Last updated: July 25, 2018
This Policy applies to all MeWe’s operating divisions, subsidiaries, affiliates, and branches and any additional subsidiary, affiliate, or branch of MeWe that we may subsequently form. All individuals whose responsibilities include the Processing of Personal Information on behalf of MeWe are expected to adhere to this Policy. This Policy is intended to meet requirements globally, including those in North America, Europe, Asia, and other jurisdictions.
Personal Information We May Collect and How We Use It
MeWe collects Personal Information regarding its current, prospective, and former clients, customers, and users (collectively “Individuals” or “you”). The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with MeWe and the requirements of applicable law. We endeavor to collect only that information which is relevant for the purposes of Processing.
Personal Information Collected
Information You Provide Directly to Us
When you use MeWe Services or engage in certain activities, such as registering for an account with MeWe, “following” or “becoming a fan,” posting content via MeWe Services, requesting services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
• Contact information, such as name, email address, telephone or mobile number, and address;
• Username and password;
• Location information as provided by your device or browser, such as your device’s GPS signal or information about nearby WiFi access points;
• Demographic information, such as your gender, ZIP code, and details about your personal preferences, interests, and characteristics;
• Payment information, such as credit card number, expiration date, and credit card security code, where needed to complete a transaction; and
• Requests and other correspondence you send to us.
MeWe does not use or disclose sensitive personal information such as race, religion, or political affiliations without your explicit consent. Additionally, in some cases MeWe is obligated to collect certain Personal Information to comply with regulatory requirements. You can choose not to provide information to us directly, but some of this information is required to participate in some of the MeWe Services, and some MeWe Services may not function properly if you choose not to provide the information requested.
Information We Collect Automatically
We may collect certain information automatically through our services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile advertising identifiers, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the services, and other actions taken through use of MeWe Services.
For Information Submitted Via MeWe Services
You agree that MeWe is free to use the content and metadata of any communications submitted by you via the MeWe Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or MeWe Services. MeWe can, but has no obligation, to monitor your Content you post on MeWe Services and may remove any Content you post for any reason and for no reason. MeWe will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a MeWe Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
• Sharing Content with Friends or Colleagues. MeWe Services may offer various tools and functionality. For example, MeWe may provide functionality on its MeWe Services that will allow you to forward or share certain content with a friend or colleague. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by MeWe or any other Third Parties for any other purpose.
• For Other Uses. MeWe may use Personal Information for other purposes disclosed to you at the time you provide Personal Information or with your consent.
Information We Obtain from Other Sources
MeWe may collect information about you from Third-Party sources to supplement information provided by you. This supplemental information allows us to verify information that you have provided to MeWe and to enhance our ability to provide you with information about our business, products, and services. MeWe’s agreements with these Third-Party sources typically limit how MeWe may use this supplemental information.
Blog & Community
MeWe Service offers publicly-accessible community services including a blog. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Your posts may remain even after you cancel your account.
Additionally, if you access Third-Party services, such as Facebook or Twitter, to login to such services or to share information about your experience with MeWe we may collect information from these Third-Party services. Generally, online social media resources are interactive tools that enable Individuals to collaborate and share information with others. Social media resources include, but are not limited to, widgets, social networks, discussion boards, bulletin boards, blogs, wikis, and referral functions to share web content and tools with a friend or colleague.
MeWe may collect Personal Information to enable Individuals to use online social media resources offered either by MeWe or a Third Party. We may also enable you to use these social media resources to post or share Personal Information with others. When using social media resources, you should take into careful consideration what Personal Information you share with others.
If you use on online social media resource offered by a Third Party (“Third-Party SMR”) through MeWe Services, you acknowledge that MeWe may be able to access any information you make public through such Third-Party SMR (such as your username, comments, posts, and contacts) and other information your privacy settings on such Third-Party SMR permit MeWe to access. MeWe will comply with the terms of this Policy and the privacy policies applicable to the social media resources it uses.
From time to time, MeWe may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of MeWe Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
Cookies and Pixel Tags/Web Beacons/Clear GIFs
Cookies are small bits of information that are stored by your computer’s web browser. They enable the entity that put the cookie on your device to recognize you across different websites, services, devices, and/or browsing sessions. Cookies serve many useful purposes. For example:
• Cookies can remember your sign-in credentials so you don’t have to enter those credentials each time you log on to a service.
