Privacy Policy

Who we are

The WeCommunify Platform is operated by EyeLinkMedia Ltd, a company incorporated in the United Kingdom under company number 05485070 and located at 1 Dover Place 5th Floor, Ashford Commercial Quarter, Ashford, Kent, United Kingdom, TN23 1FB ("WeCommunify", "we" or "us"). WeCommunify is the controller and processor of your personal information. Depending on the context, we may also refer to our website (www.wecommunify.com) and the Platform operated on it as ‘WeCommunify’ from time to time.

WeCommunify has designated a Data Protection Officer and they can be reached by emailing dpo@wecommunify.com or by post at the address above.

Who can use WeCommunify?

You must be aged 18 or over to sign up for a WeCommunify Account. Depending on where you live, you may need to be a higher minimum age. You can only use WeCommunify if you are allowed to do so by law and we will not be responsible for the members that are younger than the above minimum age.

Notwithstanding the preceding paragraph, if for whatever reason we exempt you from the minimum age above, you will need your parent, guardian or legal representative to consent to you signing up to WeCommunify and they will need to assist or represent you in the registration, and you warrant that you have obtained such parental consent.

When you sign up to use WeCommunify, you'll be asked to confirm your date of birth and to provide certain other personal information so we can verify your eligibility. Don't lie about your age – that's an important rule.

If you do not agree with this privacy policy, please do not sign up to use the Platform.

Providing us with the personal data requested to make a Submission to join the Platform and create a WeCommunify Account is only mandatory if you wish to be considered for WeCommunify Program. You may choose not to do so, but if you do not provide it you may not be able to use WeCommunify or receive payment of any number of Rewards.

How is my personal information used by WeCommunify to provide the Services to me?

WeCommunify operates a Platform that allows members to join (and apply to join) and participate in certain online activities using a variety of social media Apps in return for Rewards. WeCommunify operates an invitation-only Platform. Anybody can make a Submission to join a Program, and we assess Submissions based on their suitability for Challenges we are currently prioritizing. When you sign up to the Platform we will request personal details to verify your eligibility to participate in the Program, to ensure our compliance with tax laws, and in order to assess your suitability for Challenges being offered to members of the Platform. If you are accepted to a Program, you may be assigned a Category based on your interests or the personal attributes you have shared with us. In addition, you may provide access to your contacts on your device in order to participate in referral programs from time to time. If you choose to share this information with us, please ensure you have obtained the consent of your contacts and anyone else before sharing their personal information with us.

You understand that by using the Platform, you may from time to time be made visible to people on the Platform, and certain information you have shared with us in order to assess your suitability for the Category you have applied to or been accepted to (“Category Information”) will also be known to some extent by other members of the Platform within that Category. For example, if you have answered that you are in your twenties, and identify as female and are interested in dating people who identify as female, we may suggest your profile or introduce you to other members who have compatible preferences, who will learn of your dating preference.

Please be careful about posting private and sensitive details about yourself in participating in any Challenges. Remember that this may be visible to others. Some information has special protection under data protection laws and is called “special category” or “sensitive” data, depending on applicable laws. This includes information about or revealing your religious, philosophical or moral beliefs, your racial or ethnic origin, your political opinions, your health, your sexual orientation and sex life, among others. You may decide to voluntarily provide this type of information, but WeCommunify does not require it to fulfill the purposes for processing your data as set out in this Privacy Policy. Please remember that any photographs that you post during the Challenges may reveal these kinds of special category/sensitive data. Where you do include this type of information on your WeCommunify Account, you are explicitly consenting to WeCommunify processing your information to verify your suitability for Categories on WeCommunify. You can change your profile at any time to remove this information.

To ensure members have provided us with correct information, we may require that members verify the mobile phone number that they use to register for a WeCommunify account. To do this will send a code to the mobile phone number that is provided and that code must be entered into WeCommunify to enable an account to be created. We want to make sure you are not a robot! And we also want to avoid fake WeCommunify Accounts being created which can be used for malicious activities and cyber crime – they threaten the WeCommunify community and spoil things for everyone. We use a third party provider for account verification who will keep your phone number for up to 90 days for fraud identification purposes, and will only process it following our instructions and in accordance with applicable laws.

To prevent abuse of the Platform/site, WeCommunify may block accounts or content as part of its anti-spam procedures. If an account or message meets certain criteria that demonstrate that the Terms and/or laws are likely to have been breached, the relevant account or content will automatically be blocked.

