Privacy Policy

Privacy Policy

This Privacy Policy is incorporated by reference in the Terms and Conditions of WSPRO GLOBAL MARKETS - FZCO, a company registered under the laws of the United Arab Emirates (“WSPRO“, or “us“) and is part of the agreement between you, the user of the Website https://wspro.org (“Website” or “Service”), and WSPRO.

Important Privacy Information
To use the service on the Website, we may ask you to enter information about your age, gender, email address, and current financial situation and ask other onboarding questions. We also automatically collect from your device: language settings, IP address, time zone, type and model of a device, device settings, and operating system. We need this data to provide our services, analyze how our customers use the service, and measure ads.

For improving our service and serving ads, we use third-party solutions. As a result, we may process data using solutions developed by Amazon Web Services, Facebook, Google, TikTok, Hotjar, Amplitude, Apple, PayPal, FreshDesk, Solidgate, and ActiveCampaign. Therefore, some of the data is stored and processed on servers of such third parties. This enables us to: (1) analyze different interactions (how often users make subscriptions, what is the most popular users’ financial goal, what is the average time spent by users on the service); (2) serve ads (and can show them only to a particular group users, for example, to subscribers). Consequently, we, in particular, better understand in what of our features and content you see the most value and can focus on them to enhance your experience and increase the quality of our products.

Please read our Privacy Policy below to learn more about what we do with data (Section 3), what data privacy rights are available to you (Section 6) and who will be the data controller (Section 1). If any questions remain unanswered, please contact us at info@wspro.org

Privacy Policy
This Privacy Policy explains what personal data is collected when you use the WSPRO Website located at https://wspro.org (the “Website”) and the services and Digital products provided through it (the “Service”), how such personal data will be processed.

BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND, AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree or are unable to make this promise, you must not use the Service. In such case, you must (a) contact us and request deletion of your data; and (b) cancel any subscriptions using the functionality provided by instructions on the Website; (c) leave the Website and not access or use it.

“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons about the processing of personal data and the free movement of such data.

“EEA” includes all current member states of the European Union and the European Economic Area. For this policy, EEA shall include the United Kingdom of Great Britain and Northern Ireland.

“Process”, in respect of personal data, includes collecting, storing, and disclosing to others.

TABLE OF CONTENTS

PERSONAL DATA CONTROLLER
CATEGORIES OF PERSONAL DATA WE COLLECT
FOR WHAT PURPOSES WE PROCESS PERSONAL DATA
UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)
WITH WHOM WE SHARE YOUR PERSONAL DATA
HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
AGE LIMITATION
INTERNATIONAL DATA TRANSFERS
CHANGES TO THIS PRIVACY POLICY
CALIFORNIA PRIVACY RIGHTS
DATA RETENTION
HOW “DO NOT TRACK” REQUESTS ARE HANDLED
CONTACT US

1. PERSONAL DATA CONTROLLER
WSPRO GLOBAL MARKETS - FZCO, a company registered under the laws of United Arab Emirates will be the controller of your personal data.
2. CATEGORIES OF PERSONAL DATA WE COLLECT
We collect data you give us voluntarily (for example, when you enter your gender, financial status, or email). We also collect data automatically (for example, your IP address) and use third-party service providers for such collection.
Data you give us
You provide us with information about yourself when you register for and/or use the Service. For example age, gender, data on financial status ( including your questions regarding financial mindset), and email address.
Data we collect automatically:
Data about how you found us
We collect data about your referring URL (that is, the place on the Web where you were when you tapped on our ad).
Device and Location data.
We collect data from your device. Examples of such data include language settings, IP address, time zone, type and model of a device, device settings, operating system, and its version.
Usage Data
We record how you interact with our Service. For example, we log your taps/clicks on certain areas of the interface, the features, and content you interact with, how often you use the Service, how long you are in the Service, and your subscription orders. We also record the ads on our Website with which you interact (and the Internet links to which those ads lead).
Transaction data
When you make payments through the Service, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including date, time, and amount of the transaction, and the type of payment method used.
Cookies
A cookie is a small text file that is stored on a user's computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Service. A persistent cookie remains on your hard drive for an extended period. We also use tracking pixels that set cookies to assist with delivering online advertising.
Cookies are used, in particular, to automatically recognize you the next time you visit our Website. As a result, the information, which you have earlier entered in certain fields on the Website may automatically appear the next time when you use our Service. Cookie data will be stored on your device and most of the time only for a limited period.

3. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA
We process your data:

To provide our Service
This includes enabling you to use the Service seamlessly and preventing or addressing Service errors or technical issues. To host personal data and enable our Website to operate and be distributed we use Amazon Web Services, which are hosting and backend services provided by Amazon.
To manage your account and provide you with customer support
We process your data to respond to your requests for technical support, service information, or to any other communication you initiate. This includes accessing your account to address technical support requests. For this purpose, we may send you, for example, notifications or emails about the performance of our Service, security, payment transactions, notices regarding our Terms and Conditions, or this Privacy Policy.
To communicate with you regarding your use of our Service
We communicate with you, for example, by email. These may include information about the Service, some critical changes, and special offers. To opt out of receiving emails, you should click the unsubscribe link in the footer of our email. The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our users, as well as when they interacted with it, such as by clicking on links included in the message.
FreshDesk provides us with message and customer service tools, which enable us to communicate with you within the Service. When you chat with us via in-service chat, some of your information is automatically transferred to FreshDesk. The transfer is required to enable us to identify (if you shared any name-related data with us) and to communicate with you in the in-Service chat. Thus, FreshDesk uses these data to provide and fulfill its services (as outlined in their terms of service).
To research and analyze your use of the Service
This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what features and learning plans of the Services our users like more, and what categories of users use our Services. As a consequence, we often decide how to improve the Service based on the results obtained from this processing. For example, if we discover that users more often engage in specific topics about investments, we may develop and introduce extra chapters into this category.
To analyze how visitors use our Service and to measure the effectiveness of some ads we use Google Analytics, a web analysis program of Google.
To provide us with analytics, Google Analytics places cookies on your device. On Google Analytics we get, in particular, aggregated information on the data you enter on our Service and users’ interactions within the Service. Google allows you to influence the collection and processing of information generated by Google, in particular, by installing a browser plug-in, available here.
We also use Amplitude, which is an analytics service provided by Amplitude Inc. We use this tool to understand how customers use our Service. Amplitude collects various technical information, in particular, time zone, type of device (phone or tablet), and unique identifiers. Amplitude also allows us to track various interactions that occur on the Website. As a result, Amplitude helps us to decide what features should we focus on. Amplitude is EU-US Privacy Shield certified. Amplitude provides more information on how it processes data in its Privacy Policy.

To send you marketing communications
We process your data for our marketing campaigns. We may add your email address to our marketing list, provided we receive consent or otherwise establish the legal basis for sending you marketing communications. As a result, you will receive information about our products, such as special offers. If you do not want to receive marketing emails from us, you can unsubscribe by following the instructions in the footer of the marketing emails.
To communicate with you we use ActiveCampaign, which is the message sending service. We integrate Amplitude to create analytics-based audiences and track opening and conversion events.

To personalize our ads
We and our partners, including Facebook and Google, use your data to tailor ads and possibly even show them to you at the relevant time.
How to opt-out or influence personalized advertising
IOS: On your iPhone or iPad, go to “Settings,” then “Privacy” and tap “Advertising” to select “Personalized Ads”. In addition, you can reset your advertising identifier (this also may help you to see less of personalized ads) in the same section.
Android: To opt out of ads on an Android device, simply open the Google Settings app on your mobile phone, tap “Ads” and enable “Opt out of interest-based ads”. In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads).
macOS: On your MacBook, you can disable personalized ads: go to System Preferences > Security & Privacy > Privacy, select Apple Advertising, and deselect Personalized Ads.
Windows: On your laptop running Windows 10, you shall select Start > Settings > Privacy and then turn off the setting for Let apps use advertising ID to make ads more interesting to you based on your app activity. If you have another Windows version, please follow the steps here.
To learn even more about how to affect advertising choices on various devices, please look at the information available here. In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:
Network Advertising Initiative – http://optout.networkadvertising.org/
Digital Advertising Alliance – http://optout.aboutads.info/
Digital Advertising Alliance (Canada) – http://youradchoices.ca/choices
Digital Advertising Alliance (EU) – http://www.youronlinechoices.com/
We value your right to influence the ads that you see, thus we are letting you know what service providers we use for this purpose and how some of them allow you to control your ad preferences.
We use Facebook pixel on the Service. Facebook pixel is a code placed on the Service collecting data that helps us track conversions from Facebook Ads, build targeted audience, and remarket to people who have taken some actions on the Service (for example, made a purchase).
We use Facebook Ads Manager together with Facebook Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Facebook products (for example, Instagram). Through Facebook Custom Audience we may create a list of users with certain sets of data to choose users that have completed certain actions in the Service (for example, bought it). As a result, we may ask Facebook to show some ads to a particular list of users. As a result, more of our ads may show up while you are using Facebook or other Facebook products (for example, Instagram). You may learn how to opt out of advertising provided to you through Facebook Custom Audience here. Facebook also allows its users to influence the types of ads they see on Facebook. To find out how to control the ads you see on Facebook, please go here or adjust your ads settings on Facebook.
Google Ads is an ad delivery service provided by Google that can deliver ads to users. In particular, Google allows us to tailor the ads in a way that they will appear, for example, only to users who have conducted certain actions with our Service (for example, show our ads to users who have purchased a subscription). Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.
The TikTok pixel is a piece of JavaScript code that helps Advertisers measure the cross-device impact of Campaigns. Advertisers will be able to see how many TikTokers take action on their Website(s) after seeing their Ad.
TikTok Ads is the service provided by TikTok that can deliver ads to its users. The ads can be tailored to specific categories of users (for instance, based on their geographical location).TikTok’s Privacy Policy.

