WTWH can be considered a data controller and processor under the GDPR and as a cloud based company we rely on 3rd parties to process and control data on our behalf. WTWH has chosen vendors that are GDPR compliant and provide the highest standards in data safeguarding, storage and transmission. WTWH designed its platforms and services with built-in data security and privacy services, platform and tools needed to help safeguard sensitive data wherever it resides. WTWH Media implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk. The California Consumer Privacy Act (CCPA) takes effect on January 1st, 2020. This new privacy law requires businesses to disclose how they treat consumers’ personal information if they process information on individuals residing in the state of California. WTWH Media is exempt from the CCPA Act, but adheres to individual requests for information and data removal. WTWH Media also acts as a data processor or ‘service provider’ and the CCPA does not apply to service providers.
We use personal data to process your requests or transactions, provide you with products and services, and inform you about other products or services we think will be of interest. Certain registration information on premium content is shared with our business partners. For example some access to WTWH or other vendors data / content requires secure user registration to download or access information. Also, we use the information we collect to:
Personal data provided on our sites may be linked together or merged with other personal data we obtain about you so that we may better understand your needs and inform you about our products or services and those of our business partners. In addition, if we receive personal data from third parties with whom we have business relationships, we may combine this information with the other personal data we maintain about you. In either case, this Policy governs this information.
We share personal information with third-party vendors who assist us in performing internal functions necessary to operate our business. These functions may include, for example, analyzing data, providing marketing assistance and processing payment transactions. In all cases we limit the information shared with our third-party vendors to that which is necessary to carry out those functions. We also disclose personal data when we believe it is appropriate to comply with the law (e.g., a lawful subpoena, warrant or court order); to enforce or apply this Policy or our other policies or agreements; to initiate, render, bill and collect for amounts owed to us; to protect our or our users’ rights, property or safety; to protect our users from fraudulent, abusive, or unlawful use of, our Site; or if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay. In addition, information about our users, including personally identifiable information, may be disclosed as part of any merger, acquisition, debt financing or sale of company assets, as well as in the event of an insolvency, bankruptcy or receivership in which personally identifiable information could be transferred to third parties as one of our business assets.
WTWH adheres rigorously to all CAN-SPAM legislation and we always make it easy for opt-in recipients to opt-out of any communication sent on behalf of WTWH Media. We utilize 3rd party data processors in our emailing campaigns and those parties have been chosen for their adherence to the same CAN-SPAM legislation and data integrity, safety and security. GDPR requires the easy ‘forgetting’ or deletion of user data and WTWH adheres to accommodating these requests. Due to ensuring those users who globally opt-out of email delivery, a unique identifier – an email only in this case – is still stored with our 3rd party processors to ensure that email as an identifier is not added back into our databases. A user can be added back into our system only if they specifically double opt in via our secure forms to validate the email as owned or authorized by them and then agree to receive communications. All other data associated with a request for deletion will be eliminated from any WTWH system or database.
From time to time, we may update this privacy notice. We encourage you to periodically check back and review this policy so that you always will know what information we collect, how we use it, and to whom we disclose it.