If you request to withdraw Rewards or funds from WeCommunify, we will collect information required to verify your identity, comply with applicable laws, and tax-related documentation. This will include the information found required for IRS Form W-9 if you live in the United States. In addition, we will also collect some or all of the following information from PayPal in order to ensure our compliance with applicable payments regulations: your legal name, email, address, PayPal account verification status and PayPal ID number. We collect information about how members use WeCommunify to improve our products and services, enforce our Terms, policies and agreements with members, and comply with applicable contracts and laws. If you participate in one of our Challenges, referral programs or other special activities, we may collect Category Information and additional information about you as necessary to verify your eligibility for the Program, administer the Program, give out any rewards, and comply with applicable laws. We describe the types of information we collect as part of these activities when you sign up to participate in them.

In order to prevent fraudulent payment transactions being processed as part of WeCommunify's anti-fraud procedures, our systems check payment transactions for behavior that indicates breaches of our Terms. If a transaction meets certain criteria that demonstrate that the Terms are likely to have been breached and the transaction is likely to be fraudulent, the relevant transaction may automatically be blocked. Where a transaction is blocked, the relevant member will be notified that their transaction cannot be processed and affected members can contact WeCommunify to contest the decision.

Please note that if your account is blocked, any account(s) that you have on our other group platforms/applications may also be blocked as part of our anti-spam and anti-fraud procedures.

How else does WeCommunify use my data?

When you use the Platform, we collect information about your browser type, referring domain (this is information about a third party site that you were on before you clicked through to the WeCommunify site) and mobile carrier. We use this information to check that it is you using WeCommunify, to see how you are using the WeCommunify service so that we can improve our services, to keep track of your preferences and to create a more tailored user experience.

We may also obtain and use information provided by third party Apps (such as Facebook, Instagram, LinkedIn, Hoppy, TikTok, Twitter) that you connect to your WeCommunify Account. In such case, we will collect data about your usage of such third party platforms and Apps and your profiles on them (including, but not limited to your followers, following, engagement and activity).

What personal data is WeCommunify processing, for what purposes, and what is the legal basis that allows WeCommunify to use my data?

We are only permitted to use your data when we have a lawful basis to do so or there is an exception under which WeCommunify is allowed to use your data. The table below provides an overview of the legal bases that WeCommunify relies on to use your data, unless you are in Mexico or the US in which case the "Legal basis" column does not apply to you.

Purpose for which data is used	Data	Legal basis
To provide you with the WeCommunify Platform and the WeCommunify Services	Name, date of birth, gender, and mobile phone number.	Contract performance with the data subject/conclusion of contract with data subject
To verify your suitability for a Category and to offer you a Challenge	Category Information	Consent
To help you communicate with other members of your Category	Optional information that you choose to provide in your profile, which may include information about yourself, your work history, or your education, additional photos etc., or otherwise choose to provide, such as via chats and posts	Consent
To administer Challenges, referral programs and other special activities	Name, date of birth, gender, mobile phone number, referral code, any other information that you include in your profile, as well as conversations and other interactions that you have with other members over the Platform	Contract performance with the data subject/conclusion of contract with data subject
To verify your identity, prevent fraud, ensure the safety and security of members, and comply with tax and other applicable laws	Name, address, mobile phone number, social insurance number, taxpayer identification number or other government-issued number or identification	If you are in Chile, consent. Otherwise, compliance with legal obligations, and legitimate interests – it is in our legitimate interests to ensure that accounts are not set up fraudulently, to safeguard members of the WeCommunify services, and to verify the information of members
To send you marketing information about our offers and services	Name, date of birth, gender, mobile phone number, contact list or address book entries	Consent, or legitimate interests – it is in our legitimate interests to promote our products and services
To process cash-outs of Rewards	Name, email, address, PayPal account verification status and PayPal ID number, type of payments, amounts paid and withdrawn	Contract performance with the data subject/conclusion of contract with data subject or legitimate interests – it is in our legitimate interests to make this feature available to members as part of the Services and to promote our products and services.
To contact you in order to run surveys for research purposes and to obtain feedback	Email address and mobile phone number	Legitimate interests – it is in our legitimate interests to make this function available to members as part of the Services. Such surveys are optional.
To respond to correspondence and queries that you submit to us	Mobile phone number, account information, email address, IP address and any information you provide in your correspondence and queries	Legitimate interests – it is in our legitimate interests to respond to your queries to ensure that we provide a good service to members and troubleshoot problems
To block accounts as part of our anti-spam procedures	Email address, phone number, IP address and IP session information, username, user agent string	Legitimate interests – it is in our legitimate interests to prevent unauthorized behavior and to maintain the safety and security of our services
To block payment transactions as part of our anti-fraud procedures	Name, PayPal ID, IP address, email address, mobile number, cardholder name, payments received, type of payment, user ID, country	Legitimate interests – it is in our legitimate interests to prevent unauthorised behaviour and to maintain the safety and security of our services
To enable you to invite others to join the Program and earn Rewards	Contact list from your device	Consent

How long will WeCommunify keep my data?

