SAVOIR Privacy Policy

This privacy policy (“Privacy Policy”) governs how we, Wishupon, Inc. and its affiliates (“SAVOIR” “we”, “our” or “us”) use, collect and store information pertaining to you (“User”, “you”), such as in the following use cases:

We deeply value your privacy, which is why we strive to offer a platform that upholds the highest standards of user privacy. Please take the time to carefully read this Privacy Policy to gain a full understanding of our practices regarding Personal Data. “Personal Data” refers to any information that, either alone or combined with other data, can uniquely identify a living individual. It's important to note that this is our main privacy policy, and some of its provisions may only apply to individuals in specific jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals. This Privacy Policy is subject to periodic updates, and we encourage you to check back regularly for the latest version. If any significant changes are made to the use of your Personal Data, deviating from what was stated at the time of collection, we will notify you through postings on our Website or other means.

1. What information we collect, why we collect it, and how it is used

When you browse or visit our website(“Website”);
When you make use of, or interact with, our Website / application(s) / service(s), and the services provided thereunder (collectively referred to as the “Services”):

When you create an account and login
When you make use of our services as a registered user
When you contact us
When you subscribe to our newsletters

When you attend a marketing event and provide Personal Data
When we use the Personal Data of our service providers
When we use the Personal Data of our customers

When you create an account and make use of our services as a registered user

Data we collect	Apple ID / Email Full name Analytics events (how the product is being used)
Purpose of data collection	Creating an account To personalize the services Processing the order of the Service Performing/executing the Service
Legal basis (GDPR only)	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Third parties with whom we share your data	3rd party platforms such as for the following purposes: Hosting Vendors
Period of storage	Until you send a deletion request or we proactively decide to delete the data. Please note that under applicable laws, we may be required to retain the data for a longer or a shorter period.
Implications of not providing the data	Cannot create an account Cannot personalize the Service Cannot process the Service order and perform the agreement

When you browse or visit our website

Data we collect

Purpose of data collection

To provide our service and certain features of the product
To improve our product and quality of service

Legal basis (GDPR only)

Consent

When you contact us (e.g. customer support, help, submit a request)

Data we collect	Full name Email address Location Device type Version of the product being used OS version being used Any other information that you decide to provide/supply us
Purpose of data collection	To assist you To respond your query
Legal basis (GDPR only)	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Period of storage	Until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.
Implications of not providing the dataa	Cannot assist you and respond your query

2. How we protect and store your personal data

Security. We have implemented suitable technical, organizational, and security measures to minimize the risk of accidental data destruction or loss, as well as unauthorized access or disclosure, taking into account the nature of the information involved. However, please note that we cannot guarantee that information will remain secure in the event of unauthorized intrusion into our servers. As the security of your information partly relies on the security of the computer, device, or network you use to communicate with us, and the security measures you employ to safeguard your user IDs and passwords, we strongly advise you to take appropriate precautions to protect this information.

Retention of your Personal Data. In addition to the retention periods outlined in Section 1 above, there are circumstances where we may retain your Personal Data for extended periods. This could be necessary (i) to comply with legal, regulatory, tax, or accounting requirements, (ii) to maintain an accurate record of your interactions with us in case of complaints or disputes, or (iii) if there is a reasonable belief that litigation regarding your Personal Data or transactions may occur.

3. How we share your personal data

In addition to the recipients described in Section 1, we may share your information as follows:

We provide personal information to comply with all applicable laws, regulations, and rules, as well as requests from regulatory, law enforcement, and governmental agencies, or as required by court order.
Where you have consented to us sharing Personal Data, such as providing marketing consents or opting in to optional additional services or functionality.
When we receive requests for information from law enforcement or regulators, we carefully validate these requests before disclosing any Personal Data.
In the event of selling or transferring some or all of our business or assets to a third party in the future, we will disclose information to potential or actual third-party purchasers of our business or assets to the extent necessary. If we are acquired by or merged with a third-party entity, or in the event of bankruptcy or a similar event, we reserve the right to transfer or assign Personal Data in connection with these events.

4. Additional information regarding transfers of personal data

Internal transfers: Your Personal Data might be moved within the WISHUPON, INC. and SAVOIR, with us implementing adequate measures to guarantee consistent and sufficient protection for your data across all transfers.

External transfers: When we transfer your Personal Data outside of SAVOIR, such as to the third parties mentioned in Section 1 above, we ensure compliance with applicable laws and obtain contractual commitments from them to safeguard your Personal Data. For GDPR-protected individuals, it's important to note that certain assurances, like the EU-US Privacy Shield, are recognized certification schemes for protecting Personal Data transferred from the EU to the US. Additionally, Israel is acknowledged as a country providing an adequate level of data protection.

see here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

Before disclosing any Personal Data, we thoroughly validate requests for Personal Data received from law enforcement or regulatory authorities.

