Webelectrix Events Privacy Notice

Last updated: 26th June 2023

This is the Privacy Notice for Webelectrix (BulaSoft), Ltd. (“Webelectrix (BulaSoft) Ltd”, “us”, or “we”). Any terms we use in this Privacy Notice without defining them have the definitions given to them in the Terms of Use. We encourage you to read this Privacy Notice carefully to understand how we collect and use your information. If you have questions about our privacy practices or would like to make a complaint, please contact us at privacy@webelectrix.com.

1. CONSENT

Your use of our Services is conditioned on your consent to this Privacy Notice, including all applicable limitations on damages and the provisions regarding resolution of disputes. BY ACCESSING OR USING OUR SERVICES, YOU ACCEPT AND CONSENT TO THIS PRIVACY NOTICE. If you do not agree with this Privacy Notice, do not use our Services. We may provide additional, separate notices about our privacy practices, each of which will be considered to form part of this Privacy Notice.

2. SCOPE

This Privacy Notice describes how Webelectrix collects and treats information when you use our mobile application `Webelectrix Events` (the “App”), and through your interactions with Webelectrix by any means (collectively, our “Services”). This Privacy Notice also provides information specific to residents of California, Canada, and the European Union. Note that this Privacy Notice DOES NOT apply to information collected via a third-party websites or platforms. Webelectrix has no control over third-party privacy practices.

3. PERSONAL INFORMATION

As used in this Privacy Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, such as:

  1. Identifiers (e.g., name, email address, username, phone number, IP address)
  2. Protected Information (e.g., race, citizenship, marital status, sex)
  3. Biometric information (e.g., health data, gait or physical movements, face/voice prints) and audio, electronic, visual, thermal, olfactory, or similar information;
  4. Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
  5. Employment-related information (e.g., current or past employment);
  6. Non-public educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);
  7. Sensitive Personal Information (e.g., social security or government identification number; precise geolocation; racial or ethnic origin; religious beliefs; biometrics; health information; information related to sex life or sexual orientation; union membership; contents of mail, email or text messages when we are not the recipient);
  8. Internet activity (e.g., interactions with a website, content, or advertisement); or
  9. Inferences drawn from Personal Information to create a profile about preferences, characteristics, trends, predispositions, behaviour, attitudes, intelligence, and aptitudes.

Personal Information does not include (a) publicly available information; (b) aggregated information, meaning data about a group or category of services or users from which individual identities and other Personal Information has been removed; or (c) de-identified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer.

4. CHILDREN'S PRIVACY

Webelectrix recognises the need to provide additional privacy protections for children. We do not knowingly collect Personal Information from children under age 16 without consent from the child’s legal guardian. If we discover that a child has provided us with Personal Information without legal guardian consent, we will delete their information from our systems. Please contact us at privacy@webelectrix.com if you believe we might have collected a child’s information online without legal guardian consent.

5. COLLECTION AND USE OF PERSONAL INFORMATION

Webelectrix collects your Personal Information (a) when applicable, with your consent; (b) if we have a legitimate interest in doing so; or (c) as authorized or required by law. We only collect, use, retain and share Personal Information as reasonably necessary and proportionate to achieve our purposes, or for other purposes that we disclose to you and are compatible with the context of how we collected the Personal Information. Webelectrix collects Personal Information in the categories of identifiers, protected personal information, and your internet and similar activity. We collect this information from sources and for purposes described below:

  1. Your registration and use of the App, with your consent. If using the App with provided login details or an event code, you must download the App and set up your profile by providing identifiers such as a username and or an event code. We collect this information from you with your consent, and we use it to identify leads that you may collect. If you do not have an event code or login no personal information will be collected by Webelectrix.
  2. Your use of the App or the Site, with a legitimate interest. Webelectrix may automatically collect technical data about your use of the App or interactions through the Site, such as your device information for technical use (bug fixing).

6. DISCLOSURE OF PERSONAL INFORMATION

We may disclose information to the following recipients for a business purpose:

  1. Law Enforcement. We reserve the right to disclose your Personal Information to law enforcement or other government agencies as permitted or required by law.
  2. Other Third Parties. Webelectrix may disclose your Personal Information to other third parties in certain circumstances as permitted by applicable law, for example: (i) if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); (ii) to comply with a legal requirement or a court order; (iii) when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; (iv) to exercise or defend our legal claims; or (v) for any other reason with your consent.

7. RETENTION OF PERSONAL INFORMATION

Where applicable, Webelectrix retains Personal Information, collected as part of your use of the App, for 30 days. You may request request to have your account deleted at any point, any Personal Information will be immediately de-associated with the account and deleted. We may keep a record of your account deletion and system logs for up to 30 days following your deletion of an account. Webelectrix reserves the right to retain data from closed and deleted user accounts as needed to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our terms and conditions and take other actions permitted by law. All data is only retained as long as it is necessary and relevant to our operations, after which the data is de-identified and/or securely deleted.