We keep your personal information only as long as we need it to fulfil the legitimate business purposes for which it was collected (as set out above) and as permitted by applicable law.

In practice, we delete or anonymise (if authorized by applicable law) your information upon deletion of your account, unless:

1. we must keep it to comply with applicable law;
2. we must keep it to evidence our compliance with applicable law;
3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
4. to the extent permitted by law the information may be kept for our legitimate business interests, such as fraud prevention and enhancing members' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behaviour or security incidents from opening a new account.

Please note that, if we offer a chat service on the Platform, your chat with other members via the Platform may not be deleted if you delete your account if these chats are with other active members of the Platform.

Where WeCommunify uses machine learning, for example, to help us detect and prevent fraudulent card transactions, and to detect and prevent spam communications and false Submissions (as explained above), we may need to keep personal information for a longer period than the retention periods explained above, to enable the machine learning to work properly and if it is permitted by applicable laws. Where this is the case, we always seek to minimize the amount of personal information that is used and we ensure that it is ring-fenced and kept securely from other user personal information. We regularly review the period for which personal information is required for machine learning purposes and delete any identifiable information when it is no longer required.

What information does WeCommunify collect about me if I’m under the minimum age to use WeCommunify?

WeCommunify does not knowingly collect any information about or market to anyone under the minimum age to use the Platform as set out in the "Who can use WeCommunify?" section above. If we become aware that somebody who is under the minimum age has registered with us and provided us with personal data, we will take steps to terminate that person’s registration and delete their WeCommunify Account information. If we do delete a profile because you violated our age restriction Terms, we may retain your mobile number, email and IP address to ensure that you do not try to get around our Terms by creating a new profile.

Who does WeCommunify share information with?

We may share aggregated information that includes your personal data (but which doesn’t identify you directly), together with other information including log data with third parties for industry analysis and demographic profiling.

In addition, we share your data with the following categories of third-parties:

1. Information technology companies (hardware and software) which provide services and personnel to support our products
2. Fraud prevention and anti-spam providers to protect the service from criminal activity
3. Moderators to monitor activity on the site/apps and approve content
4. Law enforcement agencies, where we are required to by law or to protect the vital interests of a person
5. Marketing companies which provide services to support our marketing activities

We ensure these parties must adhere to strict data protection and confidentiality provisions that are consistent with this Policy and applicable laws. Measures are taken to ensure that the data shared is non-attributable to individuals to the greatest extent possible.

In the event that WeCommunify or any of its affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organisation, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data.

Your data may be shared with other WeCommunify group companies, for example, to block accounts and suspected fraudulent payment transactions as part of our anti-spam and anti-fraud procedures.

The above parties with whom we may share your data may be located in a country that does not offer the same level of data protection as that offered by the data protection laws of the country where you live or where your data was collected. In any event, whenever your data is transferred or assigned, this will be done in accordance with this Privacy Policy and applicable laws.

Your rights

UK/EU

Under UK and European law, you have the right to lodge a complaint with data protection regulators. If you are based or the issue you would like to complain about took place in the UK, you can complain to the Information Commissioner’s Office (ICO). You can find out how to raise a concern with the ICO by visiting their website at www.ico.org.uk. If you’re based or the issue you would like to complain about took place in the European Economic Area, you can complain to your local data protection regulator and a list of their contact details can be found here.

You have a number of rights under UK/European data protection law.

1. Right to be informed: what personal data an organisation is processing and why (we provide this information to you in this notice).
2. Right of access: you can request a copy of your data.
3. Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
4. Right to erasure: you have the right to have your data deleted in certain circumstances.
5. Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
6. Right to data portability: you can request a copy of your data in a machine-readable form that can be transferred to another provider.
7. Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.
8. Rights related to automated decision making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.

If you want to exercise any of your rights listed above please email us at dpo@wecommunify.com. You can also contact us by post at 12-18 Theobalds Road Unit Kew, London, Greater London, England, WC1X 8SL.

California

Please note the following about how we have collected, used and disclosed California (CA) residents’ personal information over the past 12 months, including additional rights California residents may have with respect to their personal information.

