Privacy Policy

Updated on August 21, 2024

This Privacy Policy explains how and why Cognity Life India Private Limited (doing business as “WisdomCircle”) collects, uses, and shares personal information when you interact with or use our Site or Service. It also includes any information Cognity Life India Private Limited (WisdomCircle) collects offline in connection with the Service, which we may combine with information from the Site and Service. When we say “WisdomCircle”, we mean Cognity Life India Pvt. Ltd., and any of its affiliates. When we say “Site”, we mean https://wisdomcircle.com/ and https://app.wisdomcircle.com/ and when we say “Service”, we mean the Site plus any websites, features, applications, widgets, or online services owned or controlled by Cognity Life India Private Limited. As part of the Service, Cognity Life India Private Limited provides a marketplace which results in platform collecting information pertaining to different parties to facilitate an interaction. Users of the Service may be WisGen or Recruiters (as each is defined in the Terms of Service). This Privacy Policy applies to Cognity Life India Private Limited’s processing of personal information of Users where Cognity Life India Private Limited determines the purposes and means of processing. It does not apply to processing of information by Users themselves, who may be controllers of the personal information they access through the Service. This Privacy Policy is incorporated into and is to be read as part of the Terms of Service – https://wisdomcircle.com/terms-of-service/.

1. INFORMATION COLLECTION

a. Information You Provide to Us

When you use the Service, you may provide us with information about you. This may include your name and contact information, financial information to make or receive payment for services obtained through the WisdomCircle platform, or information to help us fill out tax forms. When you use the Service, we may also collect information related to your use of the Service and aggregate this with information about other users. This helps us improve our Services for you. You may also provide us with information about your contacts or friends if, for example, you’d like to share or refer them to a role posted on WisdomCircle. Depending upon our relationship with you, we may collect the following categories and types of personal information from and about you :
Categories of Personal Information We Collect Examples of Personal Information Collected Categories of Sources of Personal Information Business Purpose for Collection of Personal Information
Identifiers
Name, Date of Birth, Social Media Account Information, Profile Data, IP Address
Directly from You or Your use of the Service; Cookies and Other Tracking Technologies; Third Parties (such as affiliates, agents, service providers and other users)
Developing, Improving, and Providing the Service, Identification, Communications, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations.
Contact / Account Profile Information
Email Address, Phone Number
Directly from You or Your use of the Service; Third Parties (such as affiliates, agents, service providers and other users)
Developing, Improving, and Providing the Service, Identification, Communicating with You, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations.
Commercial Information
Transaction Data including services offered, considered, or purchased
Directly from You or Your use of the Service; Third Parties (such as affiliates, agents, service providers and other users)
Developing, Improving, and Providing the Service, Identification, Communications, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations.
Internet or Other Network or Device Activities Including Information from Cookies
Unique device and app identifiers, browsing history or other usage data, the browser and operating system you are using, the URL or advertisement that referred you to the Service, the search terms you entered into a search engine that led you to the Service, areas within the Service that you visited, which links you clicked on, which pages or content you viewed and for how long, other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages and other information commonly shared when browsers communicate with websites
Directly from You or Your use of the Service; Cookies and Other Tracking Technologies; Third Parties (such as affiliates, agents, service providers and other users)
Developing, Improving, and Providing the Service, Identification, Communications, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations.
Approximate Geolocation Information
Your approximate location
Directly from You or Your use of the Service; Cookies and Other Tracking Technologies; Third Parties (such as affiliates, agents, service providers and other users)
Developing, Improving, and Providing the Service, Identification, Communications, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations.
Sensory Information
Audio recordings if you call our customer service, video recordings of video introductions
Directly from You or Your use of the Service; Service Providers; Third Parties (such as affiliates)
Providing and Improving the Service, Identification, Communications, Marketing, Security, Legal, Compliance and Regulatory Obligations.
Platform Communications
Communication Information (e.g., your name, contact information, and the contents of any messages you send)
Directly from You, Your use of the Service, and Users with whom you communicate
Providing the Service, Security, Legal, Compliance and Regulatory Obligations. With your consent, the contents of any messages you send may be used to Develop and Improve the Service.
Professional Information
Previous place(s) of employment, position(s), work history, earnings, resume
Directly from You or Your use of the Service; Service Providers; Third Parties (such as other users)
Developing, Improving, and Providing the Service, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations.
Other information that identifies or can be reasonably associated with you
User-generated content, (e.g., community posts, feedback, ratings and job postings), photographs, examples of your work, information on work previously performed via the Service and outside the Service, skills, tests taken, test scores, hourly pay rates and earnings information.
Directly from You or Your use of the Service; Service Providers; Third Parties (such as affiliates, agents, and other users)
Developing, Improving, and Providing the Service, Identification, Communications, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations.

