Wisian Privacy Policy

Introduction

At Wisian, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and disclose your information as described in this Privacy Policy.

Remember that your use of Wisian's Services is at all times subject to our Terms & Conditions, which incorporate this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms & Conditions. You may print a copy of this Privacy Policy.

As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. We will alert you of material changes by placing a notice on the Wisian website, by sending you an email and/or by some other means. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. "Personal Data" means any information that identifies or relates to a particular individual and also includes information referred to as "personally identifiable information" or "personal information" under applicable data protection laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don't own or control or people we don't manage.

Personal Data

Categories of Personal Data We Collect

The below details the categories of Personal Data we collect and have collected over the past 12 months:

Profile or Contact Data such as first and last name, email, username, and phone number.

  • Purpose: Providing, Customising and Improving the Services; Marketing the Services; Corresponding with You
  • Disclosed to: Service Providers, Creators, Parties You Authorise

Identifiers such as driving licence number and passport number (only if you are a Creator).

  • Purpose: Providing, Customising and Improving the Services
  • Disclosed to: Service Providers

Payment Data such as payment card type, last 4 digits of payment card, billing address, billing phone number and billing email.

  • Purpose: Providing, Customising and Improving the Services
  • Disclosed to: Service Providers (specifically our payment processing partner)

Device/IP Data such as IP address, device ID, domain server and type of device/operating system/browser used to access the Services.

  • Purpose: Providing, Customising and Improving the Services; Marketing the Services
  • Disclosed to: Service Providers

Web Analytics such as web page interactions and referring webpage/source through which you accessed the Services.

  • Purpose: Providing, Customising and Improving the Services; Marketing the Services
  • Disclosed to: Service Providers

Social Network Data such as email and phone number.

  • Purpose: Providing, Customising and Improving the Services; Marketing the Services; Corresponding with You
  • Disclosed to: Service Providers, Parties You Authorise

Geolocation Data such as IP-address-based location information.

  • Purpose: Providing, Customising and Improving the Services; Marketing the Services
  • Disclosed to: Service Providers

Biometric Data such as faceprints and voiceprints (only of Creators).

  • Purpose: Providing, Customising and Improving the Services
  • Disclosed to: Service Providers

Sensory Data such as photos, videos, or recordings of you and/or your environment.

  • Purpose: Providing, Customising and Improving the Services; Corresponding with You
  • Disclosed to: Service Providers, Creators

Other Identifying Information that You Voluntarily Provide in communications with Creator's AI Expert.

  • Purpose: Providing, Customising and Improving the Services; Corresponding with You
  • Disclosed to: Service Providers, Creators, Parties You Authorise

Our Commercial or Business Purposes for Collecting Personal Data

Providing, Customising and Improving the Services

  • Creating and managing your account or other user profiles
  • Processing orders or other transactions; billing
  • Providing you with the products, services or information you request
  • Meeting or fulfilling the reason you provided the information to us
  • Providing support and assistance for the Services
  • Improving the Services, including testing, research, internal analytics and product development
  • Personalising the Services, website content and communications based on your preferences
  • Doing fraud protection, security and debugging

Marketing the Services

  • Marketing and selling the Services
  • Showing you advertisements, including interest-based or targeted advertising

Corresponding with You

  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Wisian or the Services
  • Sending emails and other communications according to your preferences

Other Permitted Purposes for Processing Personal Data

Each of the above referenced categories of Personal Data may be collected, used, and disclosed to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process; protecting the rights, property or safety of you, Wisian or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You or Your Representative

  • When you or your representative provide such information directly to us
  • When you or your representative create an account or use our interactive tools and Services
  • When you voluntarily provide information through the Services or through responses to surveys or questionnaires
  • When you send us an email or otherwise contact us
  • When you use the Services and such information is collected automatically through cookies and similar technologies

Social Media and Similar Platforms

  • When you or your representative provide your social media profiles or posts directly or through website links to us

Creators

  • When creators refer you to our Services we may receive your email address

Third Parties

  • Analytics providers to analyse how you interact and engage with the Services
  • Third parties who help us provide you with customer support

How We Disclose Your Personal Data

Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:

  • Hosting, technology and communication providers
  • Analytics providers for web traffic or usage of the site
  • Security and fraud prevention consultants
  • Support and customer service vendors
  • Payment processors

Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:

  • Ad networks
  • Marketing providers

Creators. Individuals who create and operate AI experts on the platform may receive certain information about users of our platform. For example, when you interact with a Creator, they may receive your Profile Data and access to your chat transcript with that Creator's AI Expert.