• Cookies help MeWe and Third Parties understand which parts of our services are the most popular because they help us see the pages and features visitors are accessing and how much time they are spending on the pages. By studying this kind of information, we are able to adapt the services and provide you a better experience.
• Cookies help us and Third Parties to provide you with relevant content and advertising by collecting information about your use of our services, other websites, and apps.
Cookies can only access Personal Information you have provided on MeWe Services and cannot be accessed by other websites. Individuals also have the ability to delete cookie files from their own hard drive at any time by clicking on the “Privacy” or “History” tab typically found on the “Settings” or “Options” menu in your internet browser. However, please also be advised that cookies may be necessary to provide access to much of the content and many of the features of MeWe Services.
Pixel Tags/Web Beacons/Clear GIFs
MeWe may use “pixel tags” also known as “web beacons” or “clear gifs” which are small graphic files that allow us to monitor the use of MeWe Services. A pixel tag can collect information such as the Internet Protocol (“IP”) address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the browser type and language; the device type; geographic location; and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable email, we or our Third Party-service providers may use “format sensing” technology, which allows pixel tags to let us know whether you received and opened our email.
We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of MeWe Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of MeWe Services by going to http://tools.google.com/dlpage/gaoptout.
MeWe may use third party advertising tools, including Google Analytics, Google AdWords, and Google Adwords Remarketing Ads to advertise on the internet. These tools display targeted ads on sites across the internet by placing a cookie on a user’s machine. Cookies are used to display ads based on previous visits to MeWe websites. Use of third party advertising and remarketing tools allows MeWe to target our marketing efforts to relevant users.
Through MeWe Services, MeWe may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-MeWe related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.”
Mobile Devices and Geo-Location Data
Mobile versions of MeWe Services may require that users log in with an account. In such cases, information about use of mobile versions of the MeWe Services may be associated with user accounts. When accessing MeWe Services on mobile devices, we may collect certain information that your mobile device sends when you use such MeWe Service. Information provided by your mobile device may include a device identifier, user settings, the operating system of your device, and “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device.
How We Use Personal Information
We acquire, hold, use, and Process Personal Information based on the legal grounds and for the legitimate business purposes outlined in this Policy, including:
• Providing Products or Services: MeWe may use information about you to fulfill requests for, answer questions, or respond to requests or comments about current, potential or future products, MeWe Services, or information. MeWe may also use your information to:
o Manage Individual information and accounts;
o Provide access to certain areas, functionalities, and features of MeWe Services;
o Provide service-related notices (including any notices required by law, in lieu of communication by postal mail);
o Allow you to register for events.
• Supporting Administrative Purposes: MeWe may use Personal Information about you for its administrative purposes, including to:
o Measure interest in MeWe Services;
o Develop new products and MeWe Services;
o Ensure internal quality control;
o Verify Individual identity;
o Communicate about Individual accounts and activities on MeWe Services and systems, and, in MeWe’s discretion, changes to any MeWe policy;
o Process payment for products or services purchased;
o Process applications and transactions;
• Comply with regulatory requirements;
o Prevent potentially prohibited or illegal activities;
o Enforce our Terms of Service.
• Marketing Products and Services: MeWe may use Personal Information to provide you with materials about offers, products, and services that may be of interest, including new content or MeWe Services. MeWe may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
o To tailor content, advertisements, and offers;
o To notify you about offers, products, and services from MeWe, its affiliates, or Third Parties that may be of interest to you;
o To provide MeWe Services to you;
o For other purposes disclosed at the time that Individuals provide Personal Information; or
o Otherwise with your consent.
You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described below.
• Anonymizing and Aggregating Information: MeWe may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access MeWe Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the MeWe Services. Anonymized or aggregated information is not Personal Information, and MeWe may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within MeWe and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
• For Research and Development: MeWe may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and services or develop new products and MeWe Services.
How We Share Your Information
MeWe does not sell or otherwise disclose Personal Information about you, except as described in this Policy or as you explicitly consent. All Personal Information collected via or by MeWe may be stored anywhere in the world, including but not limited to, in the United States, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to MeWe, you consent to the transfer to and storage of your Personal Information in these locations.
MeWe may share Personal Information with our service providers that we have retained to perform services on our behalf including (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; and (iv) customer service activities. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders.
MeWe has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
MeWe may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. MeWe may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with MeWe’s. MeWe requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which MeWe provided them.
