Privacy Policy – WORDWIDE

Last updated January 2020

 

Who are we?

WORDWIDE and its affiliates and subsidiaries may be a “data controller” of your personal data, which means that WORDWIDE has control of your personal data and may utilize it for various purposes, including sending your information to “data processors” we work with. Alternatively, depending on who you are and our relationship to you, WORDWIDE may be a “data processor” or a “sub-processor” of your personal data.

Your personal data – what is it?

Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or which is likely to come into such possession. The processing of personal data of European citizens or residents (“EU Personal Data”) is governed by the EU General Data Protection Regulation (referred to herein as the “GDPR”).

How do we process your personal data?

WORDWIDE complies with its obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorized access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.

The personal data that you provide (or have previously provided) to WORDWIDE may be stored in WORDWIDE’s data center in the United Arab Emirates. 

Further processing

If we wish to use your personal data for a new purpose not covered by an existing privacy policy, we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

How long do we keep your personal data?

We will keep your personal data for no longer than reasonably necessary for our ongoing business relationship and for record keeping purposes and in case of any legal claims or complaints.

Onward Transfers and Transfer of Data Abroad

As part of its overall global privacy compliance efforts, WORDWIDE has elected to adhere to enforcing the EU Standard Contractual Clauses (Processors) and the Privacy Shields concerning the transfer of personal identifiable data from the European Union to the United States of America, including adhering to the requirements effective under the General Data Protection Regulation (GDPR).

WORDWIDE complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively.

The term “processing” of personal data includes any operation or set of operations performed upon personal data such as collecting, storing, retrieving, consulting, using, disclosing, disseminating, and otherwise making available the personal data.

This Privacy Policy may change from time to time based on changes made to the EU Standard Contractual Clauses and/or the Privacy Shields. Any changes made necessary will be reflected in an update to this policy and disseminated.

WORDWIDE’s privacy practices are self-certified and reflect current guidance concerning the optimal manner of reaching data privacy compliance in accordance with current legal and regulatory guidance.

Cookies and Website Privacy Practices

The WORDWIDE website uses cookies, tracking pixels and related technologies. Cookies are small data files that are served by our platform and stored on your device. Our site uses cookies dropped by us or third parties for a variety of purposes including to operate and personalize the website. Also, cookies may also be used to track how you use the site to target ads to you on other websites.

When any clients visit WORDWIDE’s website, WORDWIDE does not track Personal Data, names or email addresses. Instead, WORDWIDE only tracks which Internet Service Provider has accessed the site as well as statistics that show the number of site visitors, those requests received and the country origin of those requests. This information is used to improve our site in order to better serve our clients, but this information does not constitute Personal Data.

Opting-out

WORDWIDE’s cookie provider is a member of the Network Advertising Initiative (NAI) and adheres to the NAI Codes of Conduct. You may use the NAI opt out tool here, which will allow you to opt out of seeing targeted ads from us and from other NAI approved member companies.

Further, if you want to opt out of receiving communications from us, please visit WORDWIDE’s Opt-Out Portal. If you opt-out, you will not be able to receive further communications about business opportunities or services and you will no longer be able to access applications within WORDWIDE’s technology suite.

Your rights and your personal data

If you are an EU citizen or resident, your rights under the GDPR include the following (unless subject to an exemption):

  • The right to request a copy of your personal data which WORDWIDE holds about you
  • The right to request that WORDWIDE corrects any personal data if it is found to be inaccurate or out of date
  • The right to request your personal data is erased where it is no longer necessary for WORDWIDE to retain such data
  • The right to withdraw your consent to the processing at any time
  • The right to request that WORDWIDE provide you, as the data subject, with your personal data and where possible, to transmit that data directly to another data controller
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing
  • The right to lodge a complaint with governmental agencies or Data Protection Authorities as provided for in the GDPR.

To exercise your rights to data rectification, erasure, portability, access and/or restricted processing, please email info@beWORDWIDE.com.

Data Integrity – WORDWIDE is dedicated to ensuring that all data maintained is accurate, updated, and relevant for the use contemplated by the Sales Representative and will take all required steps to ensure the data is accurate, complete and current. This process is accomplished by regular email and written correspondence with Sales Representative; however, it is highly recommended that Sales Representative continue to monitor the information provided to WORDWIDE and remain proactive with requesting access to any Personal Data and advising WORDWIDE of the need for corrections as needed.

Data Security – WORDWIDE has strict physical and logical security procedures to ensure that all digital and paper records are secured (such policy is available for dissemination to clients upon written request to the WORDWIDE Sales Head. These records are accessible only by approved staff. All critical systems (e.g., servers) are accessible only by a small number of authorized staff. WORDWIDE’s information security is managed internally and is routinely audited to ensure conformity with WORDWIDE procedures and recommended industry standards.

Independent Recourses for Privacy Complaints and Contact Information

In compliance with the Privacy Shield Principles, WORDWIDE commits to resolve complaints about our collection or use of your personal information. To exercise all relevant rights, queries or complaints, please contact:


WORDWIDE

info@beWORDWIDE.com


WORDWIDE is committed to resolve all complaints in timely manner. If you do not receive timely acknowledgment of your complaint from us (to be acknowledged within 45 days of receipt), or if you are not satisfied with our response, or if contacting us does not resolve your complaint, EU individuals may request WORDWIDE to refer unresolved Privacy Shield complaints to, or you may bring a complaint before, the United States Council for International Business (USCIB). The USCIB is the American affiliate of the International Chamber of Commerce, the Business and Industry Advisory Committee to the OECD, and the International Organization of Employers, and has agreed to act as a trusted third party on behalf of the European Union (EU) Data Protection Authorities. Information about how to file a complaint before the USCIB can be found at uscib.org. As a last resort, EU individuals may seek redress through binding arbitration. 

Swiss individuals may request WORDWIDE to refer unresolved Privacy Shield complaints to, or you may bring a complaint before, the Federal Data Protection and Information Commissioner (FDPIC), which serves as the Alternative Dispute Resolution body (ADR) according to the Swiss-US Privacy Shield Framework. The services of this process are provided at no cost to you.

WORDWIDE provides information regarding the below through policies and trainings:

  • WORDWIDE is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC)
  • The possibility, under certain conditions, for the individual to invoke binding arbitration
  • The requirement for your organization to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements
  • WORDWIDE’s liability in cases of onward transfers to third parties

With respect to complaints related to our Privacy Policy that cannot be resolved through our internal process, we agree to abide by the dispute resolution procedures established by the Privacy Shield frameworks.