Privacy Policy

Dear User, Wooflo Pro (hereinafter known as “Wooflo Pro”, “Provider,” us”, “we”, “the App”, “the Site”, or “Wooflo Ltd”) respects the privacy of its users and is committed to protecting their personal information. This privacy policy explains how we collect, use, disclose, and protect personal data, and outlines your rights as a data subject. Please take a moment to review this policy carefully.

The data that may be communicated through the Site will be treated with the utmost care and with all the tools necessary to ensure their security, in full compliance with current legislation placed to protect the confidentiality of data. We wish to inform you that the “European Regulation 2016/679 on the Protection of Individuals with regard to the Processing of Personal Data and on the free movement of such data” (henceforth “Regulation” or “GDPR”) provides for the protection of individuals with regard to the processing of data of a personal nature as a fundamental right. Therefore, pursuant to Article 13 of the GDPR, we would like to inform you of the following.

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Introduction
Wooflo Pro offers its users a software platform called Wooflo Pro, accessible through the website of the same name which, through a series of features and interactions with external providers, allows Customers to:

Centrally manage the reviews of their end customers, also selecting a carousel of the best reviews that they can display on their landing pages;
Actively communicate with end customers in order to request the opportunity to review the venue and/or product/service purchased;
Monitor the progress of reviews and scores (or “ratings”), which will also be aggregated among the various service providers;
Wooflo Pro, in accordance with the GDPR Regulations, acts as:

Data Controller, with respect to the data of Users who own businesses of various kinds and/or further business activities (hereinafter “Merchants”) and browsing data, in particular the data referred to in points a) and b) of Article 2 of this Policy.
Processor for the data of end customers (i.e. those who review the Merchant’s business) conferred by Merchants in the context of requesting, creating and organizing reviews. The processing carried out by Wooflo Pro in relation to these categories of data is governed by the “Data Processor Addendum” pursuant to Article 28 of the Regulations. The Addendum constitutes an integral part of the contractual relationship between Wooflo Pro and The Merchant, together with this notice and the terms and conditions.
Wooflo Pro does not use the data provided by Merchants for its own purposes, such as marketing, market research, communication to third parties, or dissemination. It is understood that Merchants ensure that end customers have been adequately informed that their data will also be processed through external data processors and, in particular, by Wooflo Pro.

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GLOSSARY
“Addendum” is the document that governs the relationship between the Merchant and Wooflo Pro regarding privacy.
“Personal Data” means any information concerning an identified or identifiable natural person, with particular reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more characteristic elements of his or her physical, physiological, genetic, mental, economic, cultural, or social identity.
Wooflo Pro is the company Wooflo Ltd – 71-75 Shelton Street Covent Garden London – Mail: support@wooflo.pro
“Processor” means the natural person, legal entity, public administration, and any other entity that processes personal data on behalf of the Controller.
“Controller” means the natural or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data and the instruments adopted, including security measures.
“User(s)” and/or “Customer(s)” “Data Subject(s)” means the individual who visits the website www.wooflo.pro and uses the service, i.e., the one to whom the Personal Data refers who, unless otherwise specified, coincides with the Data Subject.
CATEGORIES OF DATA
The Controller collects directly from its Users Personal Data and other information as part of the online registration processes on the website www.wooflo.pro in order to provide the services requested by Users (typically these are data such as e-mail address, first name, last name, contact telephone number of a contact person).

The subject of processing may be personal data of Users such as:

a. Data provided in the basis of registration and the data necessary for payment.

Wooflo Pro will process personal data necessary to register properly on the site to allow access to the platform and the use of related services. This data is provided directly by the Data Subject and may include personal data and contact details, including but not limited to first name, last name, date of birth, e-mail address, and telephone number. Wooflo Pro will also process data necessary for the payment of non-free services by the registered User, including any billing information. If the User authorizes it or through the use of cookies, Wooflo Pro may store authentication or payment and billing data, which the User may delete at any time and will be used only for the purposes of contract performance.

b. Automatically collected data.

The computer systems and applications dedicated to the operation of the Wooflo Pro website detect, in the course of their normal operation, certain data (the transmission of which is implicit in the use of Internet communication protocols) potentially associated with identifiable users. The data collected include IP addresses and domain names of computers used by Users connecting to the site, addresses in URI (Uniform Resource Identifier) notation of resources requested, method used in submitting requests to servers, size of files obtained in response, numerical codes indicating status of responses given by servers (successful, error, etc.), and other parameters regarding operating system, browser, computer environment used by users, name of internet service provider (ISP), date and time of visit, web page of visitor’s origin (referral), and exit.

c. Data provided voluntarily by the User.

The voluntary and explicit sending of electronic mail to addresses indicated in different access channels of this site does not imply a request for consent and involves acquisition of sender’s address and data necessary to respond to requests as well as any other personal data included in messages. These data are understood to be voluntarily provided by User at time of request for provision of service. By entering a comment or other information, User expressly accepts this document and particularly agrees that contents entered may also be freely disseminated to third parties. On contrary, specific summary information will be reported or displayed on pages of site set up for particular services on request (forms). User must therefore explicitly consent to use of data in forms in order to send request.

d. Data processed as Data Processors.