b. Non-Identifying Information and De-Identified Information

  • Non-Identifying Information/Usernames: We also may collect other information that does not identify you directly, such as zip codes, demographic data, information about your use of the Service, and general project-related data (“Non-Identifying Information”). We may combine information collected from WisdomCircle users, whether they are registered or not (“WisdomCircle Users”). In some cases, we may render Personal Information (generally, email address) into a form of Non-Identifying Information referred to in this Privacy Policy as “Hashed Information.” This is typically accomplished using a mathematical process (commonly known as a hash function) to convert information into a code. While the code does not identify you directly, it may be used by WisdomCircle’s partners to connect your activity and interests.
  • Combination of Personal and Non-Identifying Information: We may combine your Personal Information with Non-Identifying Information, but WisdomCircle will treat the combined information as Personal Information.
  • De-Identified Information: We may also de-identify or aggregate information and convert it into non-personal information so that it can no longer reasonably be used to identify you (“De-Identified Information”). We may use De-Identified Information for any of the purposes described in the “We Use Information We Collect” section below. We will maintain and use De-Identified Information in de-identified form and will not attempt to reidentify the information, except to confirm our de-identification processes or unless required by law.

c. Information Collected Automatically

WisdomCircle may collect non-personally identifiable information regarding your usage of the Services, including the pages and articles and presentations you viewed, time spent using certain features of the website, demographic data such as server locations, connection speed, and other information that does not identify you. Like most online services, we also use cookies, log files, clear GIFs, tracking pixels, web beacons, and other technologies that may collect Personal Data.
Type of cookie Purpose

Essential (Necessary Cookies)

These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and help the content of the pages you request to load quickly. Without these cookies, the Services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality (Necessary Cookies)
These cookies allow our Site to remember choices you make when you use our Site, such as remembering your login details and remembering the changes you make to other parts of our Site which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.
Analytics and Performance (Analytics Cookies)
These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not "directly" identify any individual visitor. However, it may render such visitors "indirectly identifiable". This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site. We use a number of different tools including Google Analytics, Sentry, and FullStory for this purpose.
Targeted and advertising (Marketing Cookies)
These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites. Third party advertisers may also use other technologies in addition to cookies placed on the Site (such as JavaScript, or web beacons) to measure the effectiveness of their advertisements and to personalize the advertising content.
Social Media (Marketing Cookies)
These cookies are used when you share information using a social media sharing button or "like" button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google. The social network will record that you have done this. These cookies may also include certain code that has been placed on the Site to help track conversions from ads, optimize ads based on collected data, build targeted audiences for future ads, and remarket to qualified leads—users who have already taken certain action on the Site.

How can I disable cookies?

You can typically reset your web browser to refuse all cookies or to notify you when a cookie is being sent. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our Services and some features of the Service may not function properly. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Services.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.

Log Files:

Log file information is automatically reported by your browser each time you access a web page. When you use the Services, our servers automatically record certain information your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information.

Clear GIFs Information (Web Beacons):

When you use the Services, we may employ clear GIFs (also known as web beacons or tracking pixels) to anonymously track online usage patterns. No Personally Identifiable Information from your WisdomCircle account is collected using these clear GIFs. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by recipients. The information collected is used to enable more accurate reporting and make WisdomCircle better for our users.

