Wiz Mobile Application Privacy Policy

Wiz (we) are committed to protecting and respecting your privacy and personal data. This Privacy Policy relates to your use of the Wiz mobile application software (the App). As the processing of some data is essential to the functioning of the App if you do not accept the terms of this Privacy Policy you should not use the App.

This privacy policy aims to give you information about how we collect and process your personal information through your use of the App.  It makes you aware of how and why your personal information will be used, namely for the purposes of the performance of our contract with you as our User, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).This policy primarily covers how we use information relating to our parent/guardian Users who set up accounts on behalf of their own children.  In these cases, we will be the “data controller” for the purposes of data protection law. There are also cases where we will be a “data processor” for the purposes of data protection law.  Where educators, teachers or schools set up accounts on behalf of students, we are processing your personal information on behalf of the school/teacher in order that they can provide educational services to their students.  In circumstances where we are a data processor, it is the educator/school/teacher who decides what personal information to collect and how that information is used. Any questions that you may have relating to your personal information and your rights under data protection law should therefore be directed to the school/teacher as the data controller, not to us.

It is important that you read this policy, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information

Scope

The App works in tandem with the website www.crazybrain.biz (the Website) which is run and operated by Wiz.

In this Privacy Policy the terms ‘you’, ‘your’ and ‘yours’ refer to both 1) the Device Owner (being either the owner of the device on which the App has been downloaded or the owner of the account used to purchase the App and 2) the user on the App (if different).

In order to make use of the App the Device Owner must accept these terms. As the App has been developed to be played by children who are minors, the Device Owner will be accepting this Privacy Policy on behalf of the child player. In these circumstances the Device Owner represents that he or she is either the parent or legal guardian of any child who is using the App.

Data Protection Principles

We are required by the GDPR to ensure that we follow six principles whilst we are processing your information and it is these principles that are central to our processing procedures.  Your information will be:

1. Used lawfully, fairly and in a transparent way;

2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;

3. Relevant to the purposes we have told you about and limited only to those purposes;

4. Accurate and kept up to date;

5. Kept only as long as necessary for the purposes we have told you about; and

6. Kept securely.

Information We May Collect From You.

You may give us information about yourself when using the App or communicating with us about the App. Some of this may be Personal data, or personal information as we sometimes call it, which means data which relates to an identifiable living person.

When you use the App we will automatically collect the following non-personal data:

A set of data which encapsulates a student’s progress through the service and other information to provide continuity of the App experience (Saved Data); and we may collect
Technical information, including the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number), mobile network information, your mobile operating system (Device Information);

We will collect the following personal data:-

Login and registration information including the User’s phone number (for verification purposes only); Student’s name, gender, state/country of residence (for purpose of determining time zone), month and year of birth.

We will only collect minimal information necessary for the use of the Service. If the user wishes to enhance the Service experience, the user may provide optional information including profile picture; Student’s interests, audio-video recordings for exchange.

Additionally, you may give us information about you if you corresponded with us (for example via email) or report a problem with the App or our services. Any correspondence or reporting should be done by the Device Owner.

Cookies & Uses Made of the Information

Saved Data will be stored within the App and periodically this data and/or the Device Information may be sent to the Website servers and stored for the purposes of analytics. The player’s name will be stripped from this data and no additional data will be sent to the server by the App.

Why do we collect your information?

We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

1. Where you have given us consent

2. Where we need to perform the contract we are about to enter into or have entered into with you.

3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

4. Where we need to comply with a legal or regulatory obligation.

Your personal data will be collected, processed, stored and used by us, and passed to and processed by our subsidiary and/or affiliated companies and other data processors acting under contract with us for three main purposes:

1. To register you as a User

2. To provide and promote the App Service,

3. To provide customer support

We will retain your personal data only as long as is necessary for the purposes to which the Device Owner consents under this Privacy Policy and any related agreement(s) with us, or as is required by applicable law, and then we will delete it.

Disclosure of your Information

With other users; Any content posted or sent - How widely your content is shared depends on your personal settings and the type of service you are using. For example, a video may be sent to just a single friend you select. Users whom you are matched with will also receive basic information about you, such as your name, age, state/country and any additional information you have directed us to share.

In our capacity as data controller we will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. We may disclose some or all of the data we collect from you when you download or use the App to any member of our group, which means our subsidiaries, our ultimate holding company (where applicable) and its subsidiaries (as defined in section 1159 of the Companies Act 2006)

Any third parties will be bound by contractual provisions with us and only have access to personal data to perform the described purposes and may not use it for other purposes. Further, they must process the personal data in accordance with this Privacy Policy and as permitted by the GDPR.

Where We Store Your Personal Data

Saved Data will be stored locally within the App on your device and may be transferred and stored on the App’s servers.

It is possible that some of the servers and companies that process your data on behalf of Wiz may be based in countries outside the European Union (“EU”). Countries outside the EU may not have as well-developed data protection laws to protect your information as those inside the EU, but Wiz will contractually require that personal data which is processed on its behalf is treated in compliance with EU laws and the App’s privacy policy.

Security

We take appropriate technical and organisational measures to guard against unauthorised or unlawful processing of your personal information and against accidental loss or destruction of, or damage to, your personal data. While no computer system is completely secure, we believe the measures implemented by our App reduce the likelihood of security problems to a level appropriate to the type of data involved. We have security measures in place to protect our User and Student database and access to this database is restricted internally. However, it remains each User's responsibility:

1. To ensure no-one else uses the App Service while the User’s device is "logged on" to the App Service;

2. To log off or exit from your Account when not using it

3. To keep his/her password or other access information secret.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

What rights do you have?

Under certain circumstances, by law you have the right to:

1. Request access to your personal information (commonly known as a "data subject access request"). Once you have made a subject access request we are obliged:

To tell you whether we process any of your personal data

If so, to provide you with a description of the personal data we hold, the reasons it is being processed, and with whom we share it

To provide you with a copy of the personal data we process in an intelligible form, and (where this is available) to inform you about the source of the data

All Subject Access Requests must be in writing to cs@crazybrain.biz

2. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

In order to correct any of the information we hold about you, simply log into your account and make the changes that are required.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

3. Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

4. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

5. Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact cs@crazybrain.biz. Please note, there are some specific circumstances where these rights do not apply and we can refuse to deal with your request

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

Where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact cs@crazybrain.biz. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Complaints

We take any complaints we receive about the collection and use of personal information very seriously.  We would encourage you to bring it to our attention if you think that our collection or use of information is unfair, misleading or inappropriate.  You can make a complaint at any time by contacting us (see contact details section below).

Changes to Privacy Policy

Any changes we may make to this privacy policy in the future will be posted on this page and, where appropriate, notified to you when you next start the App. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.

Governing law

This policy is governed by the laws of England and Wales.