Wooflo Pro processes data provided by Merchants as a Data Processor and in accordance with requirements contained in Addendum. In particular, Wooflo Pro guarantees compliance with instructions from Merchant and not using such data for its own purposes such as marketing, market research, communication to third parties or dissemination.

e. Cookies.

The site uses cookies. Data collected through cookies may be used to access parts of site or for statistical purposes or to make browsing experience more pleasant and efficient in future while trying to assess user behavior and modify proposition of offering content according to their behavior. For more information visit here “www.wooflo.pro.”

f. Plug-ins.

The site also incorporates social media plug-ins and/or buttons to enable easy sharing of content on favorite social networks. Such plug-ins are programmed not to set any cookies when accessing page to safeguard privacy. Eventually cookies are set if provided by social networks only when user makes actual and voluntary use of plug-in. Remember that if you browse while being logged into social network then you have already consented to use of cookies conveyed through this site at time of registration with social network. Collection and use of information obtained by means of plug-in is governed by respective privacy policies of social networks.

SOURCEOFPERSONALDATA
Personal data held by Owner are collected directly from Data Subject. End-customer data are uploaded by Merchants as part of use of services.

PURPOSEDATA PROCESSING AND LEGAL BASIS
Processing Users’ data has following purposes and legal basis:

Registration and access to services
Purpose: authentication and use of site. Legal basis: contractual fulfillment.

Payment processing.
Purpose: access certain purposes of service. Legal basis: contractual fulfillment.

Storage of Users’ payment data.
Purpose: speed up purchase process. Without consent, nothing will be stored. Legal basis: consent of User.

Communication to business partners and/or third parties
Purpose: Communications for marketing, promotional and/or commercial purposes. Legal basis: consent of User.

Newsletter
Purpose: send e-mail about news and topics of interest. Legal basis: consent of User.

Sending direct marketing communications
Purpose: updates on Owner’s products and services. Legal basis: legitimate interest of Owner.

Service maintenance and improvement.
Purpose: Use aggregated and anonymous data to improve service. Legal basis: legitimate interest of Owner.

Detecting or preventing fraudulent activities.
Purpose: detect, prevent or stop fraudulent activities on site. Legal basis: legitimate interest of Owner and legal obligation.

Compliance with court orders Purpose: comply with legal obligations.
Legal basis: legal obligation.

Accounting records.
Purpose: comply with legal obligations. Legal basis: legal obligation.

Automatically collected data.
Purpose: ensure and improve web browsing experience. Legal basis: legitimate interest of Data Controller.

Data voluntarily provided by User,
Purpose: inherent purpose in request to enter that data. Legal basis: consent of User.

For cookies and plug-ins: see cookies policy at “wooflo.pro/cookie-policy”.
Providing personal data for purposes referred to in point 1 and 2 of this article is necessary to allow you to register on platform and conclude contract. Therefore, in absence of aforementioned data, you will not be able to use our services.

Consent for purposes referred to in point 3, 4, and 5 is optional and does not entail any negative consequences for Users’ experience.

DATA RECIPIENTS
To extent relevant to stated processing purposes, Users’ data may be disclosed to partners, consulting companies, private companies, third-party technical service providers, hosting providers, IT companies, communications agencies.

If suppliers process personal data on behalf of Data Controller they will be appointed as Data Processors ex art. 28 GDPR.

DATA TRANSFER TO THIRD COUNTRY
The Wooflo Pro website may share some data collected with services located outside European Union area. In particular through social plug-ins and Google Analytics service. Transfer is authorized and strictly regulated by Article 45(1) EU Regulation 2016/679 so it does not require specific authorizations.

PERIODOFCONSERVATION
According to principle storage limitation (art.5 GDPR), verification obsolescence stored data in relation to purposes for which they were collected is carried out periodically.

In particular:

(a) automatically collected data are processed for time strictly necessary for sole purpose derive statistical information on use site and check regular operation, also for security purposes or according to deadlines stipulated by legal regulations;

(b) data voluntarily provided by user will be kept for period not exceeding achievement purposes for which they are processed or according deadlines provided by legal regulations.

RIGHTS OF DATA SUBJECT
Data Subject always has right to request from Data Controller access to their data; rectification or erasure of data; restriction of processing; possibility to object to processing; request data portability; revoke consent to processing; assert other rights under GDPR by simple communication to Data Controller; lodge complaint with supervisory authority.

Interested Party may forward these requests to following e-mail address: support@wooflo.pro

10.DATA PROCESSING METHODS

Personal data provided by Users will be subject to processing operations in compliance with aforementioned regulations and obligations confidentiality that inspire activity Data Controller. Data will be processed both with computer tools and on paper media as well as on any other type suitable media in compliance with adequate security measures pursuant Article 5(1)(f) GDPR.

11.FINAL NOTES AND WAY OF UPDATING

Information is provided only for Wooflo Pro website and not also for other websites that may be consulted by user through links contained in this site. Policy may be subject change due introduction new legislation in this regard; therefore User is invited periodically check Privacy Policy in order updated on latest legislative changes.