1. About this Privacy Policy

We are Wakelet Limited ("we" or "us") a limited company incorporated under the laws of England and Wales with company number 07483296 and with its registered office and main trading address at 76 Quay Street, Manchester, M3 4PR, United Kingdom. We operate the website wakelet.com (“Website”) and the Wakelet application (“App”) and the Services and Content on the Website and App (together “Wakelet”) and are the data controller in respect of any information we collect about you on or through Wakelet.

This policy sets out our policy, procedures and ways we handle information that we collect when you visit and use Wakelet or other Wakelet products. It also tells you about the rights that you have in respect of your personal information.

This policy only applies to us and to our Agents and how we will use your personal information. Please be aware that once personal information has been posted on Wakelet this will be visible to the public (unless you tell us that you do not want it be publicly available) and we cannot control what other Wakelet Users do with any information you share on or through Wakelet. Be careful with your own information and what you are willing to share.

This policy applies to information we collect:

• On or through Wakelet.

• In e-mail, text and other electronic messages between you and Wakelet.

• When you speak to Wakelet by phone.

• Through mobile and desktop applications you download from the Website, which provide dedicated non-browser-based interaction between you and Wakelet.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you should not use Wakelet.

The Definitions at the end of this Policy set out the meaning of any capitalised words used in this Policy.

Updates to this Policy

Wakelet reserves the right to revise and update this policy from time to time and we will seek to provide reasonable notice before and changes take effect. If you are a Registered User, we will usually notify you of any changes via email and/or by asking you to review and acknowledge or accept the changes to this Policy the next time you login to Wakelet.

Wakelet is a public platform

Wakelet is for both public and private use. Whenever you add Content through Wakelet that is not created as a private display it will be public, and when you provide us with User Content or make User Comments on a non-private wake it is published so that anyone can view it.

Content published and shared publicly is accessible to everyone, including search engines, and you may lose any privacy rights you might have regarding that Content. In addition, information shared publicly may be copied and shared throughout the Internet, including through features native to Wakelet Services, such as commenting and embedding.

2. Information We Collect About You

This section of the Policy sets out the personal information that we may collect about you and how we may use this information.

(a) Account Information

When you create an account on Wakelet, you either provide your email address and password by filling out the form on Wakelet or you authenticate yourself through a third-party service, like Facebook. When you authenticate through another site, you link that account with your Wakelet account. Once the accounts are linked, we may collect and store personally identifying information that you have provided to that third party service, and consented to having shared with services like us (please see section 4(b) below for further information). Information gathered includes name, email address, avatar and public data.

We will store your email address and password that you provided to create your Wakelet Account and any information you or we add to your Wakelet account, including your name, handle, bio, profile image and any links you choose to add to your Wakelet account. Where you use a third party site to authenticate your Wakelet account, we do not receive or store passwords for your linked accounts.

Occasionally, we might need to use your email address to email you with important information about our Services. We might need to send you some administrative information, tell you something important about your account or changes to our Services, or update you on new policies or terms. These administrative communications are considered part of our Services and your Wakelet account.

(b) Third Party Site Information

When you link your Wakelet account with a third party service account, we may get the following information about you from that third party service (if you have provided that information to the third party service and made it available for Wakelet to access): biographical information or your geographic location.

We may also collect, store, and periodically update the contact lists associated with that linked account, so that, for example, we can make it easy for you to connect with your existing contacts from that service who are also on Wakelet.

We may store and use this information to improve and personalise Wakelet by using this information to make suggestions to you about Content and Users which may be of interest to you.

You should take care when linking with a third party service account that you have checked (using the third party service’s settings) that you are comfortable with the information that they will share with us. As a general practice, we strongly urge you to make careful judgments about any personal information you disclose to Internet services, including Wakelet and any third party services you link to us.

(c) Communications with Us

If you contact us or we contact you with any query or comment about Wakelet or your use of Wakelet, we may keep a record of that correspondence.

(d) Surveys and Market Research

We may ask you to complete surveys in connection with your Wakelet Account where we may receive your name, email address, account use information and opinions. We use this personal information for research purposes. We may anonymise this information so it is no longer personal information and use this for our own purposes.

