PRIVACY NOTICE

Introduction

Welcome to Wearisma Limited’s (“Wearisma”) privacy notice for Wispr http://wispr.app/privacy.html.

Wispr is a website and app developed by Wearisma that seeks to allow organisations (referred to as "Brands" in this privacy notice) to store, organise and group their social media mentions, in which the WISPR user’s business social media account(s) is or are tagged by other social media users, as well as the social media usernames of the social media users who tagged the WISPR user’s business social media accounts (“social media mentions data”) and provides a tool to create reports on how the mentions have been engaged with.

In this privacy notice, references to "Wispr" are referring to the storing service used to save and group “social media mentions data”. References to "Source Pages" are to those pages that Wearisma obtains social media mentions data from such as Instagram.

Wearisma respects your privacy and is committed to protecting your social media mentions data. This privacy notice will inform you as to how we look after this data that is obtained via Wispr.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Wearisma collects and processes this social media mentions data that is obtained via Wispr. This website and the services offered by Wearisma are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing the social media mentions data about your business social account(s) so that you are fully aware of how and why we are using your data together with our Terms of Use. This privacy notice supplements the other notices and is not intended to override them.

Contact details

Our full details are:

Full name of legal entity: Wearisma Limited

Company number: 09327823

Email address: help@wearisma.com

Postal address: 146 New London Road, Chelmsford, Essex, CM2 0AW

Telephone number: +44 203 286 4002

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 30 January 2022.

It is important that the data we hold about your social media mentions data is accurate and current. The information Wearisma holds is collected via Wispr from the Source Pages. If any information about you is incorrect, then you should check the data about you on Source Pages is correct in addition to letting us know.

2. The data we collect about you

We may collect, use, store and transfer different kinds of data about you via Wispr which we have grouped together as follows (“your social media mentions data”):

Identity Data includes your brand’s username or similar identifier and social media handles.
Social Media Mentions Data includes username or similar identifier of the social media platform users who has tagged your brand’s business username in their social media content, which can include social media posts, image captions, video titles and timestamps, and number of likes and comments.

3. How is your data collected?

We use the following method to collect data from and about you::

Wispr Integration: We will principally gather your social media mentions data via Wispr via an authentication method in which you grant the social media platforms the explicit permission to share your social media mentions data with WISPR.

4. How we use your data obtained via Wispr

We will only use your social media mentions data when the law allows us to. Wearisma’s main business is helping you identify social media publishers to work with. As such, we will use your social media mentions data in the following circumstances:

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Where we need to perform the contract we are about to enter into or have entered into with you.

Please see the Glossary at section 10 to find out more about the types of lawful basis that we will rely on to process your social media mentions data.

Generally, we do not rely on consent as a legal basis for processing your social media mentions data. You have the right to withdraw consent at any time by contacting us or removing our access to the Wispr application.

5. Purposes for which we will use your social media mentions data obtained via Wispr

We have set out below, in a table format, a description of all the ways we plan to use your social media mentions data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your social media mentions data for more than one lawful ground depending on the specific purpose for which we are using such data. Please contact us if you need details about the specific legal ground we are relying on to process such data where more than one ground has been set out in the table below. As we also aggregate data from publicly available sources, it may be that we do not have a contract with you and we are relying on the basis of processing of it being necessary for the purposes of legitimate interests pursued by us, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

PURPOSE/ACTIVITY	TYPE OF DATA	LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
To manage our relationship with you which will include notifying you about changes to our terms or privacy policy	Identity Contact	Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Social Media Mentions Data Technical Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Social Media Mentions Data Technical Usage Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

Change of purpose

We will only use your social media mentions data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your social media mentions data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your social media mentions data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your social media mentions data

We may have to share your social media mentions data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your social media mentions data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your social media mentions data and to treat it in accordance with the law. We do not allow our third-party service providers to use your social media mentions data for their own purposes and only permit them to process your social media mentions data for specified purposes and in accordance with our instructions.

6. International transfers

We share your social media mentions data within the Amazon Web Services (AWS). This may involve transferring your data outside the European Economic Area (EEA).

Whenever we transfer your social media mentions data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your social media mentions data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your social media mentions data out of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your social media mentions data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your social media mentions data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your social media mentions data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you store my social media mentions data for?

We will only retain your social media mentions data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for your social media mentions data, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of your the data, the purposes for which we process your social media mentions data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your social media mentions data are available in our retention policy which you can request from us by contacting us.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your social media mentions data (or to exercise any of your other rights). This is a security measure to ensure that your social media mentions data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your social media mentions data for our legitimate interests. We do not use your social media mentions data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your social media mentions data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your social media mentions data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

Service providers acting as processors based in the United Kingdom and/or Ireland who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.