1. CA Personal Information. Consistent with the “What personal data is WeCommunify processing, for what purposes, and what is the legal basis that allows WeCommunify to use my data” section above, we may collect certain categories of information about California residents, such as:

   1. Identifiers: name, gender, address, date of birth, mobile phone number, e-mail address, IP address, device ID, social media usernames, and contact list; if a California resident participates in certain programs we administer, we may also ask them to provide social insurance number, taxpayer identification number, and government-issued number or identification;
   2. Commercial Information: PayPal ID, payments received, type of payment, and details of payments;
   3. Internet or Other Electronic Network Activity: traffic statistics, clickstream data, mobile carrier, and search terms;
   4. Geolocation Data: physical location of a California resident’s mobile device;
   5. Audio, visual and electronic information: audio clips, images, GIFs, videos and other information that you submit that contains information about yourself;
   6. Professional or employment-related information: if a California resident submits an application to work for us, we may collect their professional or employment-related information and work history;
   7. Education information: if a California resident participates in certain programs we administer, we may collect information about their educational institution.

   The above categories of personal information correspond with the categories of personal information listed under Cal. Civ. Code § 1798.140(o)(1)(A), (D), (F), (G), (H), (I) and (J).

2. Sources of CA Personal Information. Consistent with the “How is my personal information used by WeCommunify to provide the WeCommunify services to me?” section above, we may collect personal information directly from California residents, and automatically when they use WeCommunify.

3. Use of CA Personal Information. We process California residents’ personal information for the purposes outlined in the “What personal data is WeCommunify processing, for what purposes, and what is the legal basis that allows WeCommunify to use my data” section above.

4. CA Personal Information Sold or Disclosed for Business Purposes.

   1. Sharing Personal Information for Business Purposes: We disclose the following categories of personal information for business purposes: Identifiers, Commercial Information, Internet or Other Electronic Network Activity, Geolocation Data, and other information to information technology, fraud prevention and anti-spam services providers.
   2. No Sale of Personal Information: We do not sell California residents’ personal information. We do not have actual knowledge that we sell the personal information of minors under 16 years of age.

5. CA Privacy Rights. If you are a California resident and subject to certain exceptions, you may have the following rights:

   1. Right to Know and Delete: you may have the right to request that we disclose what personal information we collect, use, disclose and sell about you specifically (“right to know”) and/or to delete the personal information we hold about you. To submit a request to exercise these rights, please submit an email request to dpo@wecommunify.com and include “CCPA Request” in the subject line. To protect your and others’ privacy and security, we will verify your identity before responding to any request, and may ask you to provide us with information matching the identifiers and commercial information already maintained by WeCommunify about you or additional proof where necessary. If you are making this request on behalf of someone else, we may request the authorized agent provide us with a copy of a valid power of attorney or evidence of the written authorization. You will not be penalized or discriminated against for exercising your rights to your personal information.
   2. Right to Opt-Out (“Do Not Sell My Personal Information”). You have the right to opt-out of the sale of your personal information by a business. We do not sell your personal information.
   3. Shine the Light: California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. If you wish to find out about any rights you may have under California Civil Code section 1798.83, you can write to us at dpo@wecommunify.com.
   4. “Do Not Track”: Under California law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our members’ personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their members’ online activities over time and across different online services when the members use the operator’s service. We do not knowingly permit third parties to collect personal information about an individual user’s online activities over time and across different online services when using the app.

How does WeCommunify protect my personal data?

WeCommunify has implemented security measures, including legal, organizational and technical measures, intended to protect and prevent the loss, misuse, and alteration of the information under our control, including your personal data. Our technical experts at WeCommunify work hard to ensure your secure use of our Platform.

While we take reasonable precautions against possible security breaches of our website, member database and records, no website or internet transmission is completely secure and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal data safe (including your password) and to log out of your account after use. If you lose your password or give it out, or another service provider that you use suffers a data breach and you have used the same credentials with that service provider as you have with WeCommunify, your personal data may be compromised. If that happens, please report it to Support via support@wecommunify.com.

Where is my personal data kept?

We want you to be able to access WeCommunify wherever you happen to be in the world. To enable us to provide that service, we operate a global network of servers including in the US, Hong Kong, Czech Republic and Russia. The hardware is located in third-party data centers but is owned by WeCommunify. If your personal information is transferred to other countries outside the country where you live or where your data was collected, we ensure that the data is adequately protected by ensuring, when required by applicable law, that valid, legal mechanisms are in place such as approved model clauses (which can be found here for the EU/UK ), or as otherwise required under applicable laws. If you want more information relating to the nature of the safeguards we have in place please email dpo@wecommunify.com.

Does WeCommunify collect any other personal data about me?

If you contact our Customer Support team via our Contact Us page in the App, we will receive your email address, and may track your IP address as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other members (and from other members about you) as required or permitted by law after deletion of your account.

