a service provided by Wongelnet Limited and its subsidiaries, including Wongelnet, Inc.
• If you are located in the United States, Wongelnet Inc. is the Data Controller of your personal data provided to, or collected by or for, or processed in connection with, our Platform;
• If you are located outside the United States, Wongelnet Ltd. is the Data Controller of your personal data provided to, or collected by or for, or processed in connection with, our Platform;
• We may share your data within our corporate group of companies that are related by common ownership or control (“Wongelnet Group”) and data of US users may be processed by Wongelnet Ltd. on Wongelnet Inc.’s behalf.
Our Privacy Principles
The personal information we collect is related to providing the Platform and its features and falls into three general categories:
• Information you provide to us
• Information collected automatically
• Information we obtain from third parties
Information You Provide
We ask for and collect the below personal information when you use the Platform.
You don’t need to register for a Wongelnet account in order to visit or use our Platform. However, certain Services require that you register for an account and, by doing so, you will need to provide us with certain information:
• Account Information - When you register any kind of Wongelnet account, you will need to provide your email address (except when you sign-up with Facebook or Google and don’t give your permission to share it with Wongelnet), your age, and choose a password. In addition, if you purchase a Subscription, you will also need to provide your real name, billing address, and payment verification information.
• Profile Information - you may choose, at your discretion, to provide additional information for your public profile on Wongelnet – for example:
• your real name
• a user name (which may be your real name or a pseudonym)
• the city and country in which you live
• a profile picture, profile header image or avatar
• information about how you categorize yourself with respect to your content (for example, whether you are a musician, a label or some other category of creator)
• details of your other websites and social media profiles, including links to those pages
• your gender if you wish to provide it
• any additional information you choose to provide as part of your public profile, such as your real name, and links to your website and other social media profiles (but not your email address), will be published on your profile page. This information will be publicly accessible and may be viewed by anyone accessing the Website, or using our API or other Services.
• Communications - When you communicate with Wongelnet by email or through the Platform, or use the Platform to communicate with other users, we collect information about your communication and any information you choose to provide.
• Survey Information - If you participate in any survey, you may provide certain personal data as part of your response, unless you respond anonymously.
• Information You Post - You may provide personal data when you upload Sounds to the Platform, or when you post comments, or contribute to community discussions.
• Usage Information - We collect information about your interactions with the Platform, including the pages that you visit and links you click on, streaming, offline listening or downloading tracks, uploading or recording tracks, connecting your Facebook or Google account, sharing a Sound with another user, following or unfollowing another user, posting a comment, performing a search, the time, frequency and duration of your visits to the Platform, and whether you interact with email messages, for example, if you opened, clicked on, or forwarded the email message.
• Log Data – We automatically collect log information when you use the Platform, even if you have not registered for an account or logged in. That information includes, among other things: details about how you’ve used the Platform (including links to third party sites or services), Internet Protocol (IP) address, access times, your browser type and operating system, device information, device event information (e.g., crashes, browser type), and the page you’ve viewed or engaged with before or after using the Platform.
• Location Data – When you use certain features of the Platform, we may collect data about your general location (e.g. IP address). We use this data to provide you with location-based services (such as advertising and personalized content). Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings.
• Device Information – We collect information from and about the devices you use, including how you interact with the Platform and information about the device itself, such as the hardware model, operating system, IP addresses, cookie information, device settings, mobile device and advertising identifiers, apps installed, browser type, language, battery level and time zone. Apple’s iOS Advertising Identifier (IDFA) and Google’s Android Advertising ID are examples of device identifiers. This information allows us to recognize and associate your activity, and provide personalized content and advertising, consistently across all of your devices.
• Software Development Kits – We may use third parties including our business partners and service providers who use mobile SDKs to collect information and information related to how mobile devices interact with the Platform. An SDK is computer code that app developers can include in their apps to enable ads to be shown, data to be collected and related services and functionality to be implemented. We may use this technology, for instance, to analyze how you interact with content and advertisements and to enable analytics or other features through mobile devices.
