Our commitment for Data Protection and compliance with GDPR
Effective date: August 30, 2019 (updated Nov 30, 2021)
Wonda ("us", "we", or "our") operates the http://www.wondavr.com website and the spaces.wondavr.com platform, Wonda authoring software and associated web, mobile and VR applications (hereinafter referred to as the "Service").
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small files stored on your device (VR headset, personal computer or mobile device).
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data").
Personally identifiable information may include, but is not limited to:
First name and last name
Address, State, Province, ZIP/Postal code, City
Cookies and Usage Data
We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking Cookies and IP Data
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website or VR experience and stored on your device.
Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.
Examples of Cookies we use:
Session Cookies. We use Session Cookies to operate our Service.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Besides, we do log IP addresses of devices visiting our website and the spaces.wondavr.com platform. As soon as you or any User of any of the content you have created using Wonda Services, Wonda collects the IP address of the User in order to analyze the traffic on the Site and to control the activity of the User on the Site to make sure that this one does not run acts likely to damage the Terms and Conditions.
This processings falls within the framework of Article 6(1)(f) of the Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on data protection (the “GDPR”), according to which processing is lawful where it is necessary for the legitimate interests of the controller.
Use of Data
Wonda uses the collected data for various purposes:
To provide and maintain our Service
To notify you about changes to our Service
To provide customer care and support
To provide analysis or valuable information so that we can improve the Service
To monitor the usage of the Service
To detect, prevent and address technical issues
To provide you with insight on your progress and performance with learning and productivity metrics about your own usage and about the usage from the users who are accessing, editing and interacting with content you shared with them using our Service.
Personal data - collected by you in the context of using our Services
As a content creator or administrator, Wonda may provide you with customizable tools to analyze behaviors and progress of a user viewing and interacting with your content.
You acknowledge that, when such data is provided to you, you have complete control over the personal data collected in this context. Thus, you acknowledge that you are a data controller within the meaning of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on data protection (the “GDPR”).
It is therefore your responsibility to comply with the obligations relating in particular to the information of data subjects and their rights. Users must contact you directly for any questions relating to the collection of their personal data in the context of the training session or any other activity they participated in using our Service.
When processing data on your behalf, Wonda undertakes to comply with the obligations incumbent upon it under all regulations relating to the protection of personal data, and in particular from the GDPR.
In particular, Wonda guarantees that it:
acts only on documented instructions from you (understood in particular as the parameters made available on Wonda Services), including with regard to transfers of personal data to a third country to the European Union and the USA;
does not use personal data for itself or for purposes other than the performance of the Terms and Conditions;
does not communicate nor transfer the personal data to unauthorized third parties;
upon your request, collaborates in the performance of any impact assessments or consultation of the authorities relating to the processing of personal data carried out in the context of the Services and cooperates with the relevant data protection authorities, in particular in the event of a request for information or supervision;
shall not at any time communicate personal data to any governmental entity or any other authority, including on legal or regulatory requisition, without prior notification to you, unless it is required to do so under Union or Member State law to which the processor is subject; in such case, Wonda shall inform you of that legal requirement before processing, unless that law prohibits such information on important grounds of public interest;
does not resort to the services of another processor without your prior written consent. Any resort to a new processor is subject to prior notification to you. You may oppose the resort of a new processor by informing Wonda by any means. In any event, Wonda must enter into a contract with its processor containing obligations at least equivalent to those to which Wonda is bound;
cooperates with and assists you, taking into account the nature of the processing, setting up appropriate technical and organisational measures insofar as this is possible, in order to respond to requests from data subjects to exercise their rights under the applicable legal provisions;
at the end of the Agreement and at your choice, deletes or returns all your personal data on the medium agreed between the Parties, and delete existing copies, unless Union or Member State law requires storage of the personal data. This return or deletion will give rise to the he drawing up of minutes, dated and signed and given to you;
makes available to you all information necessary to allow for and contribute to audits, inspections, conducted by you or another auditor mandated by you.
Transfer Of Data
Your information, including your Personal Data, may be transferred to — and maintained on — devices located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Whenever we transfer your personal data outside of the European Union, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Disclosure Of Data
Wonda may disclose your Personal Data in the good faith belief that such action is necessary to:
To comply with a legal obligation
To protect and defend the rights or property of Wonda
To prevent or investigate possible wrongdoing in connection with the Service
To protect the personal safety of users of the Service or the public
To protect against legal liability
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Wonda commits to implement all necessary technical and organisational measures to ensure:
the physical and logical security of personal data against any intentional or unintentional breach, in particular the measures required under Articles 32 to 36 of the GDPR ("Section 2 Security of personal data");
the confidentiality of personal data, in particular by ensuring that persons authorized to process the personal data have committed themselves to confidentiality of the personal data in order to ensure a level of security appropriate to the risk;
We commit to inform you of any security breach as soon as possible after becoming aware of it and takes all necessary measures to correct it;
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties may have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service.
Links to Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
By email: firstname.lastname@example.org