Third Party Services:

 WisdomCircle may use third-party services such as Google Analytics to help understand use of the Services. These services typically collect the information sent by your browser as part of a web page request, including cookies and your IP address. They receive this information and their use of it is governed by their respective privacy policies. You can also prevent the use of Google Analytics relating to your use of our Services by downloading and installing the browser plugin available via this link: [http://tools.google.com/dlpage/gaoptout?hl=en-GB.](http://tools.google.com/dlpage/gaoptout?hl=en-GB)

d. Analytics Providers, Ad Servers and Similar Third Parties

We receive information from third party vendors and/or other commercially and/or publicly available sources, such as:
  • Third party vendors who provide us data to supplement the information we collect about you, in accordance with applicable laws. For example, advertising and marketing partners in order to manage and measure our campaigns.
  • If you link, connect, or login to your account with a third-party service (e.g. Google, Facebook, LinkedIn), we receive certain information, such as your registration and profile information from that service. This information includes, for example, your email address, name and profile picture, but may vary and is controlled by that service or as authorized by you via your privacy settings at that service.
  • If any other third party submits a report and/or complaint about you or your activity on WisdomCircle we may receive information relating to the specific report and/or complaint, review and address it.
  • If you choose to refer or share links with your contacts, we will have the ability to view details of contacts.
  • If you integrate into your account information from third parties or otherwise integrate your account with third party systems, tools or products, we will receive certain information about you according to your permissions at such third parties.
  • We also receive certain information about you, if you are referred to WisdomCircle by another user (for example, as part of our referral program), in such case we will receive limited information, such as your email address or other contact information, and we will use it for the same purpose it was provided and in accordance with this Policy.
We combine your personal information with information we collect automatically or obtain from other companies and use it for the purposes detailed in this Policy.

e. Do Not Track

Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. Currently, we do not respond to web browsers’ “do not track” signals that provide a method to opt out of the collection of information about users’ activities on the Services and on other websites. If we do so in the future, we will provide relevant information in this Privacy & Cookies Policy.

f. Children

The Service is general audience and intended for users 18 and older. We do not knowingly collect Personal Information from anyone younger than age 18. If we become aware that a child younger than 18 has provided us with Personal Information, we will make reasonable efforts to delete such information from our files. If you are the parent or legal guardian of a child younger than age 18 and believe that WisdomCircle has collected Personal Information from your child, by contact us as outlined in the “Contact Us” section below.

2. USE OF INFORMATION

We Use Information We Collect:

  • To develop, provide, and improve the Service, complete your transactions, address your inquiries, process your registration, verify the information you provide is valid, and for compliance and internal business purposes.
  • To tailor content we display to you and offers we may present to you, both on the Service and elsewhere online.
  • To administer and develop our business relationship with you and, if applicable, the corporation or other legal entity you represent.
  • To enforce and comply with the law, including to conduct an investigation, to protect the property and rights of WisdomCircle or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, fraudulent, unethical or legally actionable activity. We may also use Device Identifiers to identify WisdomCircle Users.
  • For the purposes disclosed at the time you provide your information, with your consent, and as further described in this Privacy Policy.
  • To Honor Our Contractual Commitments to You. Much of our processing of Personal Information is to meet our contractual obligations to our investors, or to take steps at Users’ request in anticipation of entering into a contract with them.
  • For Our Legitimate Interests. In many cases, we handle Personal Information on the grounds that it furthers our legitimate interests in commercial activities, such as the following, in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
    • Providing our Site and Service.
    • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.
    • Measuring interest and engagement in our Services.
    • Short-term, transient use, such as contextual customization of ads.
    • Improving, upgrading or enhancing our Services.
    • Developing new products and services.
    • Ensuring internal quality control and safety.
    • Authenticating and verifying individual identities.
    • Debugging to identify and repair errors with our Services.
    • Auditing relating to interactions, transactions and other compliance activities.
    • Enforcing our agreements and policies.
    • Analyzing and improving our business.
    • Communications, including marketing and responding to your inquiries about our services.
    • Addressing information security needs and protecting our Users, WisdomCircle, and others.
    • Managing legal issues.
  • To Comply with Legal Obligations. We need to use and disclose Personal Information in certain ways to comply with our legal obligations.
  • To contact you with administrative communications and WisdomCircle newsletters, marketing or promotional materials (on behalf of WisdomCircle or third parties) and other information that may be of interest to you.
    • We use your personal information to send you direct marketing communications about our products, services or promotions from WisdomCircle that may be of interest to you or our related services. This may be via email, SMS, WhatsApp message, telephone or targeted online advertisements.
    • Our processing of your personal information for marketing purposes is based on our legitimate interest, on your consent, or on other legal basis permitted by applicable laws. You have a right to prevent direct marketing of any form at any time – this can be exercised by following the opt-out link attached to each communication or by sending an email to our Grievance Officer.
    • We take steps to limit direct marketing to a reasonable and proportionate level, and to send you communications which we believe may be of interest or relevance to you, based on the information we have about you.
  • This Site is also protected by reCAPTCHA. Google Privacy Policy and Terms of Service apply with respect to data collected by reCAPTCHA. The use of Google reCAPTCHA is required in order to prevent fraud and misuse of the Site by use of automated machines. To learn more, please see Google’s privacy policy.