Information Disclosed for Our Protection and the Protection of Others
We may disclose information about you: (i) if we are required to do so by law, court order, or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation; (iv) to enforce MeWe policies or contracts; (v) to collect amounts owed to MeWe; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
Information Disclosed in Connection with Business Transactions
We reserve the right to disclose or transfer any information we have about you in the event of a proposed or actual purchase, reorganization, sale, lease, merger, joint venture, assignment, amalgamation, or any other type of acquisition, disposal, or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding). Should such an event occur, MeWe will endeavor to direct the transferee to use Personal Information in a manner that is consistent with this Policy.
Rights of Access, Rectification, Erasure, and Restriction
You may inquire as to whether MeWe is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may use any of the methods set out below to request access to, receive (port), restrict Processing, seek rectification, or request erasure of Personal Information held about you by MeWe. Such requests will be processed in line with local laws.
Although MeWe makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which MeWe is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If MeWe determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
You have the right to opt out of certain uses and disclosures of your Personal Information.
Where you have consented to MeWe’s Processing of your Personal Information, you may withdraw that consent at any time and opt out to further Processing by following the instructions below.
Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out.
Email and Telephone Communications
An “Unsubscribe” button will be provided at the top or bottom of any marketing or promotional email communications sent by MeWe so that you can opt out. Additionally, you may unsubscribe by contacting MeWe at firstname.lastname@example.org or 1-415-985-6393. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain communications regarding MeWe and our services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms of Service or this Policy).
We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
“Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. MeWe does not recognize or respond to browser-initiated DNT signals.
While MeWe does not currently participate in interest-based advertising, it may in the future. In the event that we do so, an opportunity to opt out of such interest-based advertising will be provided through an AdChoices link.
Advertisements on Third-Party websites that contain the AdChoices link and that link to this Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes.
Even if you opt out through AdChoices, we may still collect and use non-Personal Information regarding your activities on MeWe Services and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
How We Protect Your Information
The security of all Personal Information provided to MeWe is important to us and MeWe takes reasonable steps designed to protect Personal Information. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while MeWe strives to protect Personal Information, we cannot ensure or warrant the security of any information you transmit to MeWe, and you do so at your own risk. You are responsible for maintaining the secrecy of your own passwords. If you have reason to believe that your passwords or Personal Information is no longer secure, please promptly notify MeWe at email@example.com or 1-415-985-6393.
Other Rights and Important Information
Redress/Compliance and Accountability
156 2nd Street, 1st Floor
San Francisco, California 94105
MeWe will address your concerns and attempt to resolve any privacy issues in a timely manner.
MeWe retains the Personal Information we receive as described in this Policy for as long as you use MeWe Services or as necessary to fulfill the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
Information Regarding Children
Protecting the privacy of children is important to us. Due to the nature of MeWe’s business, products and services are not marketed to minors. MeWe does not knowingly solicit or collect Personal Information from children under the age of 13 (and in certain jurisdictions under the age of 16). If we learn that we have collected Personal Information from a child under the age of 13 (and in certain jurisdictions under the age of 16), we will promptly delete that information. If you believe that we might have any information from or about a child under 13 (or in certain jurisdictions, under 16), please contact us at firstname.lastname@example.org.
California Privacy Rights
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. MeWe does not share Personal Information with Third Parties for their own marketing purposes.
Links to Third-Party Websites
“Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, MeWe or to which MeWe discloses Personal Information for use on its behalf.
“Individual” is an identified or identifiable natural person. An Individual may be an Employee, a customer, user or visitor of the MeWe Services, or any other natural person. An identifiable natural person is one 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 natural person.
“Employee” refers to any current, temporary, permanent, prospective or former employee, director, contractor, worker or retiree of MeWe or its subsidiaries worldwide.
“Personal Information” is any information relating to an identified or identifiable natural person (“Individual”), including Internet Protocol addresses, information contained in cookies, and navigational data. This type of information is used for the purposes of gathering data to provide improved administration of MeWe Services, and to improve the quality of your experience when interacting with MeWe Services.
“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, 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.
“Protected Health Information” is a subset of Personal Information and has the meaning set out in the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPAA”), and in particular at 45 C.F.R. § 160.103, as it may be amended from time to time.
“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections.
Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.
“Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, MeWe or MeWe’s Agents.