• Wongelnet Widget – Other websites may integrate Wongelnet widgets; when you visit a website with a Wongelnet widget embedded, we may receive certain information, including information about the website you visited. Wongelnet and the widget may be able to recognize you in order to retrieve your library of content, and in some cases the widget may be used to show personalized content. We know when you interact with a widget, and websites containing the widgets may receive this information as well.
Information from Third Parties
• Single-Sign Ons – If you sign up for Wongelnet through a third-party application like Facebook or Google, you authorize us to collect your authentication information, such as your username and encrypted access credentials, and other information available through the third party application account, including the following information:
• Service Providers and Business Partners – We may also receive information about you from our service providers and business partners, including companies that assist with payment processing, analytics, advertising, marketing, data processing and management (e.g. to measure ad quality and responses to ads, and to display ads that are more likely to be relevant to you, including for Wongelnet products) account management, hosting, customer and technical support, content moderation, and other services which we use to personalize your Wongelnet experience. We explain in more detail why and how we use this information below.
We use the personal information we collect from you, including with the help of automated systems and decision making, for a range of different business purposes according to different legal bases of processing and subject to the choices you make in your Settings.
• Provide, Improve, and Develop the Platform
• To operate and maintain your Wongelnet account, and to provide you with access to and use of the Platform. Your email address and password are used to identify you when you log into the Platform. Your device-IDs are used to ensure that you are in control of the devices that have access to your Subscription.
• To identify you as the creator of the Sounds that you upload, the comments that you post and/or the other contributions that you make to the Platform.
• To provide creators with stats and insights about users’ listening behavior of their Sounds, (i.e. streaming and downloading their Sounds or following their profiles).
• We conduct surveys and research, test features in development, and analyze the information we have to evaluate and improve products and services, develop new features, and conduct audits and troubleshooting activities.
• If you purchase a Subscription, your name, address and payment verification information will be used to process your account subscription and renewals and to collect your payment. All payment verification information is transmitted using industry-standard SSL (Secure Socket Layer) encryption. Wongelnet also complies with the Payment Card Industry Security Standards.
• Your email will be used to send you service updates and notifications about your account.
• To respond to you about any comment or enquiry you have submitted.
• We use your age to enable age restrictions.
• Maintain a Safe and Secure Environment
• Detect and prevent fraud, spam, abuse, security incidents, and other suspicious activity.
• Verify and authenticate your identity and prevent unauthorized or illegal activity.
• Enhance the safety and security of our products and services.
• Conduct security investigations and risk assessments.
• To provide you with customer and technical support.
• Personalize Content, Advertising and Marketing
• To improve your experience on the Platform by providing personalized content, recommendations, and features.
• To customize the content and measure performance of any email, push notification, or in-app message we may send to you.
• Administer sweepstakes, contests, or other promotional activities or events sponsored or managed by Wongelnet or its partners.
• Use automated systems and decision making to profile user characteristics and infer preferences based on information that you provide to us, your interactions with the Platform and content, your profile information, and information obtained from third parties. This data is used to create groups of users, called segments, who share similar characteristics and interests; we use segments to serve personalized content, advertising, and marketing messages. We also use automated systems to associate your activity over time across devices, and may associate activity and accounts under a single user ID, in order to determine that certain devices are related to each other and provide you with a personalized experience across devices and platforms.
• Ads are more effective when they are shown to people who are likely to be interested in the product or service advertised. For this reason, we use the information we collect and receive to help us select which ads to show you on behalf of advertisers. This includes information you choose to provide to us (e.g. age and gender) and make available to us when you interact with the Platform (e.g. by listening, liking or creating playlists), as well as general location data. We may also display ads based on the page you’re on or content you have recently viewed, searched, or listened to. This allows us to show you ads that will likely be more relevant and interesting to you.
• When we engage third party services such as ad-networks and exchanges that enable us showing you targeted ads, we may also allow them to collect certain information such as cookie data and device identifiers. That information is used to synch or match users to segments and serve targeted advertising, including based on device activity, inferred interests, and general location information.
• Combine information we collect about you with information from business partners and use it to serve more relevant advertising.