Parties You Authorise

  • Third parties you access through the services
  • Social media services

Legal Obligations

  • We may disclose any Personal Data that we collect with third parties in conjunction with legal requirements

Business Transfers

  • All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business

Data that is Not Personal Data

We may create aggregated, de-identified or anonymised data from the Personal Data we collect. We may use such aggregated, de-identified or anonymised data and disclose it with third parties for our lawful business purposes, provided that we will not disclose such data in a manner that could identify you.

Biometric Information

Individuals who use the Services ("Creators") to create an AI version of themselves (a "Creator AI Expert") are asked to provide access to photos, videos and/or audio recordings that depict them ("Content"). In connection with creating the Creator AI Expert, we may derive data from the Content that may be considered "biometric information" under privacy laws. Such biometric information may include a scan of facial geometry, voiceprint, and/or other physiological measures intended to capture the likeness of the Creator.Wisian captures and uses this data to create, operate, and make available to end users a realistic Creator AI Expert on the Services, and to improve Wisian's models.

Disclosure of Biometric Information

Wisian may disclose biometric information to its service providers, including hosting providers and other service providers that process information for Wisian. Wisian's service providers are contractually restricted with respect to their use and disclosure of information they process on behalf of Wisian.

Retention of Biometric Information

Wisian retains Creator's biometric information for the duration of its agreement with the Creator, unless a different retention period is required by law.

Tracking Tools, Advertising, and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, "Cookies") to enable our servers to recognise your web browser, tell us how and when you visit and use our Services, analyse trends, learn about our user base and operate and improve our Services.

We use the following types of Cookies:

Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. Disabling these Cookies may make certain features and services unavailable.

Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognise you when you return to our Services.

Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They help us measure the performance of our advertising campaigns.

Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you.

You can decide whether or not to accept Cookies through your internet browser's settings. Most browsers have an option for turning off the Cookie feature. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

Data Security

We seek to protect your Personal Data from unauthorised access, use and disclosure using appropriate physical, technical, organisational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Data Retention

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law.

Personal Data of Children

We do not knowingly collect or solicit Personal Data from children under 13 years of age; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at hello@wisian.com.

UK Data Subject Rights

If you are a resident of the United Kingdom, you may have additional rights under the UK General Data Protection Regulation (the "UK GDPR") with respect to your Personal Data, as outlined below.For this section, we use the terms "Personal Data" and "processing" as they are defined in the UK GDPR. Wisian Limited will be the controller of your Personal Data processed in connection with the Services.

Personal Data We Collect

The "Categories of Personal Data We Collect" section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our "legitimate interests" or the legitimate interest of others, as further described below.

Contractual Necessity: We process the following categories of Personal Data as a matter of "contractual necessity", meaning that we need to process the data to perform under our Terms & Conditions with you:

  • Profile or Contact Data
  • Identifiers
  • Payment Data
  • Social Network Data
  • Biometric Data
  • Sensory Data
  • Other Identifying Information or Content that You Voluntarily Choose to Provide

Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:

  • Profile or Contact Data
  • Identifiers
  • Payment Data
  • Device/IP Data
  • Web Analytics
  • Geolocation Data
  • Other Identifying Information or Content that You Voluntarily Choose to Provide

Examples of these legitimate interests include:

  • Providing, customising and improving the Services
  • Marketing the Services
  • Corresponding with you
  • Meeting legal requirements and enforcing legal terms

Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data.

UK Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at hello@wisian.com.

  • Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data
  • Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data
  • Erasure: You can request that we erase some or all of your Personal Data from our systems
  • Withdrawal of Consent: If we are processing your Personal Data based on your consent, you have the right to withdraw your consent at any time
  • Portability: You can ask for a copy of your Personal Data in a machine-readable format
  • Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes
  • Restriction of Processing: You can ask us to restrict further processing of your Personal Data
  • Right to File Complaint: You have the right to lodge a complaint about Wisian's practices with respect to your Personal Data with the Information Commissioner's Office (ICO)

Transfers of Personal Data

The Services are hosted and operated through Wisian and its service providers. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Wisian and will be hosted on our servers, and you authorise Wisian to transfer, store and process your information.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at: