Wawiwa Tech Training - Privacy Policy
Version: September 16, 2020 | You may contact us for previous versions of the Privacy Policy.
In a nutshell:
Wawiwa bridges the tech skills gap by reskilling people for tech professions in high demand.
Like most businesses, we collect and process personal information of our website visitors, business contacts, customers, and partners. We may also process personal information of our partners’ trainees.
It’s our privilege and duty to protect our partners’ data and yours. We respect your rights regarding your personal information.
Have a question and can’t find an answer? Póngase en contacto con nosotros, we’re here to help: info@wawiwa-tech.com
Now in more detail:
1) Introduction and Definitions
We are Wawiwa Tech Training, a brand name and commercial activity of Wawiwa Tech Ltd., an Israeli company – simply referenced here as “Wawiwa”. You can find our contact details below.
Wawiwa bridges the tech skills gap by reskilling people for tech professions in high demand. Wawiwa is a tech education provider from Israel, which establishes local tech training centers with Partners around the world.
Wawiwa may provide its Partners around the world with various technology Platforms for the operations of their training centers, such as a Learning Management System (LMS) or a Vocational Assessment Platform. When our Partners train Trainees in their centers or online and collect Trainees’ personal information, they decide the purposes for which they use Wawiwa Platforms, as well as the means for collecting data. Our Partners control the data processed on their behalf on Wawiwa Platforms and they are responsible under our mutual agreements for handling any data rights and data requests as Data Controllers for their Trainees’ information.
To make things clear with an example: if you are a Trainee at a Wawiwa training center operated by our Partner in your home country, then you are a Trainee, the training center operator is our Partner and has full control over your personal data, and we process your personal data on our Partner’s behalf and according to its instructions. If you’re a Trainee and have any issue regarding your personal information, please contact our Partner – your training center operator – first!
In addition, we also operate several Websites – such as wawiwa-tech.com – and collect personal data of Visitors. Some Visitors and other people who communicate with us, become our business Contacts or Partners. We collect and process various personal information regarding our Visitors, Contacts, and Partners, and we are the Data Controllers for such personal data.
If you are a Visitor, Contact or Partner of ours and have any issue regarding your personal information that we control, please contact us (details below).
2) How Do We Collect Personal Data?
If you’re a Contact or Partner of ours, or a Trainee of a Partner of ours, there might be several ways in which we receive your personal data:
When you share it with us directly, through your communication with us on the Websites’ contact forms, by email, phone, or facsimile, in conferences, meetings, or via any other communication channel, or by using the Platforms.
When other Partners, Contacts, or third parties share your information with us, based on their interaction with you, their purposes, their legal bases, and their privacy policy. In such cases, we take responsibility for controlling only the personal data that we have received.
We might augment the personal data we have about you with information you provided us directly, information others have provided us about you, and data we’ve collected about you from your use of our Websites and Platforms (see below).
If you’re a Visitor to our Websites or a Trainee using our Platforms, we might receive some usage data and personal data through your device, operating system, and browser, and various hosting, tracking, analytics and advertising technologies used on our Websites and Platforms, such as cookies (see below), analytics, and CRM services. Our Websites do not currently respond to “Do Not Track” signals sent by your browser or device.
3) What Personal Data Do We Process?
If you’re a Contact or Partner of ours, we may collect and process these types/categories of personal data about you:
Identification and Account information, such as full name, identification number, gender, profile photo, username and password
Contact details, such as country/time zone, work and home addresses, phone numbers, and email address
Social networking information you’ve shared with us
Work-related information, such as company, division, department, role, and title information
Payment information, such as bank account number, or other billing information
Any personal data contained in any photos, media, and other files sent to us
Any other personal data you provide us on any communication channel, such as email correspondence, customer support, and product feedback.
If you’re a Trainee, our Partners decide what data to collect, by what means, and what data to send Wawiwa in order to help them with operations of their training centers.
These are the types/categories of personal data about Trainees that we may process on Partners’ behalf:
Identification and Account information, such as full name, identification number, gender, profile photo, username and password
Contact details, such as country/time zone, work and home addresses, phone numbers, and email address
Social networking information you’ve shared with our Partners or us
Work-related information, such as company, division, department, role, and title information, interest in various sectors, job roles, and companies; applications for jobs, interview results, and salary levels
Education and skills information, such as academic background, certifications and credentials, skill levels, courses pursued, interest in further learning, test and assignment grades, progress in programs
Any personal data contained in any photos, media, and other files sent to us
Any other personal data our Partners share with Wawiwa
We also collect and process these types/categories of non-identifiable personal data about anyone using our Websites and Platforms:
Usage, logs, analytics, and other device and technical data collected when you use our Websites or Platforms, including device information and identification numbers, operating system information, IP address, browser and session information, browsing history and referrals, cookies information, web beacons, advertising identification numbers, language information, connectivity information, configuration information, metadata of files, and usage information (such as screen views, clicks, and usage time).
4) What About Personal Data of Children?
Wawiwa’s services and Platforms are not intended for children. We do not knowingly collect or process information about children.
Please contact us (contact details below) if you have any concern with respect to Children’s personal data on the Wawiwa Platform.
5) What About Cookies?
A cookie is a small data file that your browser saves on your computer or mobile device. We use cookies to collect information and provide our services. We may use cookies to enable certain features, understand how you interact with us, monitor your usage of our Websites, Platforms, products and services, and personalize your experience and advertising displayed to you. You can set your browser to prevent the use of cookies. If you don’t accept cookies, our Websites and Platforms might not function properly.
6) What Are The Purposes for Processing Personal Data? How Is Your Personal Data Used?
Partners, Contacts, and Visitors
If you’re a Partner, Contact, o Visitor on our Websites, we may process your personal data for our own business purposes, including:
1) Delivering our products and services, improving them, and developing new features, products, and services
2) Providing information about our company, products, and services
3) Providing customer support, billing, and invoicing
4) Contacting you via any communication channel, including email, phone, SMS, and other messaging platforms
5) Analyzing and optimizing traffic and usage of our Websites and the Platform
6) Protecting our company, staff, Partners, Platforms, and systems
7) Online advertising in all forms and channels, including targeting you and others who share similar characteristics as you (lookalikes) online on search engines, websites, apps, messaging platforms, social networking platforms, and offline
8) Direct Marketing in all forms and channels, including email, SMS, messaging, postal service, and more; you can always opt-out from Direct Marketing by unsubscribing yourself through links on any communication or by contacting us and notifying us accordingly.
Wawiwa Platforms
The purposes for the processing of personal data on Wawiwa Platforms are determined by our Partners. Each Partner might use the Platforms for different purposes. Such purposes might include managing the Trainee records and instructor records; delivering their products and services, such as the delivery of the training programs online, live and on-demand; assessing potential Trainees’ skills and fit for tech training programs and future job roles; providing information, support, or otherwise communicating with Trainees, instructors, mentors and others; and more.
If you’re a Trainee, we collect and use your personal data to provide our services to our Partners, according to their instructions and settings, so they can achieve their respective purposes. We do not sell personal information of our Partners’ Trainees to third parties.
Our purpose in processing aggregated, non-identifiable data on Wawiwa is to provide our services to the Partners according to our agreements with them and applicable law. We also make use of the data collected on the Platforms and through Wawiwa’s services to ensure our products and services are working as intended; to analyze, measure and understand how our services are used; to improve our products and services; to develop new features, products, and services; to protect our company, staff, Partners, and Platforms; and to comply with any applicable law and assist law enforcement agencies under any applicable law.
We may use anonymous, statistical or aggregated information collected on the Platforms, in a form that does not enable the identification of a specific user, by posting, disseminating, transmitting or otherwise communicating or making available such information to any third party.
We also process usage and analytics information, as well as some statistical and aggregate data derived from personal data, for the improvement and further development of the Platforms or for research purposes.
7) What Is The Legal Basis For The Processing of Data?
Partners, Contacts, and Visitors
As Data Controllers for our Partners, Contacts and Visitors’ personal data, we process personal data based on any or some of the following legal bases:
- The data subject has given us consent to the processing of his or her personal data for specific purposes communicated in this policy;
- Processing is necessary for the performance of a contract to which the data subject is party – for example, a partnership agreement with us or the Terms of Service of the Websites – or in order to take steps at the request of the data subject prior to entering into a contract;
- Processing is necessary in order to protect the vital interests of the data subject or of another natural person, for example protecting our Partners’ management and our staff; or for the establishment, exercise, or defense of legal claims;
- Processing is necessary for compliance with a legal obligation to which we are subject, for example the need to maintain billing records for transactions;
- Processing is necessary for the purposes of the legitimate interests pursued by us, or our Partners, for example the conduct of our business, the development and delivery of our products and services, and the promotion and sales of such products and services.
Wawiwa Platforms
Our Partners are the Data Controllers for the personal data we process on their behalf on the Platforms. Partners process data based on any or some of the following legal bases:
Processing is necessary for the performance of a contract to which the data subject is party (for example, the agreement with Partners to undergo tech training) or in order to take steps at the request of the data subject prior to entering into a contract;
The data subject (Trainee) has given consent (for example, upon log in to the Platform) to the processing of his or her personal data for specific purposes communicated by the Partner in its respective Privacy Policy.
Processing is necessary for the purposes of the legitimate interests pursued by our Partner or by a third party, for example: providing their services, etc.
As Data Processors, we process personal data on the Platform based on the following legal bases:
Processing is necessary for the performance of our contracts with our Partners;
Processing is necessary for compliance with a legal obligation to which we are subject as data processors, for example data protection and privacy regulation;
Processing is necessary for the purposes of the legitimate interests pursued by us, such as the conduct of our business and the purposes for which we process personal data as detailed in this Privacy Policy;
The data subject (Trainee) has given us consent, through the Partner website, our Websites, the Platforms, or otherwise, to the processing of his or her personal data for the specific purposes communicated in this policy.
8) Who Is Your Information Shared With?
Partners, Contacts, and Visitors
We process your details on our servers, computers, and systems; cloud hosting services; CRM services; team collaboration services; billing systems; email and SMS communication services; and backup systems. We may share some of your details with our staff, subsidiaries, affiliates, contractors, consultants, resellers, and other third-party business partners for research and analysis, cooperation opportunities, joint promotions, sales, and events.
Wawiwa Platforms
For the delivery of our services, we share all Trainee and data on the Platforms with the Partner who is the Data Controller with respect to such data. Our Partners may select to share the information with others, as stated in their respective Privacy Policies.
Everybody
We may share data with our staff, subsidiaries, affiliates, and contractors for the provision of our services and our operations.
We use additional processors around the world for various processing activities needed for the performance of our Websites, the Platforms, our Services, our operations, and our business, and share information with such processors on a need basis. Such processors include hosting and backup providers (such as Intechgrade T.G Ltd.), analytics providers (such as Google, Hotjar), website technology (such as WordPress and WordPress plug-ins), advertising technology (such as Google, Facebook, LinkedIn, Taboola, Outbrain), communication services (such as Microsoft 365, Mailchimp), team collaboration tools (such as Trello), CRM services (such as PowerLink), Assessment tools (such as Veritas), LMS (such as Blossom), telecommunication services, security technology, and more. We limit the information we share with each processor based on the business need in using such a processor, to protect your information while still effectively benefiting from the services of such processor.
We may also share non-personally identifiable information and aggregate information for any purpose. Such data is not personal data, and its sharing cannot be used to identify you.
We may need to share your information with law enforcement agencies, courts of law, and other governmental organizations, if ordered to do so by competent bodies and according to applicable law.
Mergers and Acquisitions
If we are involved with a merger, asset sale, financing, liquidation, bankruptcy, or the acquisition of all or part of our business to another company, we may share your information with that company and its advisors before and after the transaction date.
9) How Do We Safeguard Your Personal Data?
We take information security very seriously. We implement the state of the art security standards to prevent unauthorized or excessive access, maintain data accuracy, and ensure the correct use of information. We encrypt all major data communication transmissions to avoid interception and securely backup the information on the Platforms to avoid data loss. We also implement appropriate organizational measures to protect your information.
We apply our security standards also when working with business and technology partners. We only select and contract with processors and third parties who use appropriate security measures and provide sufficient guarantees, including technical and organizational measures, to ensure the appropriate protection of the data we entrust with them. Unfortunately, although we make every effort to keep your data safe, we cannot fully ensure or warrant the security of your personal information.
10) Do We Transfer Personal Data Internationally?
Most of our information is stored over the cloud in Israel. Our management, sales, marketing, and customer support are also located in Israel.