(e) Technical Information

We may also keep details of your visits to Wakelet including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access when you use Wakelet.

We automatically receive and record information from your web browser when you interact with Wakelet. This information may include your browser type and version, what sort of device you are using, your operating system and version, your language preference, the website or service that referred you to Wakelet, the date and time of each web request you make, your screen display information, and information from any cookies we have placed on your web browser.

We may collect information about your device, including where available your IP address, operating system and browser type, for system administration.

We use this information to fight spam, malware and identity theft. We also may use it to create a profile of your use of Wakelet and personalise Wakelet for you and to generate aggregate, non-identifying information about how people use Wakelet.

We also collect your IP address when you navigate to a third party website which has established a Wakelet frame on its website. We use your IP address only for the purpose of displaying the relevant wake to you.

(f) Information relating to User Content

In some cases, we may collect information by analysing your User Content. We may do this where you upload a link to Wakelet, by analysing the content of such link and determining the broad subject matter of such link (for example, sports, music, technology, science etc.).

This allows us to improve our Services and provide additional features and functionality.

(g) Information Relating to Your Use of Wakelet

We collect information about how you use Wakelet, whether you are a Registered User or User. This includes general usage information such as the number and frequency of visitors, which pages or features of Wakelet people have visited, which links on Wakelet they have clicked on, and the length of those visits. It also includes details of Users you have followed, wakes you have liked, your activity, the comments you make and the Users you interact with. Some of this information may be associated with the IP Address used to access Wakelet, and some may be associated with your Wakelet account, such as the topics you search for and the help pages that you visit.

We will use this information to help improve Wakelet and identify and fix any issues with Wakelet.

We will also use this information to create a profile of the Content in which you are likely to be interested and suggest Content and Users which we think may be of interest to you (both on Wakelet and by email).

(h) Location Information

In some cases we collect and store information about where you are located, such as by converting your IP Address into a rough geolocation. We may use location information to improve and personalise Wakelet Services for you by finding and presenting Content to you which we think will be of interest to you based on your location.

(i) Information Collected Using Cookies

Like many websites, we use "cookie" technology to collect additional website usage data and to provide you with a good experience when you browse Wakelet. This also allows us to improve Wakelet.

A cookie is a small data file that is transferred to your device's hard disk. Wakelet may use both session cookies and persistent cookies to better understand how you interact with Wakelet, to monitor aggregate usage by our Users and Registered Users and web traffic routing on Wakelet, and to customize and improve Wakelet. Our cookies do not, by themselves, contain information that personally identifies you. Most Internet browsers automatically accept cookies. You can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of Wakelet. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon you visit Wakelet.

When you create your Wakelet account, and authenticate via a third party service like Twitter, Wakelet Services may collect, store, and periodically update the contact lists associated with that linked account, so that, for example, we can make it easy for you to connect with your existing contacts from that service who are also on Wakelet.

(j) Information Collected through Email Tracking

To measure the deliverability and interest of our emails to users, we may embed information, such as a web beacon or tag, in them. This enables us to see which of our emails you have read and clicked-through from so we can analyse the effectiveness of our communications and seek to make these more relevant for you in the future.

3. Our Lawful Basis for our use of your Information

We use your name, email address, profile image and handle to enable you to use Wakelet services as part of our contract with you and to send you service updates in respect of Wakelet, generally by email or Wakelet notification.

We may also use your name, email address and any phone number you provide to us to help us deal with any service related enquiries you may have during your use of Wakelet to help us provide the best Wakelet experience to you as part of our contract. We may also need to use certain Technical Data to fully investigate any problems you are having and deal with these appropriately as part of our contract with you.

It is in our legitimate interests of making Wakelet more personalised to you and giving you a better user experience to use your Third Party Site Information, Technical Information, Information relating to your Use of Wakelet; Location Information and Information Collected through Email Tracking to create a profile of your interests and way you use Wakelet to create suggestions for wakes, Users and Content we think will be of interest to you, presenting these to you on Wakelet and sending these to you by email and Wakelet notifications. Creating a better experience helps us attract more users and build a better and more effective Platform.

We may also use this information, along with your Communications with Us and your Surveys and Market Research, for our legitimate interests of: addressing any technical and performance issues with Wakelet, understanding the profile of our Users, how Users tend to engage with Wakelet and improving Wakelet so it works better for our Users and for us.

