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Privacy Policy

LAST REVISED ON: OCTOBER 15, 2020

This Privacy Policy applies to information that WW Good Foundation, Inc. with the address 675 Avenue of the Americas, 6th Floor, NY, NY 10010 (“we”, “us”, or “our”) collects about individuals who interact with our organization.

WW Good Foundation Inc. is the controller of the data collected via this website, and this policy explains what personal information we collect, how we use it, and your rights concerning our use of your information.

Please remember that this Privacy Policy applies only to information collected by our website. We are not responsible for the privacy practices of websites that are operated or owned by third parties.

1. Personal data that we process

The following table explains the types of data we collect and the legal basis, under current data protection legislation, on which this data is processed.

Purpose Data (key elements) Legal Basis
Enquiring about our organization and its work Name, email, message Legitimate interests – it is necessary for us to read and store your message so that we can respond in the way that you would expect.
Subscribing to email updates about our work Name, email Consent – you have given your active consent.  

Where data processing is based on consent, you may revoke this consent at any time, and we will make it possible for you to do this (for example by putting ‘unsubscribe’ links at the bottom of all our marketing emails).

Website functionality Website activity collected through cookies Legitimate interests – it is necessary for us to store a small amount of information, usually through cookies, to deliver functionality that you would expect.

2. How we use your data

We will only use your data in a manner that is appropriate considering the basis on which that data was collected, as set out in the table at the top of this policy.

For example, we may use your personal information to:

  • where you have specifically agreed to this, send you communications by email relating to our work which we think may be of interest to you; and
  • reply to enquiries you send to us. We will provide you with an option to change your preferences if you no longer desire to receive communications you have agreed to receive.

3. When we share your data

We will only pass your data to third parties in the following circumstances:

  • you have provided your explicit consent for us to pass data to a named third party;
  • we are using a third party purely for the purposes of processing data on our behalf and we have in place a data processing agreement with that third party that fulfills our legal obligations in relation to the use of third-party data processors; or
  • we are required by law to share your data.

We may employ third party independent contractors, vendors and suppliers to provide specific services and products related to our website, such as developing applications for our website and e-mail services. These third parties may sometimes have limited access to information collected on our website, including your personally identifiable information, in the course of providing products or services to us.

Some of the third party companies we share your personal data with as described above are located outside of the European Economic Area.

If required under applicable data protection laws, we will collect your prior consent before sharing your personal information with other companies. In such cases, the legal basis is Art. 6(1)(a) GDPR.

4. How long we keep your data

We take the principles of data minimization and removal seriously and have internal policies in place to ensure that we only ever ask for the minimum amount of data for the associated purpose and delete that data promptly once it is no longer required.

5. Cookies & usage tracking

A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things, such as remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website.

Where cookies are used to collect personal data, we list these purposes in section 1 above, along with other personal data that we collect. However, we also use some cookies that do not collect personal information but that do help us collect anonymous information about how people use our website.

We use Google Analytics for this purpose. Google Analytics generates statistical and other information about website usage by means of cookies, which are stored on users’ computers. The information collected by Google Analytics about usage of our website is not personally identifiable. The data is collected anonymously, stored by Google and used by us to create reports about website usage. Google’s privacy policy is available at http://www.google.com/privacypolicy.html.

6. California Consumer Privacy Act

The California Consumer Privacy Act of 2018 (the “CCPA”) is a California law that gives California residents (“consumers”), the right to learn about and control certain aspects of how a business handles the personal information that a business collects about them. Pursuant to the CCPA, effective January 1, 2020, consumers have certain rights, including:

  • The right to know the categories of personal information we’ve collected and the categories of sources from which we got the information;
  • The right to know the business purposes for sharing personal information;
  • The right to know the categories of third parties with whom we’ve shared personal information;
  • The right to access the specific pieces of personal information we’ve collected;
  • The right to delete your information; and • The right to opt-out of the sale of your information.
  • Consumers also have the right to not be discriminated against if they choose to exercise their privacy rights.
CCPA CATEGORIES OF PERSONAL INFORMATION WE COLLECT SOURCES OF PERSONAL INFORMATION WHY WE COLLECT THAT INFORMATION
Identifiers and Personal information described in California Civil Code section 1798.80

We collect identifying information such as your email address, and contact information.

We collect this information though our website, when you sign up to receive emails or when you contact us. We collect this information in order to provide our products and services and respond to your questions or requests.
Internet or other electronic network activity information

We collect information about your browser and device, IP address, access time and log information. We also use cookies.

We collect this information when you visit our website and through our analytics or service providers. We collect this information to keep track of website visits, tailor relevant content, improve your experience on our website, prevent fraud and abuse, and troubleshooting.
Geolocation data

We collect location data.

We collect this information when you visit our website and through our analytics or service providers. We collect this information for statistical purposes and to improve your experience on our website.

While the chart above contains the categories and primary purposes of processing for each category of personal information, we also collect information as described above.

