

- In the context of litigation or other disputes, including as part of investigations or regulatory inquiries, it is in our interest to protect our rights and those of our users.

All Data

To fulfil our tax obligations and comply with tax legislation

Compliance with a Legal Obligation

Profile Data

Payment Data

Usage Data

Geolocation data

To reorganize or make changes to our business

Legitimate Interests

- It is in our interest to process personal data for organizational and business planning purposes.

All Data

To ensure the security of the services 

Depending on the issue, All Data may be used for technical and cybersecurity reasons: for example, measures for combating piracy and ensuring the security of the services as well as for making and storing backup copies and preventing/repairing technical issues.

Legitimate Interests

- It is in our interest and in the interest of our users to protect, guard and maintain our security systems, respond to suspected or actual criminal acts and repair any technical issues.

All Data

Retention Periods Criteria

Description

Personal data retained until you remove/delete it

It is your right to request that we delete certain elements of your personal data. This right, along with other rights, is provided in further detail below.

Personal data that expires after a specific period of time

We have set certain retention periods so that some data is not retained after a specific period of time. See table below for further details. After a retention period has lapsed, the personal data is securely deleted, unless it is necessary for the establishment, exercise or defense of legal claims.

Personal data retained until your account/profile is deleted

We keep your data until your account/profile is deleted unless further retention of certain personal data is required for the purposes described in the table below.

Category of Retention Periods

Description

Tax, accounting and financial reporting purposes

We retain data for 10 (ten) years after the last journey if your personal data is necessary for tax, accounting and financial reporting purposes.

Provision of services purposes

We retain your data as long as you have an active user account/profile. If your account is closed, personal data will be deleted (according to our retention schedule and rules), unless such data is still required to meet any legal obligation, or for accounting, dispute resolution or fraud prevention purposes. You may request deletion of your account at any time by contacting info@wrwrapp.com.

Formal investigations of a criminal offence, fraud or false information

We retain data for as long as necessary according to the internal, legal, and regulatory requirements, in the event that there are formal investigations of a criminal offence, fraud or false information having been provided.

Disputes

We retain data in the event of disputes, until the claim is satisfied or the expiry date of such claims.

Complaints

We retain a record of all complaints which we make available to an authorized officer of the licensing authority on request in the case of an investigation for 12 (twelve) months.

Instant Messages

We retain data about instant messages between you and customer support directly in the WRWR App for 90 (ninety) days, except in cases where messages are related to a reported incident or in the event, they are related to a dispute, in which cases we will store them for 6 (six) months. 

Customer Support

We retain data in relation to support tickets, phone calls and chats for 3 (three) years.