CCPA Privacy Notice

For California Consumers

For Users who are California residents, you have the following rights under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination for exercising your rights under the Act:

a. You have the right to request that we disclose certain information to you and explain how we have collected, used, and shared your personal information over the past 12 months.
b. You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.

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@vlmedia.com.tr.

In addition, 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 Users’ 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 users’ online activities over time and across different online services when the users 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.

 

This California section supplements the Privacy Policy and applies solely to California consumers (excluding our personnel). The table below describes how we process California consumers’ personal information (excluding our personnel), based on definitions laid out in the California Consumer Privacy Act ("CCPA").

 

Purpose of collection Source Legal Basis CCPA Category
 To provide you with social networking service  You provide your name, email address, and date of birth to us. We obtain location data from the device that you use to access the service  Contractual necessity  CCPA Categories A and B
To facilitate networking opportunities   You provide this information to us Consent
 
CCPA Categories C, H, I, J 
 To verify your identity and prevent fraud and to ensure the safety and security of Users You provide this information to us    Legitimate interests – it is in our legitimate interests to ensure that accounts are not set up fraudulently and to safeguard users of the site. CCPA Categories B and H
 To send you marketing information about our offers and services (if you give us permission)  You provide this information to us (if you give us permission)  Consent  CCPA Category B)
 To show you other Users near you  We obtain this information from the device that you use to access the service (if you give us permission) Legitimate interests – it is in our legitimate interests to provide this functionality as part of the services
 
CCPA Category G 
To carry out research and analysis to help us improve the App    You provide photos and videos to us. We obtain the log and usage information from the device that you use to access the service  Legitimate interests – it is in our interests to analyze the way in which Users are accessing and using our services so that we can further develop the App, implement security measures and improve the service  CCPA Categories F and H
 To respond to correspondence and queries that you submit to us, including social media queries You provide your email address, social media name, and phone number to us when you contact us and we obtain your IP address from the device that you use to contact us   Legitimate interests – it is in our legitimate interests to respond to your queries to ensure that we provide a good service to Users and troubleshoot problems
 
 CCPA Categories B and F
To block accounts as part of our anti-spam procedures You provide your email address, phone number, and username to us. We obtain the other information from the device that you use to access the service Legitimate interests – it is in our legitimate interests to prevent unauthorized behavior and to maintain the safety and security of our services CCPA Categories B and F
To investigate and block Users for reported infringements of our Terms and Conditions of Use You provide your name, profile content, and activities on the App to us Legitimate interests - it is in our legitimate interests to prevent unauthorized behavior and to maintain the safety and integrity of our services CCPA Categories A, B, C, E, and H
To enable Users to create and enhance their profile and log into the App via third party accounts We obtain this information from Facebook, or the providers of any other accounts you use to log in or connect with your Waplog account Legitimate interests – it is in our legitimate interests to facilitate access to our services CCPA Categories A, B, C, and H
To serve promo cards and advertisements on the App (if you give us permission) We obtain age, gender, and profile information from you, and location data from the device that you use to access the service (if you give us permission) Legitimate interests – it is in our legitimate interests to target advertisements so that Users see relevant advertisements and to allow us to generate income from advertising revenue CCPA Categories A, C, and G
To enable video and audio call functions, and the sending of images and video  We obtain this information from the device that you use to access the service  Legitimate interests – it is in our legitimate interests to provide these functionalities as part of the services  CCPA Categories F and H
 To defend legal claims, protect legal rights, and protect people from harm  This information may be obtained directly from you, from your device, or from third parties, depending on the information involved  Legitimate interests – it is in our legitimate interests to protect our legal rights, defend legal claims, and protect our users and third parties from harm  

 

DISCLOSURE OF INFORMATION

Our policy is to not disclose your Registration Information or personal data, except in the limited circumstances described here:

 

Circumstances where data may be disclosed Disclosed data
Service Providers – We engage certain trusted third parties to perform functions and provide services to us. We may share your Registration Information or personal data with these third parties, but only for the purposes of performing these functions and providing such services. More information about this is available directly below. This could include all data, including all CCPA Categories listed above
Moderators – To monitor activity on the App and approve content. Name and user registration details, profile information, the content of messages and photographs (CCPA Categories A, B, C, E, and H)
Law and Harm – As we mentioned in the Terms & Conditions, we think it is very important that all Users behave whilst using the App. We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement inquiries from within or outside your country of residence where we are required to by law, where there is an investigation into alleged criminal behavior or to protect the vital interests of a person. This may include preserving or disclosing any of your information, including your Registration Information if we believe in good faith that it is necessary to comply with a law or regulation, or when we believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal request; to protect the safety of any person; to address fraud, security or technical issues e.g. through anti-spam providers to protect the service from criminal activity or to protect our rights or property or those of third parties. In such cases, we may raise or waive any legal objection or right available to us. This could include any personal data that Waplog holds about you, depending on the nature of the request or the issue that we are dealing with, including all CCPA Categories listed above
Business Transfers – In the event that a VLMedia A.S or any of its affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organization, 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. This could include all personal data that VLMedia holds about you, including all CCPA Categories listed above
Marketing Services Providers – To help us serve marketing and advertising on third-party websites and applications and measure the effectiveness of our advertising campaigns. More information on this is available below Advertising identifier associated with your device (Device ID), estimated location (based on your IP address), age, gender, and data about your visit to our Sites or App and action taken on those (for example if you downloaded our App or created an account with our App) (CCPA Categories B, C, G, F, and K)
 Anti-Spam and Anti-Fraud – Your data may be shared with other VLMedia Group companies, for example, to block accounts and suspected fraudulent payment transactions as part of our anti-spam and anti-fraud procedures. Email address, phone number, IP address, and IP session information, social network ID, username, user agent string, and transaction and payment data (CCPA Categories B, F, and D).
 
Aggregated Information – We may share aggregated information with third parties that includes your personal data (but which doesn’t identify you directly) together with other information including log data for industry analysis and demographic profiling.  

 

Waplog does not sell your data and has not sold your personal data in the previous 12 months.