We may also need to use your Account Information, Technical Information and Information relating to your Use of Wakelet for law enforcement and fraud prevention reasons and to enforce our Rules and Terms. This use is in our legitimate interests of keeping Wakelet a safe platform and protecting our own commercial interests.

We only use your Information Collected using Cookies with your consent.

4. Marketing

We will only send you marketing emails about wakes, Users and Content we think may be of interest to you. We hope this helps you find relevant and interesting Content on Wakelet and brings you back to Wakelet. We do not send you marketing communications about third party products or services.

You can ask us to stop sending you these messages at any time by following the ‘unsubscribe’ link in each email.

If you do unsubscribe, we will still use your information to present Content on Wakelet which we think will be of interest to you but will not send you messages about these.

5. Sharing Your Information

We never share information we receive from you unless:

(a) we have your permission to share that information; or

(b) we have given you prior notice that the information will be shared, and with whom; or

(c) that information is aggregate information or other information that does not identify you.

(b) Information You Share with Third Party Services

Our content platform enables you to access third party services through Wakelet Services. For example, Users can embed externally-pointing links in their content; Users can click on those links to reach other sites and services. We also enable Users to share information that you provide to us or embed a wake into a third party site, like posts and comments, with other services. For example, Users may share posts on Twitter and Facebook.

This Privacy Policy only covers information we collect. It does not cover information collected by other services. If you access or otherwise share information with third party services through Wakelet Services, you are responsible for reading and understanding those other services' privacy policies (and we recommend you do this before sharing the information).

(c) Information We Share with Our Agents and Third Parties

In some circumstances, we might share your information that we store, like IP addresses, with our third party service providers for the purposes of operating and improving Wakelet Services. Those third parties might include:

• Our help desk/technical services provider..

• Our email and website hosts.

• Our professional advisors (lawyers, accountants, surveyors, tax advisers etc.).

This also includes the following third parties:

When we share information with service providers under those circumstances, we have appropriate contractual protections in place with them. Unless we tell you differently, our service providers will not have any right to use personal information or any other information we share with them beyond the scope and duration of what is necessary to assist us.

We may share or disclose non-private information, aggregate information, or other non-personal information with people and entities with which we are doing business.

(d) Information Disclosed Pursuant to Business Transfers

We may buy or sell business assets. In these transactions, user information is typically one of the transferred business assets. Likewise, if we, or substantially all of our assets, get acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your personal information as set forth in this policy.

(e) Information Disclosed for Our Protection and the Protection of Others

We try to protect you from having your privacy violated through abuse of the legal system, whether attempted by individuals, entities, or governments. It is our policy to insist upon jurisdiction and proper legal process for governmental information requests, and to contest claims we believe to be unwarranted by the law. At the same time, we also reserve the right to access, preserve, and disclose information as we reasonably believe is necessary, in our sole discretion, to (i) satisfy a valid law, regulation, legal process, governmental request, or governmental order, (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, including exchanging information with other companies and organizations for fraud protection and the prevention of spam and malware, (iv) respond to user support requests, or (v) protect the rights, property, health or safety of us, our users, any third parties or the public in general.

6. Our Policy Towards Children

Wakelet is not intended to be used by unsupervised children under 13 years of age.

Children under 13 years of age may only use Wakelet under the supervision of a responsible adult (over the age of 18) who has agreed to our Terms and the provisions in respect of their responsibilities as a “Group Registered User”.

We do not send any marketing messages to children under the age of 13 years old.

Save as set out above, we do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on Wakelet or on or through any of its features or register on the Wakelet, or use any of the interactive or public comment features of Wakelet or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use.

If you become aware that your child has provided us with personal information without your consent, please contact us at privacy@wakelet.com. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information without verification of parental consent, we will take steps to remove such information and terminate the child's account.

7. Where We Store Your Personal Data

Some of our service providers are based outside of the European Economic Area so their processing of your personal data will involve a transfer of data outside the European Economic Area (“EEA”).