We may use your data for other purposes, provided we disclose the purposes and use to you at the relevant time, and provided that you consent to the proposed use of your personal data.
This section describes how the information collected or generated through your use of the Platform may be shared by you or by us.
• Through Your Profile – Any information in your public profile (other than your email address) will be accessible by other users of the Platform, who may view your profile information, listen to and comment on any of your public Sounds, add themselves to your list of followers, and send you messages. If you listen to any Sounds uploaded by a Wongelnet Pro user, the fact that you have listened to those Sounds will be shared with that Pro user, and that you are following that Pro user, so that they can track the popularity of their Sounds. Similarly, if you comment on any Sounds on the Platform, your comments will be available to all users of the Platform.
• With Your Consent – We will disclose your information if you have agreed that we may do so. We will make this clear to you at the point at which we collect your information, including the purpose(s) for which we will use the data.
• Service Providers – We use a variety of service providers, some of who may be located outside of the European Economic Area (“EEA”), to provide services to us or to our users on our behalf. These service providers have access to your information solely to perform these tasks on our behalf, and are contractually bound to implement appropriate organizational and technical security measures to protect against unauthorized disclosure of personal data, and only to process personal data in accordance with our instructions and to the extent necessary to provide their services to us. We need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.
• Content Partners – The Platform allows you to listen to a variety of audio content, including licensed streaming content from our commercial content partners. We share information with these content partners that license this content to us to help them understand how the content they provide is performing, including insights about general user listening trends and preferences. We use technical measures to ensure the data is de-identified and/or aggregated so it does not identify you directly. We share this data based on our legitimate interest in helping content partners deliver high performing content and to ensure the fulfillment of our contract with those partners.
• Advertising – We share the data collected about you, generally in hashed, aggregated, or de-identified forms with advertisers and advertising service providers and business partners in order to serve ads based on your interests and measure the reach and effectiveness of those ads, including whether a user took an action (e.g. purchase a product). We may also share cookie data and device identifiers with service providers for data matching purposes, in order to improve ad targeting.
• Social Media – For users outside of the EU/EEA, where permissible under applicable law, we may share your email address (in hashed form, so that it does not identify you) with Facebook in order to target you with ads for Wongelnet products on Facebook and on third party websites and applications in the Facebook Audience Network. We also allow Facebook and other social media platforms to collect information through cookies and similar technologies like pixels in order to serve ads for Wongelnet on those third-party websites and apps and drive users to our Platform. In order to measure the effectiveness of and optimize these marketing campaigns, these technologies track activity taken across devices after a user sees a Wongelnet ad, in order to determine performance metrics like sign ups, visits to the Platform, and purchases. We undertake these activities based on our legitimate interest in acquiring new customers and offering products we think you may be interested in. Any questions regarding how these social media platform service provider processes your personal data should be directed to such third-party platform.
• Aggregated Data – We may also share aggregated information (information about our users that we render in such a way that it no longer identifies or references an individual user) and other pseudonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
• Third Party Applications – If you choose to connect your Wongelnet account to other apps or social networks such as Facebook and Google you may be sharing certain information with these apps or networks. Content that you share with Facebook will appear on your timeline and in your Facebook friends’ newsfeeds. In the case of connected apps, you will need to provide the app developer with full access to your Wongelnet® account in order to upload and download Sounds, or comment on, favorite, or repost Sounds from within the app. This means sharing your public information, plus access to your private Sounds. Wongelnet is not responsible for these other apps or networks, so please make sure you only connect your account with apps or services that you trust. For information on how to control the information that you share, and how to disconnect your account from these apps, please see the Your Choices and Controls section below. If you do not want this information shared with Facebook or Google, please change your Wongelnet Settings on our Platform or in those networks.
• Protecting our Rights – We may disclose your information if we feel this is necessary in order to protect or defend our legitimate rights and interests, or those of our users, employees, directors, officers, or shareholders, and/or to ensure the safety and security of the Platform and/or the Wongelnet community.