Does WeCommunify use my personal data for any other purpose?

We may use your personal data to resolve disputes, troubleshoot problems and enforce our Terms. This is in our legitimate interests to resolve issues and ensure the smooth running of the Services.

From time to time we may run surveys for research purposes and we may contact you to find out if you would like to take part. Such surveys are optional and more information will be provided at the point of contact. We may also contact you for feedback purposes. If you do not wish to be contacted to take part in a survey, please contact our Support team via support@wecommunify.com.

What are 'cookies' and what 'cookies' does WeCommunify use?

We collect information by placing cookies on your computer or mobile. A cookie is a piece of text stored on your computer or mobile by your web browser. They are basically a tool that stores information about website visits, recognises you and your preferences each time you visit the Platform, and ensures site functionality and enables us to provide the services our members request.

When you visit the publicly available sections of WeCommunify, a session ID cookie is placed on your computer that only lasts while you’re visiting. We may also place persistent cookies (also known as local storage devices) on your device, so that WeCommunify remembers you and makes your login experience faster and easier. We may use persistent tracking cookies on your mobile device, mainly for security protection purposes, such as to prevent phishers, scammers, unauthorized login attempts, and to help you recover your account if it is hacked.

You may set your browser and your mobile settings to block cookies and local storage devices, but if you do so, you may not be able to access the features that WeCommunify offers.

WeCommunify’s use of cookies and local storage devices basically falls into the following categories:

1. cookies related to the performance of WeCommunify’s site, such as analytics cookies that help us determine how our site is performing and ensure a smooth and trouble-free experience for our members and visitors;
2. cookies related to the functionality of WeCommunify’s site, such as remembering your preferences at log in or your preferred language or allowing you to chat, add photos and message WeCommunify members; and
3. third party cookies which link to other social networks and which you request via social plugins.

WeCommunify uses cookies and local storage devices so that we know who you are, what interests you have and so that you can do the things online that you want to do, like chat with new people and share your content knowing that your data will be secure. Below is a table to explain WeCommunify’s cookie functions and why they’re used.

Cookie Functions	Cookie Purpose
Analytics and research	WeCommunify uses Google Analytics to collect information about how visitors use the WeCommunify site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. For more information about Google’s privacy policy, please visit http://www.google.com/intl/en/policies/
Authentication	These cookies help us to identify our members so that when you’re logged in, you can enjoy WeCommunify’s offerings, experiences and various features, such as uploading photographs and chatting or when you’ve asked WeCommunify to ‘remember me’. These cookies also help to remember who invited you to join WeCommunify.
Security and site integrity	We use cookies and other devices, such as CAPTCHAs, to help keep WeCommunify and our members safe and secure. These cookies do things like protect WeCommunify members from spam and fraud. We may use persistent cookies, which will help us to ensure we have identified the same device is logging into the correct account. These types of cookies also help with our anti-spam measures and may help us to prevent phishers, scammers, unauthorized log-in attempts to your account and recovering any hacked accounts.
Site features and services	These cookies and local storage devices provide the functionality that our WeCommunify members enjoy, such as uploading photographs, chats and your account settings. In some cases, the site feature you choose may allow a third party to place cookies or local storage devices on your computer. The third party who places cookies on your device is responsible for how they process their data and WeCommunify recommends that you read their privacy policies. Third parties who place cookies on your device when you use WeCommunify include the following, and we have included a link to their privacy policies: Twitter, https://twitter.com/privacy Facebook, https://en-gb.facebook.com/policy.php YouTube, http://www.google.co.uk/intl/en/policies/privacy/ AddThis, http://www.addthis.com/privacy
Performance	We need to use certain cookies and local storage devices to ensure our members have the best possible experience, such as assisting with your navigation of our site, ensuring pages load up quickly and responding faster to your requests for WeCommunify services.

Our use of cookies and local share devices, including the specific cookie names, may change over time, but will generally fall into the above categories. We will notify you of any important changes to our use of cookies and local storage devices. If you would like to know more about cookies, including flash cookies/local storage devices, and/or how to disable them the following websites provide useful information:

1. www.allaboutcookies.org
2. www.youronlinechoices.eu
3. http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html

Changes to the Privacy Policy

Any changes to this Privacy Policy or to the purposes for processing your data will be communicated to you by means that are reasonable, such as by email or a notification on the Platform. To the extent permitted by law, changes will be effective from the day after publication, unless we let you know otherwise. To the extent permitted by law, your use of our site/app after the Privacy Policy has been updated means you consent to the changes, where applicable.

This Privacy Policy was last updated on 9 September 2024.