WHO ARE WE?

• We are Be Wise, 8998 Route 18, Old Bridge, NJ 08857 (“We”, “Us”, “Be Wise” or “our”). Our company is committed to our users’ privacy and the compliance of our data processing activities. This Policy is intended to get you familiarized with the purpose, type and extent of the processing of personal data. Please note that privacy regulations and technology are both constantly changing, so corresponding to it, our privacy policy might be revised and updated. 
• We strongly recommend you to read the full text of this Policy and to regularly check it for any updates. However, we may inform you in case we consider that a major change of this Policy will affect you. We will duly protect the integrity of your personal data, whether concerning you independently or in relation to your company, services or products.

WHAT TYPE OF INFORMATION DO WE COLLECT?

• In the course of using our services, we have to ask you to provide us with certain personal data which includes: names and contact details (e.g. e-mail, telephone number), billing information (physical billing address, payment and transaction details, debit/credit card information), cookies and third party analytics data (please refer to section Cookies under question “Do we use cookies?”). We also process any personal data provided to us by visitors or users through their access to our website or use of our services, including via our contact form.
• Our business does not target children so we do not knowingly collect personal data of children.

WHY DO WE PROCESS YOUR PERSONAL DATA AND WHAT ARE THE LEGAL GROUNDS FOR IT?

• Processing of your personal data is necessary in order to be able to fulfil our contractual obligations towards you and to provide you with our services /art. 6, para. 1, p. b) of the General Data Protection Regulation – GDPR/, to comply with our legal obligations (Art. 6, para. 1, p. c) of the GDPR/. Generally, we collect personal data which you have provided voluntarily and we aim to request for as little information as possible in order to comply with the applicable legislation and to be able to offer you our services. Besides these most common reasons for the collection of personal data, based on our legitimate interest we might also use it for further improvement and development of our services, to provide you with technical support, enhance our data security, fraud and anti-money laundering prevention. We also use this information for: getting in touch with our customers, personalizing our advertising based on the customers’ preferences and providing targeted marketing related to our services and promotions.

WHERE IS YOUR PERSONAL DATA STORED?

• We are based in the United States of America. If you are an EU resident or you reside within the EEA, your personal data might automatically be transferred to US. We use Amazon Web Services (AWS). AWS delivers an industry-leading network of state-of-the-art data centers located around the world, including in the United States of America and Australia. You may read more about their privacy and security policies here: https://aws.amazon.com/privacy/ and here: https://aws.amazon.com/security/. Amazon Web Services, Inc. participates in the EU-US and Swiss-US Privacy Shield frameworks. Click here to learn more: https://www.amazon.com/gp/help/customer/display.html/ref=hp_left_v4_sib?ie=UTF8&nodeId=202135380.We use standard contractual clauses when we transfer your personal data to third parties outside the EEA or we adopt other means to ensure that adequate safeguards are applied to your personal data, such as a relevant third party’s Privacy Shield certification or binding corporate rules (approved by EU data protection authorities and put in place to protect your personal data).

PERSONAL DATA RETENTION:

• We will retain personal information that we have collected and process for as long as needed to provide our service to our customers or as required or permitted under the applicable law. We may further retain and use this personal information as necessary to comply with our legal obligations; maintain accurate accounting, financial, and other operational records; resolve disputes; and enforce our agreements. We have established internal policies for the deletion of data from customer accounts following termination of a customer’s subscription to the service.

THIRD-PARTY SERVICES:

• We use service providers. We may engage third-party companies and individuals to facilitate our services, to assist us in analysing how our website and services are used, and to perform services related to administration of our service or website (e.g. maintenance, payments, hosting and database management services, website analytics and administration). These third parties may have access to your personal data  so that they may perform these tasks on our behalf. They are obligated to comply with our requirements for confidentiality and this Policy and may not use your personal data for any purpose other than what they have received it for.

Some of the third-party services that we are currently using are:

Matomo Analytics:

Matomo is an all-in-one web analytics platform designed to give us insights and evaluate the full user-experience of our visitor’s behaviour with Matomo’s Conversion Optimization features, including Heatmaps, Sessions Recordings, Funnels, Goals, Form Analytics and A/B Testing. Matomo can be configured to automatically anonymise data so we don’t process any personal data.

Purpose: users statistics about our website visitors;

Legal ground for processing: Article 6 (1) (f) GDPR /processing is necessary for the purposes of the legitimate interests pursued by the controller/

Provider’s Privacy Policy: https://matomo.org/gdpr/

Paypal:

We process payments made by our users via Paypal – a reputable payment service provider.