Wongelnet maintains appropriate technical, administrative, and physical safeguards that are designed to prevent unauthorized access, use or disclosure of personal information we collect or store and to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of natural persons that may be involved with our processing operations. We regularly monitor our systems for possible vulnerabilities and attacks. However, it is not possible to guarantee the security of information transmitted over the Internet. You use the Platform and provide us with information at your own discretion and risk.
Wongelnet is a religious platform and intended for use by children. Anyone under the age of 16 in the EEA, or 13 in the United States and the rest of the world, is permitted to use the Platform and may attempt to register an account or submit any personal information to us. We do not knowingly collect any personal information from any person who is under the age of 16 or 13, as the case may be, or allow them to register an account. If it comes to our attention that we have collected personal data from a person under the age of 16 or 13, as applicable, we will not delete or modify this information. If you have reason to believe that we may have collected and modified any such personal data, you may notify us at email@example.com.
We do our best to give you as much choice as possible regarding the amount of information you provide to us, and the control you have over that information.
• Managing Wongelnet Settings. If you register an account, you may manage the content and information you share when you use Wongelnet through your account Settings, including for the features explained below. You are solely responsible for keeping your Settings up-to-date.
• Email – You can adjust your Settings in the Notification tab to disable email and desktop notifications (other than important service updates and essential notifications about the Platform or your account). All commercial emails and newsletters also allow you to unsubscribe at any time.
• Analytics – To control whether we collect analytics and usage information, including through cookies and similar technologies, you can adjust your Settings in the “Analytics” tab.
• Marketing – If you do not want to receive personalized ads, offers or other marketing messages for Wongelnet products or services, you can adjust your Settings in the “Communications” tab.
• Advertising – If you do not want Wongelnet to deliver “interest based” or personalized ads for third party products, you can adjust your Settings in the “Advertising” tab. Please note, however, that even if you opt out of personalized ads, you may still see ads, but they will likely not be as relevant or useful to you.
• Content Sharing – It’s not possible to make your account entirely private. However, you do have the option to make all of your tracks, playlists and other uploads private. This means that no one will be able to access and listen to your Sounds without your explicit permission.
• Third Party Apps – If you have chosen to connect your account to a third-party application, like Facebook or Google, you can disable permission for the app by adjusting your Settings in the “Connections” tab.
• Third Party Developers – Wongelnet has an open API, which allows third party developers to build some really cool apps as an extension of the Platform. If you would prefer that your Sounds are not made available to third party app developers, you can disable API access within the sound page for each of the Sounds that you upload. Click on the pencil icon in the waveform player, and uncheck the “Apps enabled” box at the bottom of the page. Please note that your public profile information will still be accessible, but this does not include anything that is not publicly available on the Website.
• Managing Device Settings
• On your mobile device, enable the “Limit Ad Tracking” setting in your iOS phone’s settings, or the setting to “Opt out of Ads Personalization” in your Android phone’s settings. To opt-out of location tracking when using our Apps, you can use the settings of your device. You can disable mobile analytics and bug reporting through these same settings as well.
• Managing Browser Settings
• To control cookies, you can modify your settings in most web browsers to accept or deny cookies or to request your permission each time a site attempts to set a cookie. You can also manually delete previously stored cookies at any time. Please note that if you choose to block cookies, doing so may impair the Platform or prevent certain elements of it from functioning.
• Additional Choices and Controls
If you are a user residing in the EU/EEA, you may exercise any of the rights described in this section through the Help Center or by contacting us at dataprotection@Wongelnet.com. Please note that we may ask you to verify your identity before taking further action on your request.
• Data Access and Portability
• You may be entitled to request copies of your personal information held by us. While a lot of the personal information you provide to us can be accessed in your account Settings, you may also be entitled to request copies of personal information you have provided to us in a machine-readable format.
• Change or Correct Data
• Where you cannot update data yourself through an account, you have the right to ask us to correct change, update or rectify your data.
• Data Retention and Deletion
• We generally retain data for as long as your account is in existence or as needed to provide the Platform. However, specific retention times can vary based on the context of the processing we perform and on our legal obligations.
• You have the right to ask us to delete all or some of the personal data we hold about you. If you have an account, you can also delete your account through the Settings at any time as described below.
