Wild Mouse Privacy Statement

Introduction

This privacy statement applies to any processing of personal data for applications using Wild Mouse’s software platforms – Unearth AI, Xmouse Live and PDX.

Personal data in this regard shall mean any information relating to an individual who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

Processing shall mean any operation which is performed on personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

What and how we process your personal data

When you log into our products, we will automatically gather and store certain information (i.e., your email address, IP address, device type, the browser used, the date and time of visit, pages visited, information accessed, and functions used).

This information is used to improve the information you receive, is used to ensure you should have access to information delivered and, in some case, to calculate billing of the system you are using.

In some cases, we explicitly request personal information such as your address to use in completing purchases and shipping products to you.

In some cases, we explicitly request that you provide profile information such as avatars, usernames, and text about you.

Within our products we will be able to identify you so that we can give you access to the correct information within the respective products. The legal basis for this processing activity is Article 6 (1) 1 lit. b of the European General Data Protection Regulation (“GDPR”), as we will generally grant you access when a contract shall be executed or if we envisage to enter into a contract.

Log Files

Wild Mouse is collecting log files when using the applications to determine error situations and measure application performance and reliability.

Legal basis for this processing is Article 6 (1) 1 lit. f GDPR as it is our and the customer’s legitimate interest to get to know how their data is used.

Automated decision making

Data collected from and about you can be used in the following ways in automated decision making:

· To deliver content to you that our algorithms determine you will be more interested in viewing or accessing, such as search results in Unearth AI and articles and videos in Xmouse Live. In some cases, specifically when using Xmouse Live, this may include advertising.

Recipient of your personal data

Your personal data will be disclosed to the following parties in the following products:

Xmouse Live:

· Profile information provided by you will be viewable by other users of the system.

· Personal information may be available to organisations that are essential for completing transactions such as eCommerce fulfilment providers.

Unearth AI:

· Your personal data may be transferred to other users and entities of your organisation where information about you that may have been ingested and can be queried by staff with the correct access rights.

· Your personal data may be transferred to other users in your organisation when you share information or otherwise communicate with other users through the Unearth AI platform.

PDX:

· Profile information provided by you will be viewable by other users of the system.

· Your personal data may be transferred to other users when you share information or otherwise communicate with other users through the Unearth AI platform.

Third party recipients 

We engage third party companies and individuals who assist us in providing our services and products or support us with certain functions of these applications. Your personal data will be shared with the following categories of third parties and partly their sub-processors:

· Microsoft is our service provider for Azure, Azure AD and Office 365. Please read their information practices at  Microsoft Privacy statement .

· For Xmouse Live: Shopify is our service provider for the eCommerce platform. Please read their information practices at Privacy for Users of Shopify Apps .

The legal basis for this data transfer and processing activity is Art. 28 GDPR in conjunction with the data processing agreements we concluded with respective third-party companies. Therefore, our contractors will only use your personal data to the extent necessary to perform their functions and will be contractually bound to process your personal data only on our behalf and in compliance with our requests.

We may disclose your personal data if legally entitled or required to do so (for example if required by law or by a court order). The legal basis for this processing is Art. 6 (1) 1 lit. c GDPR.

International data transfer

Within the scope of our information sharing activities set out above, your personal data may be transferred to other countries which may have different data protection standards than your country of residence. Please note that data processed in a foreign country may be subject to foreign laws and accessible to foreign governments, courts, law enforcement, and regulatory agencies. However, we will endeavor to take reasonable measures to keep up an adequate level of data protection also when sharing your personal data with such countries.

The following are known instances where information may be transferred to other countries:

Xmouse Live:

o eCommerce transaction information, including your name and address, with Shopify Inc.

o Your personal details that may be accessed by our customer – the company that is operating the Xmouse Live-branded application you may be using.

Unearth AI:

o Your personal details and other information may be accessed across country borders if your organisation is multi-national.

PDX:

o Your personal details and other information may be accessed across country borders if you are transferring information with a hospital in another country.

In the case of a transfer outside of the European Union, this transfer is safeguarded by the EU Standard Contractual Clauses. You can find further information about the aforementioned safeguards under: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en .

Retention periods

We strive to keep our processing activities with respect to your personal data as limited as possible. In the absence of specific retention periods set out in this policy, your personal data will be retained only for as long as we need it to fulfil the purpose for which we have collected it and, if applicable, as long as required by statutory retention requirements.

Security

We take market standard precautions to protect personal data. When our download form asks users to provide personal data, that personal data is encrypted and is protected with technology such as SSL in transit and encrypted storage. While on a secure page, the lock icon in web browsers is present. 

Unfortunately, no data transmission or processing can be guaranteed to be 100 % secure. Accordingly, despite our efforts to protect the personal data, Wild Mouse is not in a position to guarantee or warrant the security of the personal data.

Data subjects’ rights

You may be entitled to exercise some or all of the following rights free of charge: 

a. require

(i) information whether your personal data is retained and

(ii) access to and/or

(iii) duplicates of your personal data retained, including the purposes of the processing, the categories of data concerned, and the recipients or categories of recipients to whom the data are disclosed and where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; 

b. request proper rectification, removal or restriction of your personal data, e.g. because

(i) of the incomplete or inaccurate nature of the personal data,

(ii) it is no longer needed for the purposes for which it was collected,

(iii) the consent on which the processing was based has been withdrawn, or

(iv) you have taken advantage of an existing right to object to the data processing; in case your personal data is processed by third parties, we will forward your request for rectification, removal or restriction also to such third parties unless this proves impossible or involves disproportionate effort; 

c. receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit those data to another controller without hindrance from our side; where technically feasible you shall have the right to have the personal data transmitted directly from us to another controller, 

d. refuse to provide and – without impact to data processing activities that have taken place before such withdrawal – withdraw your consent to processing of your personal data at any time;

e. object at any time that your personal data will be used for direct marketing purposes, or – based on grounds relating to your particular situation, that your personal data shall be subject to data processing for other purposes; 

f. not to be subject to any automatic individual decisions (automatic decisions based on data processing by automatic means, for the purpose of assessing several personal aspects) which produce legal effects on you or similarly significantly affect you; 

g. take legal actions in relation to any breach of your rights regarding the processing of your personal data, as well as to lodge complaints before the competent data protection regulators.

Revision of the Privacy Statement

Wild Mouse may change or update the privacy statement without notice. All such changes will take effect once they have been posted. It is your responsibility to monitor such updates. The privacy statement was last updated on the date stated at the beginning of this privacy statement.

Contact Details

If you are concerned about use of the data or have any questions regarding this privacy statement, please contact privacy@wildmouse.com. Wild Mouse regrets that only general queries about the privacy statement can be responded to via e-mail.