Where we transfer your personal information outside of the EEA, we ensure a similar degree of protection is given to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

• We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

• • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

8. Security of your Information

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Wakelet. You are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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

It’s important for you to prevent unauthorized access to your account and personal information by choosing and protecting a strong third party service password and by limiting access to your computer and browser by signing off after you have finished using Wakelet.

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

Note that we will never email you to ask for your password or other Account information; if you receive such an email, send it to us, so we investigate and take any appropriate action.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Wakelet; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

9. Retention of Your Information

We will only retain your personal information for as long as necessary to fulfil 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 personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Where you are a Registered User, we retain your information for the period during which you continue to hold your account with us and a period of 14 days thereafter. After this time it will be purged from our data store and caches. Logs are retained for up to 30 days and may contain some user information. The longest retention is the use of the incremental backup system of the AWS Dynamo data store, which can roll back tables over a time period of up to 35 days. Data is therefore completely gone after 49 days. Anonymous aggregated analytic data is held in Google Analytics indefinitely.

Where you are a User (without a Wakelet account), we retain your information for 30 days, which is as long as it takes for the logs to clear. Anonymous aggregated analytic data is held in Google Analytics indefinitely.

We do periodically cleanse Technical Information, Third Party Site Information, Information relating to User Content, Information Relating to your use of Wakelet, Location Information, Information Collected using Cookies and Information Collected Through Email Tracking.

We will delete your IP address thirty days following collection.

10. Your Data Subject Rights

You have certain legal rights under data protection laws in relation to your personal information. We have set these out below and provided further information about certain of these rights in the next sections.

• The right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and check that we are processing this lawfully.

• The right to request that the personal data we hold about you be corrected or updated.

• The right to request that the personal data we hold about you be erased. You can exercise this right where we have no good reason for continuing to process your personal data (subject to any legal reasons for needing to continue holding the personal data).

• The right to object to our processing of your personal data where we are relying on a legitimate interest or are processing for direct marketing purposes.

• The right to restrict our processing of your personal data.

• The right to request the transfer of your personal data to you or a third party in a structured, commonly used and machine readable format.

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 before escalating your complaint.

(a) Modifying Your Personal Information

If you are a Registered User of Wakelet, we provide you with tools and account settings to access or modify the personal information you provided to us and associated with your account.

You can review and change your personal information by logging into Wakelet and visiting your account settings page. You may also send us an e-mail at admin@wakelet.com to exercise you data subject rights. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Content from Wakelet or request we do so, please note that User Content might have been copied or stored by other Website users.

(b) How to Delete Your Account and What Happens When You Delete Your Account

If you want to delete your Account, we will enable you to do this in your account settings page. Given the sharing, commenting, and dialogue that takes place on Wakelet, some of the public activity on your account prior to deletion may have been copied to third party servers outside of our control and so may remain accessible to the public indefinitely.

(c) Exercising your Rights

You can exercise your data subject rights by contacting us at:

Wakelet Limited

76 Quay Street

Manchester

M3 4PR

United Kingdom

support@wakelet.com

11. Where to Direct Questions or Concerns

If you have any questions or concerns regarding Wakelet’s privacy policies and practices, please send us a note.

Wakelet Limited

76 Quay Street

Manchester

M3 4PR

United Kingdom

daniel@wakelet.com

Our data protection manager is Daniel Sheppard.

12. Definitions

Here are some definitions of capitalized words we use in these Terms:

"Agents" means service providers, consultants and other third-parties and agents not employed by us.

"Content" means any information, text, graphics, photographs, images, illustrations, logos, tools, written posts, executable files, scripts, software, interactive features, creative expression, data or other information materials generated, provided, uploaded, downloaded, appearing or otherwise accessible on or through Wakelet.

"Interactive Services" means message boards, chat rooms, personal web pages or profiles, forums, bulletin boards and other interactive features.

"Registered User" means a User who has registered and created an account to use Wakelet.

"Services" means Wakelet.com and all other domains, products, applications, services and Content provided by Wakelet.

"Terms" means these terms of agreement between us and you.

"User" means any person or entity using Wakelet.

"You" means you, whether you are a person or someone acting on behalf of an entity you are authorized to represent, and whether you are a Registered User or not.

"User Comments" means any comments, recommends, feedback, likes, or other Content posted by Users that is not included in the body of a Wakelet post.