At the same time, our business is international – we serve Partners that operate training centers around the world and make use of our services and the Platforms, and we utilize additional processors and service providers in various countries. Therefore, we transfer, store or otherwise process your personal information in other countries. We take appropriate safeguards in the selection of our processing vendors around the world to require that your personal information is well protected. Despite our efforts, it may be the case that a country where your personal information is processed has different, or less protective, data protection and privacy regulation than the country you live in.
11) For How Long Do We Keep Personal Data?
We keep personal information we collect for different periods, depending on the type of information, for example: the period of our contract with our Partners, legal requirements regarding certain types of data, and other factors. Generally speaking, we will retain your personal information for a period reasonably needed to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. We will also retain your personal information for as long as necessary to resolve disputes, enforce our rights and agreements, and protect our staff and Partners.
If we no longer need your information for the purposes mentioned in this Privacy Policy, we will delete or anonymize it. On certain occasions we might not be able to fully delete or anonymize your personal information due to technical or operational reasons, for example deleting from backup storage and archives. In such cases, we shall take reasonable measures to secure any information still maintained by us according to our standard data security practices.
Please be aware that our Partners may also retain on their own systems and computers copies of personal data collected through the Platforms, even after we completed the provision of our services, ended our contractual relationships, and deleted or anonymized any data related to Partners’ Trainees on the Platforms. Such data retention by Partners is subject to their Privacy Policy, purposes, legal bases, agreements with data subjects, and any applicable law. We take no responsibility over Partners’ use of personal data outside of the Platforms.
12) What Are Your Rights With Respect to Your Personal Data?
If you’re a Trainee using the Platforms as part of a Partner program, please approach such Partner to exercise any rights you may have, as they are the Data Controllers of your personal information. Otherwise, please contact us (details below).
According to the data protection and privacy regulation where you live, you may have certain rights with respect to your personal information.
Your rights may include, under certain terms and conditions set in the EU General Data Protection Regulation (GDPR), or other applicable law:
Right of Access to your personal data processed by us;
Right to Rectification of inaccurate or incomplete personal data;
Right to Erasure of your personal data (“Right to be Forgotten”);
Right to Restriction of Processing for a certain period or under certain conditions;
Right to Data Portability of your personal data to another data controller in a structured format;
Right to Object the processing of your personal data. Specifically, you have the right to object further processing of your personal data for direct marketing purposes;
Right to Opt-Out from the Sale of your personal data – to opt-out, please contact us;
Right Not To Be Subject to a Decision Based Solely on Automated Decision-Making. We do not make any decisions with legal effect based on automated decision-making; our Partners using the Assessment Platform to evaluate a candidate’s fit to specific tech programs also do not make decisions solely based on the Assessment’s results, but rather defer the decision to the candidate and a human manager at the training center.
Right Not To Be Discriminated Against for exercising Privacy rights;
Right to File a Complaint with the applicable data protection authority in your country.
After deletion or anonymization of your personal data following its retention period, the rights to access, erasure, rectification, and data portability cannot be enforced.
Your personal information is processed based on several legal bases, sometimes including your consent. You can withdraw your consent at any time. Other legal bases, including statutory or contractual requirements that apply to you or our Partner might remain intact even following the withdrawal of your consent.
13) Do We Ever Change Our Privacy Policy?
Occasionally, we change this Privacy Policy to accommodate product and service development, industry standards, or new regulation. If we have your contact details, we will let you know personally if such changes are material, and seek consent for the updated Privacy Policy where required and as needed.
Please read the latest Privacy Policy available here from time to time. Note that we may require your consent to our up-to-date Terms of Service and Privacy Policy whenever you use our Websites or the Platforms. If you do not agree to these terms and policy, please do not use our services.
14) Who Can You Contact Regarding Your Personal Data?
If you’re a Trainee using the Platforms, please contact our Partner first with any issue, as they are the Data Controllers of your personal information.
When you contact us to exercise your rights, we will verify your request and identity. Depending on your residence, you might be able to designate an authorized agent to exercise these rights on your behalf, but we will require proof that the agent is authorized to act on your behalf and may also still ask you to verify your identity with us directly.
You can contact us with any question or concern you have at:
Wawiwa Tech Ltd.
A company incorporated in the State of Israel, company ID# 516158623,
12 Grofit St., Ramat Efal, Ramat Gan, Israel
Email: info@wawiwa-tech.com