Purpose: receiving payments from our users;

Legal ground for processing: Article 6 (1) (b) GDPR / processing is necessary for the performance of a contract to which the data subject is party/;

Provider’s Privacy Policy: https://www.paypal.com/en/webapps/mpp/ua/privacy-full#Updated_PS

Sendgrid:

We use Sendgrid for our email campaigns.

Purpose: sending e-mails to our users, including notifications or newsletter;

Legal ground for processing: Article 6 (1) (b) GDPR / processing is necessary for the performance of a contract to which the data subject is party/; Article 6 (1) (f) GDPR /processing is necessary for the purposes of the legitimate interests pursued by the controller/

Provider’s Privacy Policy: https://sendgrid.com/policies/privacy/

Google:

We use several services, provided by Google, including services provided by Google Ireland Limited, as well as those provided by Google LLC, these services include Google Analytics, Google Analytics Ads, Google Tag Manager, Google Search Console, Google reCaptcha and Google Maps. Please note that similar to Amazon, Google is also certified under both the EU-U.S. Privacy Shield frameworks and their certifications can be viewed on the Privacy Shield list- https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI.

Purpose: usage analysis, marketing and personalized advertising, ad delivery and reporting across multiple sessions and devices;

Legal ground for processing: Article 6 (1) (f) GDPR /processing is necessary for the purposes of the legitimate interests pursued by the controller/ or on the basis of your consent where such is required..

Provider’s Privacy Policy: https://policies.google.com/privacy

Tawk.to

Purpose: We use Tawk.to’s services in order to provide real-time customer support to our customers. The chat-function that Tawk.to provides gives users the opportunity to connect with their clients or with us.

Legal ground for processing: Article 6 (1) (b) GDPR / processing is necessary for the performance of a contract to which the data subject is party/; Article 6 (1) (f) GDPR /processing is necessary for the purposes of the legitimate interests pursued by the controller/ 

Provider’s Privacy Policy: https://www.tawk.to/privacy-policy/

DO WE USE COOKIES?

A cookie is a small text file that a website saves on your computer or mobile device when you visit our website. We may gather information through files such as cookies or log files on the browsing habits. Cookies are files by the website and stored on the user's browser through a web server for the maintenance of the browsing session by storing the IP address of the user (of his or her computer) and other possible browsing data. 

We use several type of cookies:

• Web analytics cookies. 

We use them in order to to measure and analyse user browsing on our website. Analytics cookies allow us to monitor and analyse the behavior of users on our website. Web analysis does not allow information like your names or email address to be obtained. The only information obtained relates to the number of users that access the website, the number of pages seen, the frequency and repetition of the visits, their duration, the browser used, the operator providing the service, the language, the device used or the city to which the IP is assigned. We use the described cookies via Google Analytics (a service, provided by Google Inc.) and other services provided by Google, as well as via our own cookies – managed by us. 

Google Analytics collects first party cookies, as described above. The information collected using these cookies is sent to Google and is used to evaluate how our web page is being used (for statistics purposes). We will not associate any data gathered with any personally identifying information. We will not link or seek to link any cookie information with any IP address or with the identity of a computer user. Besides the analytics and statistics purpose, we might use advertising cookies to deliver ads that we believe are more relevant to you and your interests. We use the services of Google and you can read more about their policies here:

https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage  https://policies.google.com/privacy  

These are all the cookies we use: 

*Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

You can control or delete cookies if you wish - through the options of your browser. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. Be informed that doing so may prevent you from taking full advantage of the website.

You may read more information about cookies at: https://www.allaboutcookies.org/ 

WHAT RIGHTS DO YOU HAVE?

The General Data Protection Regulation grants you numerous rights with respect to your personal data: right of access, correction, erasure, restriction of processing, objection and data portability, request a copy of your personal data.

We will not require you to pay any fee to accessing your personal information or to exercise any of the other rights and yet we may charge a reasonable fee if your request/requests is/are clearly unfounded or excessive. Any questions or requests related to this Policy shall be addressed at: [email protected] 

If you want to submit a complaint, you can do this in your relevant data protection authority as you can find a list of all EU data protection authorities here although we would prefer if you contact us directly so that we can promptly resolve the issue: 

https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm 

CHANGES TO THIS DATA PROTECTION & COOKIE POLICY:

We reserve our right to change and update this Policy at any time. We may also notify data subjects or our clients in case we make some substantial updates.

CONTACT INFORMATION OF OUR EU REPRESENTATIVE UNDER ART. 27 OF THE GENERAL DATA PROTECTION REGULATION:

EU GDPR Privacy Officers Ltd.

Address:  Sofia 1408, 34 Mila Rodina Str., fl. 1, office 1

e-mail: [email protected]