3. DATA RETENTION

Unless you request that we delete certain information, we will only retain your personal information for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements, as well as ongoing fraud prevention, backup, and business continuity purposes.

4. INFORMATION SHARING AND DISCLOSURE

  • With other users and Site visitors. Once you register, your username, country, and additional information regarding your activity is made public and is visible to all users of the Site. This information includes but is not limited to photos you upload, your profile, and additional information you may choose to add to your profile. We also offer you the opportunity to participate and post content publicly in forums, blogs and on other similar features. Please be aware that certain information, such as your user name and profile, together with the content uploaded by you, will be publicly displayed when you use such features. Your information will also be shared with other users when you message or otherwise communicate with them. When you publish your information and/or share your data with other WisdomCircle users, you do so at your own risk.
  • With users with whom you interact. We share personal information to help facilitate interactions between users. For example, if you are a WisGen we may share certain information about you with the Recruiter to ensure the services they receive from the WisGen will fit their needs; such sharing of information is limited in scope, and is intended to improve the services provided and your user experience.
  • With Service Providers. We share personal information for business purposes with service providers that provide us with services for the purpose of operating the Site, opening and operating your account as well as providing ancillary services and solutions. These include, among others, hosting services, billing and payment processors and vendors, fraud detection and prevention services, CRM systems, forum hosting, community management services, data and cybersecurity services, web analytics and performance tools, translation tools, IT SaaS services, session recording, communication systems, mailing systems, data optimization and marketing services, data enrichment services, legal and financial advisors and technical consultants. Consistent with applicable legal requirements, we take appropriate technical and organizational measures to require third parties to adequately safeguard personal information and only process it in accordance with our instructions.
  • When you submit a report or complaint about a user. We may share personal information about you when you submit reports or complaints about other users to allow them to protect their rights or as required by applicable laws.
  • For legal reasons. We share personal information with law enforcement agencies, public authorities or other parties in order to respond to a subpoena or court order, judicial process or to regulatory authorities, if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes; when we believe it necessary or appropriate to disclose personal information to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Policy; to respond to claims against us; and to protect the rights, property, or personal safety of Fiverr, our customers, or the public.
  • For payments and fraud detection. We share personal information with payment processors, fraud detection agencies and similar third parties for the purpose of facilitating payments done via the Site, securing the Site and protecting it against fraud, unauthorized transactions (such as money laundering), claims or other liabilities.
  • With social media partners. Our Site includes certain social media features, including single sign on features. We also share limited personal information with such social media platforms and marketing partners, such as Facebook and Google, to promote our services. Such features and third party services collect certain information about you and may set a cookie to enable their functionality. Such third parties’ features are governed by their policies.
  • With our corporate affiliates. We share personal information with WisdomCircle’s corporate affiliates for business and operational purposes, including for the purpose of operating our and our affiliates’ business, providing supplemental services to you, preventing fraud and maintaining safe and secure services, promoting our and our affiliates’ services and for other purposes listed herein; and
  • In the context of a corporate transaction. Personal information will also be disclosed if we go through a business transition such as a merger, sale, transfer of all or a portion of WisdomCircle’s assets, acquisition, bankruptcy or similar event. In the event that we sell any business or assets, we will disclose your data to the prospective buyer. If we or substantially all of our assets are acquired by a third party, information held by us about our users will be one of the transferred assets.
  • We do not sell your Personal Information for monetary consideration, and we do not share your Personal Information with third parties for those third parties’ marketing purposes.