To process your payments
We provide paid features and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment for our Service and we will be notified that the payment has been made and will provide you with it. We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors. We use SolidGate to process your payments on the Website.
i.
To enforce our Terms and Conditions and to prevent and combat fraud
We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions).
To comply with legal obligations
We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

4. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)
In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 3. This section applies only to EEA-based users.
We process your personal data under the following legal bases:

Your consent
Under this legal basis, we will send you marketing emails. You have the right to withdraw your consent at any time by clicking on the unsubscribe link in the footer of our marketing emails
To perform our contract with you,
Under this legal basis we:
a. Provide our Service in accordance with our Terms and Conditions
b. Customize your experience
c. Manage your account and provide you with customer support
d. Communicate with you regarding your use of our Service
e. Process your payments

For our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.
We rely on legitimate interests:
a. to research and analyze your use of the Service. Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to introduce and test new features).
b. to send you marketing communications. The legitimate interest we rely on for this processing is our interest in promoting our Service in a measured and appropriate way.
c. to personalize our ads. The legitimate interest we rely on for this processing is our interest in promoting our Service in a reasonably targeted way.
d. To enforce our Terms and Conditions and to prevent and combat fraud.
Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions etc. To comply with legal obligations.

5. WITH WHOM WE SHARE YOUR PERSONAL DATA
We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes indicated in Section 3 of this Privacy Policy.
The types of third parties we share information with include, in particular:

SERVICE PROVIDERS
We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We share your personal information with the following types of service providers:
a. cloud storage providers (Amazon Web Services)
b. data analytics providers (Facebook, Google, Amplitude)
c. marketing partners (in particular, social media networks, marketing agencies, email delivery services, Facebook, Google, ActiveCampaign)
d. payment processing providers(Solidgate, PayPal, ApplePay, GooglePay)
e. communication services providers (FreshDesk)

LAW ENFORCEMENT AGENCIES AND OTHER PUBLIC AUTHORITIES
We may use and disclose personal data to enforce our Terms and Conditions, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

THIRD PARTIES AS PART OF A MERGER OR ACQUISITION
As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

6. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
To be in control of your personal data, you have the following rights:

Accessing/reviewing/updating/correcting your personal data. You may request a copy of your personal data and request us to update/correct your personal data collected during your use of the Service at info@wspro.org

Deleting your personal data. You can request the erasure of your personal data by sending us an email at info@wspro.org. When you request the deletion of your personal data, we will use reasonable efforts to honor your request. In some cases we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.

Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof by sending requests to info@wspro.org

If you are based in the EEA, you have the right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particularly in the EU Member State where you reside, work or where the alleged infringement has taken place.

The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send a respective request to info@wspro.org

To exercise any of the available to your privacy rights, please send a request to info@wspro.org

7. AGE LIMITATION
We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us at info@wspro.org

8. INTERNATIONAL DATA TRANSFERS
We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.
In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the European Commission adequacy decisions about certain countries (details available here).

9. CHANGES TO THIS PRIVACY POLICY
We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified through our Service or by other available means and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

10. CALIFORNIA PRIVACY RIGHTS
This section provides additional details about how we process the personal data of California consumers and the rights available to them under the California Consumer Privacy Act (“CCPA”) and California’s Shine the Light law. Therefore, this section applies only to residents of California, United States. California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties‘ direct marketing purposes. Learn more about what is considered to be personal information under the statute. To obtain this information from us, please send an email message to info@wspro.org which includes “Request for California Shine the Light Privacy Information” on the subject line and your state of residence and email address in the body of your message. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

11. DATA RETENTION
We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you), which includes (but is not limited to) the period during which you have an account with the App. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

HOW “DO NOT TRACK” REQUESTS ARE HANDLED
Except as otherwise stipulated in this Privacy Policy, this App does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Contact us

WSPRO GLOBAL MARKETS - FZCO
DSO-IFZA -41895, Dubai Silicon Oasis
00000, Dubai, United Arab Emirates
PO Box 3420001
email: info@wspro.prg

* “Personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person 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 (Article 4 (1) of the GDPR).

(See the full text of the EU’s General Data Protection Regulation (GDPR) at https://eur-lex.europa.eu/eli/reg/2016/679/oj)