Your Rights Under the CCPA

Right to Opt-Out of Sale of Your Personal Information

Consumers have the right to request that a business that sells the consumer’s personal information, or that discloses it for a business purpose, inform the consumer of what has been collected about them and who it has been sold or disclosed to.  Consumers also have the right, at any time, to direct a business that sells personal information about them not to sell their personal information.

Right to Access / Data Portability

Consumers have the right to request that a business that collects personal information about them disclose the following: (1) The categories of personal information it has collected about that consumer; (2) The categories of sources from which the personal information is collected; (3) The business or commercial purpose for collecting or selling personal information; (4) The categories of third parties with whom the business shares personal information; (5) The specific pieces of personal information it has collected about that consumer.  The disclosure shall cover the 12-month period preceding your request.  We are not required to provide your personal information more than twice in a 12-month period.

Right to Deletion

Consumers have the right to request that a business delete any personal information about them.  However, there are exceptions to this rule.  For example, a business does not have to delete information if it is necessary to: a) complete a transaction; b) prevent illegal activity; c) exercise free speech; d) comply with a legal obligation; e) identify or repair errors that impair functionality; or f) otherwise use a consumer’s personal information, internally, that is compatible with the context in which the consumer provided that information. 

Right to Non-Discrimination

A business cannot discriminate against a consumer because the consumer exercised any of the consumer’s rights listed above. 

Exercising Your Right to Access or Right to Deletion

  1. To submit a Request for Access or Request for Deletion as a Consumer or as an Authorized Agent, send an email to privacy@ww.com. You can also call us toll-free at 1-800-651-6000.
  2. Once we receive a request, we will take steps to determine whether your request is a valid Verifiable Consumer Request.  We will ask for information that is reasonable in light of the nature of your request.
  3. When you submit a request for access:
    1. Within 45 days of receipt of your request, we will provide you with a copy of the information listed in “Right to Access / Data Portability,” above, electronically.  To the extent possible, we will provide this information in a portable and useable format.
    2. In the event we need additional time, we will inform you within the initial 45-day period of our need for an additional 45 days (for a maximum of 90 days between request and provision of information). 
  4. When you submit a request for deletion:
    1. If your request does not fall within one of the exceptions to deletion listed in “Right to Deletion,” above, we will confirm deletion within 45 days. If we are not required to delete your account, we also let you know within 45 days. 

Exercising Your Right to Opt-Out

We do not sell your personal information for money.  The definition of “sale” under the CCPA is broad and may include activities that are common practice to many businesses, such as sharing partially de-identified information (hashed email addresses), Internet or network activity (through cookies), and engage in remarketing and retargeting activities.  You may opt out of the sale of your personal information by clicking here.

DO NOT SELL MY PERSONAL INFORMATION

You can also send an email to: privacy@ww.com or call us toll-free at 1-800-651-6000.

7. EU Data Subjects

If you are an EU resident, you have certain rights under the GDPR as relates to your personal data:

  1. Right of access (Art. 15 GDPR): You have the right to request confirmation as to whether we process your personal data and where that is the case, to request access to the personal data we hold about you.
  2. Right to rectification (Art. 16 GDPR): You have the right to request the correction of inaccurate personal data.
  3. Right to erasure (Art. 17 GDPR): You have the right to request erasure of personal data without undue delay under certain circumstances, e.g. if your personal data is no longer necessary for the purposes for which it was collected or if you withdraw consent on which our processing is based according to Art. 6(1)(a) GDPR and where there is no other legal ground for processing.
  4. Right to restriction of processing (Art. 18 GDPR): You have the right to request us to restrict the processing of your Personal Data under certain circumstances, e.g. if you think that the personal data we process about you is incorrect or unlawful.
  5. Right to data portability (Art. 20 GDPR): Under certain circumstances, you have the right to receive your personal data you have provided us with, in a structured, commonly used and machine-readable format and you have the right to transmit that information to another controller without hindrance or ask us to do so.
  6. Right to object (Art. 21 GDPR): You have the right to object to the processing of your Personal Data under certain circumstances, in particular if we process your Personal Data on the legal basis of legitimate interests (Art. 6(1)(f) GDPR) or if we use your Personal Data for marketing purposes.

RIGHT TO LODGE A COMPLAINT BEFORE THE DATA PROTECTION AUTHORITY

You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or place of the alleged infringement if you consider that our processing of your Personal Data infringes the applicable data protection laws.

To can assert your above mentioned rights by contacting us at: privacy@ww.com.

8. Children

We are committed to protecting the privacy of children. Our website is not designed for or directed to children under the age of 13. We do not collect Personally Identifiable Information from any person we actually know is under the age of 13. We urge all parents or guardians to participate in their children’s exploration of the Internet, and to teach their children about protecting their personally identifiable information while online.

9. Modifications

We may modify this Privacy Policy from time to time and will publish the most current version on our website. If a modification meaningfully reduces your rights, we’ll notify people whose personal data we hold and is affected.

10. Contact us

If you have any comments or questions about this notice, feel free to contact us at: privacy@ww.com.

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