Effective date: August 30, 2019 (updated January 10, 2024)
Wonda VR Inc and Wonda VR SAS (“Wonda”, “we” or “us”) operates the http://www.wondavr.com website and the spaces.wondavr.com platform, Wonda immersive learning authoring and publishing software and associated web, mobile and VR applications.
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.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from help.wondavr.com
Your privacy protection is important to us. This is why we have adopted the EU’s General Data Protection Regulation 2016/679 (“GDPR”), UK General Data Protection Regulation (“UK GDPR”) and the California Consumer Privacy Act 2018 (“CCPA”). This privacy notice relates to all personal data we process and addresses the legislation mentioned.
‘Personal data’, in this privacy notice, means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is someone who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Useful resources
We remain committed to building a secure learning platform that protects the privacy and security of learners' and employees’ data. We provide all users with the tools to ensure that their data, information and operations are secure and protected.
Privacy features embedded with Wonda are GDPR compliant and adheres to local privacy legislation requirements. However, some responsibility for compliance and safety rests with the organisation that controls how Wonda is used.
We encourage institutions and organisations to implement security measures for their Wonda installation and:
Provide students/employees/clients with specific privacy policy notice about the data they collect using Wonda so that they can be completely transparent with their learners, educators and anyone who visits their site on how they collect, use or disclose their data;
protect digital minors with age-of-consent checks and manage access for minors who require parental agreement to access their learning management system;
enable users to easily request access to their data, to see the policies they’ve agreed to and appoint a Privacy officer role to manage subject access/deletion requests from such users centrally.
We have also included some useful resources for your use in engaging with Wonda:
Our standard Data Processing Agreement (DPA) that covers all of our products and services in a concise and comprehensive Schedule 1.
Cross Border Standard Contract Clauses (SCCs) that will allow us to contract with you to ensure protection of any personal data required to be transferred outside the EEA.
Why we collect your personal data
In order for us to provide you with our services or for correspondence purposes we need to collect your personal data. We ensure that the information we collect and use is confined to this purpose. We always process your personal data for specific purposes, with the nature of the data collected depending on your interaction with us. We are committed to transparency in this.
Our legal bases for controlling or processing personal data are:
Article 6.1(a) GDPR (Consent): You provide informed consent to us or have a reasonable expectation that we will use your information in a certain way – for example, to engage in our community discussions, or to hear about new services or offers.
You can withdraw your consent at any time either by selecting ‘delete my data’ within the specific service or by request to [email protected];
Article 6.1(b) GDPR (Contract): Providing our services and fulfilling our obligations to you, usually relating to a terms of service or partnership agreement;
Article 6.1(c) GDPR (Legal Obligation): The necessity to meet compliance with our legal obligations; and/or
Article 6.1(f) GDPR (Legitimate Interest): Where it is in our legitimate interests to do so. We only rely on ‘legitimate interests’ as the legal basis for processing by us, or third parties we use, for these purposes:
recruitment and induction of new employees, contractors and other people who work with us;
emergency contacts for people who work with us, such as employees and contractors for health and safety purposes;
business development; or
providing login systems to users via their existing social media accounts.
Where we rely on a specific basis for processing your information and you wish to object to that processing, you must be aware that it might not be possible for you to continue using our services.
The special categories of personal data (Article 9 of GDPR) we process are:
biometric data in the form of facial images, where you have uploaded and we store your profile picture;
health data in respect of employees, contractors and other people who work with us; and/or
any special categories of special personal data which any user volunteers while using our services (for example in a forum or submission).
If we need to pass on special category personal data (see Article 9 of GDPR) to a third party, we will only do that in accordance with the legal bases under Article 6 of GDPR as outlined above.
If you would like more details about which data and how we and our subprocessors use it, please refer to our Register of GDPR Information.