8. YOUR PRIVACY RIGHTS

This section describes the variety of methods and options Webelectrix provides to directly control how we collect and use your Personal Information. Depending on where you reside, you may have additional privacy rights or be entitled to other controls over your Personal Information. Please see our supplemental notices specific to residents of California, the European Union, and Canada.

  1. Your Account. If you would like assistance deleting and deactivating your account, please contact privacy@webelectrix.com. Once deactivated, your account data cannot be reinstated.
  2. Consumer Privacy Requests. If you wish to exercise your privacy rights beyond the methods described above, or if you want to express concerns, lodge a complaint, or request information, please submit a request via our Consumer Privacy Request by email to privacy@webelectrix.com. We can only fulfil a request when we have sufficient information to verify that the requester is the person or an authorized representative of the person about whom we have collected Personal Information, and to properly understand, evaluate, and respond to the request. We endeavour to respond to Consumer Privacy Requests in accordance with the requirements of the law applicable to your jurisdiction, subject to statutory exceptions and limitations. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so. If we determine that the request warrants a fee, we will tell you why and provide you with a cost estimate before completing your request.

9. CALIFORNIA PRIVACY RIGHTS

This section provides residents of the State of California (“California Consumers”) with the disclosures and notices required under the California Consumer Privacy Act of 2018 (“CCPA”). NOTE THAT WEBELECTRIX IS NOT CURRENTLY GOVERNED BY THE CCPA. This section is included as a courtesy to describe the rights afforded to California Consumers under the CCPA:

  1. Right to Know. You have the right to request that we disclose information to you about our collection and use of your Personal Information, such as: (i) the categories of Personal Information we have collected about you; (ii) the categories of sources for the Personal Information we have collected about you; (iii) our business purpose for collecting and disclosing Personal Information; (iv) the categories of third parties with whom we disclose Personal Information; and (v) the categories of your Personal Information we have sold or shared for cross-contextual behavioural advertising purposes, and to whom that information was sold or shared. Webelectrix is only required to respond to two disclosure requests within a 12-month period.
  2. Right to Access. You have the right to request that we provide you with access to specific pieces of Personal Information we have collected about you over the past 12 months. If you submit a right to access request, we will provide you with copies of the requested Personal Information in a portable and readily usable format. Please note that Webelectrix may be prohibited by law from disclosing copies of certain Personal Information when the disclosure would create a substantial, articulable, and unreasonable risk to the security of the information, our systems, or your account. We are only required by law to respond to two access requests from you within a 12-month period.
  3. Right to Correct. If you discover that we maintain inaccurate Personal Information about you, or if your Personal Information changes, please inform us and we will update our records to reflect the correct information.
  4. Right to Deletion. You have the right to request that we delete Personal Information that we collected from you and retained, with certain exceptions. We may permanently delete, de-identify, or aggregate the Personal Information in response to a deletion request. If you submit a deletion request, we will confirm the Personal Information to be deleted prior to its deletion, and we will notify you when your request is complete.
  5. Right to Opt-out of Sale or Sharing Personal Information. Webelectrix does not sell your Personal Information or share any Personal Information with third parties for cross-contextual behavioural advertising purposes. You can opt-out of such sharing of your Personal Information at any time by changing your device settings to block marketing and analytics cookies or by contacting us at privacy@webelectrix.com.
  6. Limited Use and Disclosure of Sensitive Personal Information. Webelectrix does not use or disclose your Sensitive Personal Information for the purpose of inferring characteristics about you. If this ever changes in the future, we will update this Privacy Notice and provide you with methods to limit use and disclosure of Sensitive Personal Information.
  7. Right to Non-discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by law, we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services; (iii) provide you a different level or quality of goods or services; or (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised a right under the CCPA.
  8. Right to Disclosure of Marketing Information. Under California’s Shine the Light Act (Ca. Civ. Code § 1798.83-1798.84), California Consumers are entitled to request certain disclosures about Personal Information sharing with affiliates and/or third parties for marketing purposes. Please contact us if you wish to obtain these disclosures.

Webelectrix is not governed by the CCPA. If this changes in the future, we will update this Privacy Notice and California Consumers will have the right to exercise these rights over their Personal Information. At this time, California Consumers may take many of the actions described above by logging into their App account and changing profile information or settings.