• We may need to retain some of your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations, or where we have a legitimate interest in doing so (e.g. to prevent fraud and abuse and maintain and enhance security).
• Objection to Processing
• You may object to processing your personal information in some circumstances (in particular, where we don’t have to process the information to meet a contractual or other legal requirement, or where we are using the information for direct marketing).
• If you object to such processing Wongelnet will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims or obligations.
• Where your personal information is processed for direct marketing purposes, you may, under certain circumstances, ask Wongelnet to cease processing your data for these direct marketing purposes.
• Restriction of Processing
• Under certain circumstances, you may have the right to limit the ways in which we use your personal information.
• Withdrawing Consent
• Where you provide consent to the processing of your personal information by Wongelnet, you may withdraw your consent at any time by changing your account Settings or by sending a communication to Wongelnet specifying the specific consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
• Lodging Complaints
• You have the right to lodge complaints about the data processing activities carried out by Wongelnet before a competent data protection authority. A list of EU data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
Notice To California Users
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following details regarding the categories of personal information about California residents we have collected or disclosed within the preceding 12 months.
We collected, including through service providers, and disclosed the following categories of personal information:
• Identifiers, such as your name, email address, birthday, profile name, as well as IP addresses, device IDs, mobile advertising IDs, anonymous Wongelnet user IDs, and other similar identifiers;
• Payment and financial information you provide when you purchase a Subscription or use certain features of the Platform;
• Characteristics about you like any gender information you choose to provide when you register an account on the Platform;
• Commercial information, such as Subscription and other purchase or transaction information related to your use of the Platform;
• Internet or other network activity information, including browsing and search history and other information about your use of the Platform, as well as information about how you interact with ads for Wongelnet off the Platform;
• Geolocation data derived from IP addresses;
• Audio, visual, and other electronic information, such as sound recordings, images, and comments;
• Education information to verify your student status if you purchase a Go+ for Students Subscription; and
• Inferences drawn from any of the personal information above to create a profile or segment about you so we can provide you with personalized content and advertising.
We disclosed the categories of personal information above, including to our service providers and affiliates, for a range of operational business purposes, including:
• To operate and maintain the Platform and your account;
• To market and sell our products and services;
• To provide personalized content and ads;
• To perform research and development;
• To perform data and business analytics;
• To detect and prevent fraud or abuse;
• To perform identity verification;
• To process Subscription payments;
• To process user inquiries and requests;
• To perform security and other risk testing;
• To undertake quality assurance measures;
• To maintain our systems and infrastructure;
• To comply with law or exercise or defend legal claims;
• To perform accounting, audits and other internal functions; and
• To otherwise operate our business and achieve our business objectives
For purposes of CCPA, the disclosure of personal information to our advertising partners to provide you with personalized ads may constitute a “sale” in some instances. The personal information disclosed is limited to the following:
• IP address and device ID
• Age and gender you provide
• General location information
• Inferred music preferences based on your use of the Platform
We do not otherwise “sell” personal information.
Exercising Your California Privacy Rights
CCPA and other California law provides California residents with the additional rights listed below. You may exercise any of the rights described in this section through the Help Center or by contacting us at dataprotection@Wongelnet.com. Please note that we may ask you to verify your identity before taking further action on your request.
• Right to Access: You have the right to know and access what data we have collected about you over the past 12 months, including:
• The categories of personal information we’ve collected about you;
• The categories of sources from which the personal information is collected;
• The business or commercial purpose for collecting your personal information;
• The categories of personal information about you which we shared and/or sold;
• The categories of third parties we have shared or sold personal information to; and
• The specific pieces of personal information we have collected about you.
• Right to Delete: You have the right to request that we delete personal information we have collected from you (and direct our service providers to do the same). In some instances, however, we may decline to honor your request where an exception applies.
• Right to Opt Out: You have the right to opt-out of any future “sale” of personal information about you by clicking here or by adjusting your Settings in the “Advertising” tab.
• Other Rights: You can request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request may be made once a year. You also have the right not to be discriminated against for exercising any of the rights listed above.