How we collect personal data
Wonda collects personal data from you when you interact with us. This can be through our websites, over the phone, in person, including, without limitation, when you:
create an individual or corporate user account;
request support;
register for or participate in an online class, exam, certification, training, webcast or other event;
request information or materials;
participate in surveys or evaluations;
participate in promotions, contests or giveaways;
make a purchase through our online payment system;
apply for employment;
submit questions or comments; or
submit content or posts on our forums or other interactive webpages.
How we use personal data
We may need to pass your personal data on to third-party service providers contracted to Wonda in the course of dealing with you. We do this because there are services, such as our video conferencing facility, which will not work unless we are able to make these transfers. Any third parties we share your data with are obliged to keep your personal data secure and use it only for necessary service delivery.
When your data is no longer required to fulfil the service, those third parties will be directed to dispose of your data in accordance with our standard procedures.
We seek to enter into Data Processing Agreements with our third party service providers to ensure they only process your data as instructed by us. If you obtain products or services directly from us on behalf of others we will ensure you enter into a Data Processing Agreement (DPA) with us. You will also need to enter into a DPA with your students/employees/customers when using our systems.
How we store personal data
We will process (collect, store and use) the information you provide in a manner compatible with GDPR. We maintain physical, organisational and technical safeguards for all personal data we hold. We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.
We are required to retain certain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept are governed by specific business sector requirements and agreed practices. Personal data can be held in addition to these periods depending on individual business needs.
We will process different forms of personal data for as long as it is necessary and proportionate for the purpose for which it has been supplied and we will store the personal data for the shortest amount of time possible, taking into account legal and service requirements.
Marketing
We have no interest in collecting any data beyond that needed to ensure our services work for you. If you are going to be contacted by us for marketing purposes, we will not rely solely on this privacy notice. We will endeavour to seek your consent appropriately. Wonda does not sell data, and has no intentions in doing so in the future.
Your rights when we process your personal data
At any point while we are in possession of or we process your personal data, you have the following rights:
right to withdraw consent;
right of access;
right of rectification;
right to erasure;
right of data portability;
right to restrict processing;
right to object;
right to object to automated processing, including profiling;
right to know;
right to opt out of the sale of your personal information, although we do not sell your data;
right to judicial review: in the event that we refuse your request under rights of access, we will provide you with a reason as to why;
right to be free of discrimination if you exercise your rights;
notification of data breaches; and/or
the right to lodge a complaint with a supervisory authority.
Where we are your Data Controller, please make your request directly to the Data Protection Officer at [email protected]. We will always respond within one month.
However, if we are processing your data on behalf of your Data Controller (your university or your employer) you should contact them directly.
Privacy notices of other websites
This privacy notice outlines how we manage your personal data. If the website you are using is not hosted by us or you click on a link to another website, we encourage you to read their privacy notice.
Where we are not involved with your personal data, such as where experiences made with Wonda are embedded (e.g. on a company website or another LMS) , you should address your requests to the Data Controller of the website.
Children and Personal Data
Here at Wonda we understand the importance of protecting the personal data of children under the age of 16. It is not our intention to collect personal data from a child. If you believe that a child has disclosed personal data or that we hold personal information about a child, please email us at [email protected].
Verification
Before we action a personal data request we need to verify your identity. We accept a request made through your personal Wonda account while you are logged in. We may require additional information such as a colour copy of your passport, driving licence or national ID card.
Amendments to our Privacy Notice
Wonda updates our privacy notice when necessary or in response to:
feedback from our community, customers, relevant authority, industry or other stakeholders;
changes in our products or services; and/or
data processing or policy changes.
The “last updated” date at the top of this privacy notice reflects when the most recent changes were made. We encourage you to periodically review this privacy notice for any amendments.
How to contact us
If you have any questions about our privacy notice, please contact us by email at [email protected], or by mail at:
Wonda VR Inc
C/O Constantin 20 W 55TH ST FL 7
New York, NY 10019
Wonda VR SAS
16 rue du Caire
75002 Paris, France
Register of GDPR Information
If you would like more details about the types of information we process, please refer to our Register of GDPR Information.