5. Your rights

The following rights (which may be subject to certain exemptions or derogations), shall apply to certain individuals (some of which only apply to individuals protected by the GDPR in certain circumstances):

You are entitled to access the information we hold about you. While typically free of charge, we reserve the right to levy an appropriate administrative fee where permitted by applicable law;
You have the right to request corrections to any inaccurate or misleading Personal Data we hold;
You can request the deletion of Personal Data relating to you. Please be aware that certain circumstances may require us to retain your data, such as for legal claims;
You may object to or request restrictions on the processing of your data. However, there may be situations where we are legally authorized to deny your request;
You have the right to data portability, enabling you to receive your Personal Data in a structured, commonly used, and machine-readable format, and to transmit it to another controller;
You can object to profiling activities;
You possess the right to lodge a complaint with your local data protection authority at any time. We encourage you to attempt resolution with us before contacting your local supervisory authority;
You can withdraw your consent. Note that there may be circumstances where we are obliged to continue processing your data to fulfill our legal and regulatory obligations;
Additionally, you have the right to request information about the basis on which your Personal Data is transferred outside the European Economic Area, understanding that data transfer agreements may be partially redacted for commercial confidentiality reasons.

You may assert your rights by reaching out to us at savoir@wsupon.com. We will endeavor to promptly address your request, subject to legal and other permissible considerations. If further information is needed to fulfill your request, we may request additional details to verify your identity and ensure security before disclosing the requested Personal Data. In accordance with applicable law, we reserve the right to impose a fee where permitted, particularly if your request is deemed manifestly unfounded or excessive. Should your request potentially impinge upon the rights and freedoms of others or require a different approach due to legal entitlements, we will strive to address it to the fullest extent possible, all within the bounds of applicable law.

6. Use of anonymous information

We might utilize Anonymous Information (as defined below) or share it with third-party service providers to enhance our Website and services, thus enriching your browsing experience. Additionally, we may disclose Anonymous Information (with or without compensation) to third parties, including advertisers and partners. "Anonymous Information" refers to data that does not permit the identification of individual users, such as aggregated information concerning the use of our Website.

7. How can I delete my account?

If you choose to delete your Account at any time, you can do so by sending an email to savoir@wsupon.com. Upon termination of your Account, any connection between your Account and the stored information will no longer be accessible. However, please note that any public activity on your Account before deletion will still be stored on our servers and accessible to the public.

8. Links to and interaction with third party product

The Product may allow you to engage with or include links to your Third Party Account and other third-party websites, mobile apps, and services not owned or managed by us (each, a "Third Party Service"). We are not liable for the privacy practices or content of such Third Party Services. Please note that Third Party Services may collect Personal Information from you. Therefore, we advise you to review the terms, conditions, and privacy policies of each Third Party Service you opt to use or interact with.

9. Contacts Information

SAVOIR requests access to contact lists solely to facilitate easier collaboration among users and their contacts. When a user selects a contact from their list, certain details may be transmitted to our servers to generate invitations for the selected contacts. These details may include email addresses and contact names.

10. Use by children

Our products and services are not intended for use by children. If you are under 18, you are not permitted to use the product or provide any information to it without the involvement of a parent or guardian. We do not knowingly collect information from or about children.

11. Log files

We may utilize log files. These log files contain data such as internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages, and any other data that your browser or mobile device may transmit to us. We may utilize this information to analyze trends, manage the Site, monitor users' activity on the Site, and collect demographic information.

12. Location Information

SAVOIR requests location permissions solely to offer location-based information (e.g., Weather, etc.). No location data is stored on our servers.

13. Cookies and other tracking technologies

Our website may employ "cookies," anonymous identifiers, and similar tracking technologies to enhance our service delivery and provide personalized information. A "cookie" is a small text file that may gather data about activity on the site. Some cookies and technologies may remember Personal Information, such as an IP address, previously provided by a user. Most web browsers offer controls for managing cookies, including options to accept, reject, or remove them. You can configure your browser to alert you when receiving a cookie or to block cookies altogether.

14. Use of External Analytics Tools

We utilize analytics tools (e.g. Google Analytics) to gather information about the usage of our Websites and Services. These tools collect data on user visit frequency, visited pages, and referral sources. The insights obtained from these tools are used to enhance and maintain our sites, services, and other offerings.

15. Third-Party Advertising

SAVOIR uses third-party advertising networks, including Google's AdMob, to serve advertisements. AdMob may collect advertising identifiers, IP address, device information, other data necessary for ad performance and user statistics analysis. The collected data is used for Ad personalization, Ad performance measurement, user statistics analysis.

We may share collected data with third parties such as AdMob. These third parties use the data to assist in providing our services and will not use or share it for other purposes.

Users can opt-out of ad personalization or limit data collection through the following methods:

Resetting the advertising identifier on your mobile device
Changing device settings to opt-out of ad personalization

For more information, please refer to Google’s Privacy Policy (https://policies.google.com/privacy?hl=en)

16. U.S. Privacy Provisions

California privacy rights. California Civil Code Section 1798.83 allows California residents, who are our customers, to inquire about the disclosure of their Personal Data to third parties for direct marketing purposes. If you are a California resident and wish to make such a request, please contact us at savoir@wsupon.com. Please be aware that we are only obligated to respond to one request per customer per year.

Our “California do not track” notice. We do not engage in tracking consumers' activities over time and across third-party websites, and as such, we do not acknowledge or respond to Do Not Track signals. Additionally, we do not permit third parties to gather personally identifiable information about individuals' online activities when they use the Website.

17. How to contact us

If you have any inquiries, concerns, or complaints regarding our adherence to this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to reach out to us initially at savoir@wsupon.com.

If you are an individual subject to the GDPR, you can read more about your rights here: https://ec.europa.eu/info/law/law-topic/data-protection_en

Updated - July 2024