10. EUROPEAN UNION PRIVACY RIGHTS

Webelectrix adopted this section to comply with the European Union’s General Data Protection Regulations (“GDPR”). This section applies solely to residents of the European Union (“EU Residents”). Webelectrix offers the Services to EU Residents in our role as a data controller. If you are an EU Resident, you have the following rights over the Personal Information we collect about you:

  1. Right to Know. You have the right to know how we process your Personal Information. We have set the required notices in this Privacy Notice. We may provide you with additional notices about other ways we process your Personal Information, such as by sending you a notice via email or by other means of communication.
  2. Right to Access. You have the right to access your Personal Information. Upon request, we will provide you with a copy of your Personal Information, along with details about the types of Personal Information we process, why we process it, and any third parties we work with to collect Personal Information on our behalf. We may have one or more legally valid reasons to refuse your request in whole or in part, for example to protect the rights of other individuals.
  3. Right to Restrict Processing. You have the right to restrict processing of your Personal Information. You can request that we restrict the processing of your Personal Information if (i) the data is inaccurate, (ii) the processing is unlawful, (iii) we no longer need the Personal Information, or (iv) you exercise your right to object.
  4. Right to Rectify your Personal Information. If you become aware that the Personal Information that we hold about you is incorrect, or if your situation changes (e.g., you change address), please inform us and we will update our records.
  5. Right to Data Portability. In some circumstances, we are required to provide your Personal Information to another organization at your request and in a structured, commonly used machine-readable format, so that the other organization can read and use it.
  6. Right to Erasure (a.k.a. the "Right to be Forgotten"). Upon your request, and in certain circumstances and where we are required to do so by law, we are required to delete your Personal Information. This right is not absolute, and we may be entitled to retain and process your Personal Information despite your request. If you make this request, we balance certain legal, contractual, and business interests against your right to request the deletion of your Personal Information.
  7. Right to Object. You have the right to object to certain processing of your Personal Information. Upon your request, and in certain circumstances and where we are required to do so by law, we will limit our processing of your Personal Information as you request.
  8. Right to not be subject to automated decision-making. The Services do not process your Personal Information in a manner that produces a decision based solely on automated processing that produces legal effects concerning you or that similarly significantly affects you.

EU Residents may take many of the actions described above by logging into their App account and changing profile information or settings, or by submitting a Consumer Privacy Request by following the instructions under Your Privacy Rights.

11. CANADIAN PRIVACY RIGHTS

We adopted this section to provide supplemental information in compliance with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”). This section applies solely to residents of Canada where PIPEDA applies (“Canadian Consumers”). PIPEDA gives Canadian Consumers specific rights regarding Personal Information offering details on an identifiable person without the inclusion of name, title, telephone number and business address of an employee of a business or organization. The following paragraphs describe PIPEDA rights and explain how to exercise those rights.

  1. Right to Know. You have the right to know why we collect, use, and distribute the Personal Information we process. We have set the required notices in this Privacy Notice. We may provide you with additional notices about other ways we process your Personal Information, such as by sending you a notice via email or by other means of communication.
  2. Right to Expect. You have the right to expect us to collect, use or disclose Personal Information responsibly and not for any other purpose other than which you consented. We set your expectations in this Privacy Notice and collect express or implied consent at various stages of collection or processing. If we collect or use your Personal Information based on your consent, we will also notify you of any changes and will request your further consent as needed. You can withdraw your consent at any time with reasonable notice by contacting us at .
  3. Right to Accuracy. You have the right to the accuracy of your Personal Information. We take steps to reasonably ensure that your Personal Information we are using is accurate. In most cases, we rely on you to ensure that your information is current, complete, and accurate. We provide methods for you to correct, update, and delete inaccurate Personal Information in your account, and we will provide you with reasonable assistance to ensure that your Personal Information is accurate in our systems and with our service providers.
  4. Right to Access. Upon written request and identity authentication, we will provide you with your Personal Information under our control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We will make the information available within 30 days or provide written notice where additional time is required to fulfil the request. If limited by law or potential infringement on another’s privacy rights, we may not be able to provide access to some or all of the Personal Information you request. If we must refuse an access request, we will notify you in writing, document the reasons for refusal and outline further steps that are available to you.

Canadian Consumers may exercise these rights over their Personal Information by logging into their App account and their information or settings, or by submitting a verifiable Consumer Privacy Request as described under Your Privacy Rights.

14. DATA SECURITY

We implement reasonable and appropriate security procedures and practices to help protect your Personal Information from unauthorized or illegal access, destruction, use, modification, or disclosure. Webelectrix encrypts data using industry standard Transport Layer Security (TLS) technology and stored on secure servers. Please note, however, that no transmission of data over the Internet or mobile platforms is 100% secure, and we cannot guarantee that unauthorized third parties will not defeat our security measures or use your Personal Information for improper purposes. The security of your Personal Information also depends on how you use the App. We encourage you to take steps to safeguard your Personal Information by signing off your device after use and keeping your login and password private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized activity.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Notice from time to time. If we make material changes to how we treat your Personal Information, we will post the revised Privacy Notice on this page. The date that this Privacy Notice was last revised is identified at the top of the page. Your continued use of the Services after we make changes is deemed to be your acceptance of those changes. You are responsible for periodically visiting this Privacy Notice to check for any changes.