5. YOUR CHOICES AND RIGHTS

You may have certain choices and rights associated with your personal information. Residents of certain locations may have the right to have an authorized agent submit requests on your behalf. You or your authorized agent may request that WisdomCircle honor these rights by contacting us as outlined in the “Contact Us” section below. Non-Discrimination: You will not receive any discriminatory treatment by us for the exercise of your privacy rights. Verifying Your Request: Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. In the case of access and deletion, your request must be verifiable before we can fulfill such request. Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or a person authorized to act on your behalf. We will only use the personal information that you have provided in a verifiable request in order to verify your request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority. Please note that we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive or manifestly unfounded. You may withdraw your consent given for collection and use of your Personal Information by contacting us as outlined in the “Contact Us” section below. Once you withdraw your consent, you will lose access to all WisdomCircle Platforms. To remove your data or your account from our database, please contact us as outlined in the “Contact Us” section below.

Marketing Communications Preferences

You can ask us to stop sending you marketing messages or modify your email preferences at any time through any of the following methods:
  • by following the opt-out links on any marketing message sent to you; or
  • through your account settings
  • by contacting us at any time using the information in the “Contact Us” section below.
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of emails.

For Individuals Located in the European Economic Area (EEA), United Kingdom (UK) or Switzerland:

You have a number of rights under applicable data protection laws in relation to your personal information. Under certain circumstances, you have the right to:
  • Have access to your personal information by submitting a request to us;
  • Have your personal information deleted;
  • Have your personal information corrected if it is wrong;
  • Have the processing of your personal information restricted;
  • Object to further processing of your personal information, including to object to marketing from us;
  • Make a data portability request;
  • Withdraw any consent you have provided to us;
  • Restrict any automatic processing of your personal information; and
  • Complain to the appropriate Supervisory Authority.
To exercise any of these rights, please contact us as outlined in the “Contact Us” section below.

Notice for California Residents

“Shine the Light” and “Eraser” Laws: Residents of the State of California may request a list of all third parties to which we have disclosed certain information during the preceding year for those third parties’ direct marketing purposes. California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA): The CCPA, as amended by the CPRA, provides California residents and/or their authorized agents with specific rights regarding the collection and processing of their personal information. Your Right to Know: California residents have the right to request that we disclose the following information to you about our collection and use of your personal information over the past twelve (12) months. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Upon verification, we will disclose to you:
  1. The categories of personal information we have collected about you.
  2. The categories of sources for the personal information we have collected about you.
  3. The specific pieces of personal information we have collected about you.
  4. Our business or commercial purpose for collecting or “selling” your personal information as defined by the CCPA.
  5. The categories of third parties to whom we have sold or shared your personal information, if any, and the categories of personal information that we have shared with each third-party recipient.
Your Right to Opt-Out of “Sale” or “Sharing” of Personal Information: California residents have the right to opt-out of the “sale” or “sharing” of their personal information as defined by the CCPA by contacting us using the information in the “Contact Us” section below. Please note that we do not knowingly “sell” the personal information of any individuals under the age of 18. Where we are “sharing” your personal information with third parties for the purposes of cross-context behavioral advertising or profiling, you may opt-out of such sharing at any time by submitting a request as directed on the homepage of our website or by contacting us using the information in the “Contact Us” section below. Your Right to Limit Use of Sensitive Personal Information: California residents may have the right to request that businesses limit the use of any sensitive personal information to those uses which are necessary to perform the Services or for other specifically-enumerated business purposes under the CCPA, as amended by the CPRA. Please note that we do not use sensitive personal information other than as necessary to perform the Services or as specifically permitted under the CCPA. Your Right to Delete: California residents have the right to request that we delete any of the personal information collected from you and retained by us, subject to certain exceptions. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Once your request is verified and we have determined that we are required to delete the requested personal information in accordance with the CCPA, we will delete, and direct our service providers to delete your personal information from their records. Your request to delete personal information that we have collected may be denied if we conclude it is necessary for us to retain such personal information under one or more of the exceptions listed in the CCPA. Your Right to Correct: Under the CCPA, as amended by the CPRA, California residents have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes for which we are processing such personal information. We will use commercially reasonable efforts to correct such inaccurate personal information about you. Non-Discrimination: You will not receive any discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA.

Notice for Nevada Residents

Under Nevada law, certain Nevada residents may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, email address, phone number, or an identifier that allows a specific person to be contacted either physically or online. We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting us using the information in the “Contact Us” section below. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

Notice for Residents of Certain Other States

The laws of your state of residence (“Applicable State Law”) may provide you with certain rights, including the following: Your Right to Confirm and Access: You have the right to confirm whether we are processing personal information about you and access the personal information we process about you. Your Right to Portability: You have to right to obtain a copy of the personal information we maintain and process about you in a portable and, to the extent technically feasible, readily-usable format. Your Right to Delete: You have the right to request that we delete the personal information we maintain or process about you. Your Right to Correct: You have the right to request that we correct inaccuracies in the personal information we maintain or process about you, taking into consideration the nature and purpose of such processing. Your Rights to Opt-Out: You have the right to opt-out of certain types of processing of personal information, including:
  • Opt-Out of the “sale” of personal information as defined by Applicable State Law;
  • Opt-Out of targeted advertising by us;
  • Opt-Out of automated profiling for the purposes of making decisions that produce legal or similarly significant effects.
Please note, as explained above, we do not “sell” personal information as that word is traditionally defined. However, we do share personal information with third parties to provide you with personalized advertising from us and to better understand how you interact with our Services. Through the use of cookies, we may also make available certain personal information to third parties for targeted advertising. You may opt-out from any of these disclosures under Applicable State Law by contacting us using the information in the “Contact Us” section below.

Appeals Process & Other Concerns

Certain information may be exempt from the rights described above under applicable law. If we deny your request in whole or in part, you may have the right to appeal the decision. In such circumstances, we will provide you with information regarding the appeals process.

6. SECURITY

WisdomCircle takes reasonable steps to help protect and secure the information it collects and stores about WisdomCircle Users. We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information that we receive against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or use.

7. CROSS-BORDER DATA TRANSFERS

Some of the personal information you provide to us will be stored or processed on our behalf by third party suppliers and data processors and may be located in other jurisdictions, such as the United States and Israel, whose laws may differ from the jurisdiction in which you live. Whether to third parties or internally, there are also transfers of personal information from the European Economic Area (“EEA”) to countries outside of the EEA not deemed to provide an adequate level of data protection from a European data protection perspective, such as the United States. With regard to data transfers to such recipients outside of the EEA we provide appropriate safeguards, in particular, by way of entering into European Union (EU) standard contractual clauses as amended from time to time, and/or equivalent data transfer safeguards. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy.

8. LINKS TO OTHER SITES

Our Service contains links to other websites. If you choose to click on a third-party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We encourage you to read the privacy policies or statements of the other websites you visit.

9. CHANGES TO THIS POLICY

This Privacy Policy is effective as of the date stated at the top of this page. WisdomCircle may update this Privacy Policy at any time and any changes will be effective upon posting. We reserve the right to modify, alter, amend, change or update this Privacy Policy at any time without (i) any prior notice; (ii) assigning any reason, or (iii) assuming any liability whatsoever. We have no obligation to individually intimate each user or visitor about any changes or amendments made to this Privacy Policy. We recommend that you check the Policy periodically for any updates or changes.

10. CONTACT US

If you have any concerns or questions about this Privacy Policy, any complaint, or information on potential breach or violation of this Privacy Policy, this can be taken up with the designated Grievance Officer mentioned below.

Grievance Officer:

Joanna Sundharam: joanna.sundharam@wisdomcircle.com

We request you to provide the following information in your complaint:

  • clear statement explaining your request or concern and how that relates to your or another person’s Personal Information;
  • your email address and telephone number; and
  • an undertaking by you stating that your request or complaint is being made on a good faith basis and all material facts disclosed by you is true to the best of your knowledge.

We shall make our best efforts to resolve complaints within one (1) month from the date of receipt.

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