Privacy Policy

Who we are

We are WiXLu, Inc of 17th Level, Unit 1704, Tower 2, Winland Towers J. Osmeña Extension, Brgy. Camputhaw, Cebu City, Philippines, 6000 and WiXLu, Ltd (CRN 09884153) of 32 Sunset Avenue, North Chingford, London E47LW (“WiXLu”) and welcome to our privacy policy. This policy sets out how we handle your personal information if you’re a WiXLu user or visitor to our Sites. It applies across WiXLu Elements, WiXLu Market, WiXLu Site.

When we say ‘we’, ‘us’ or ‘WiXLu’ it’s because that’s who we are and we own and run the Sites.

If we say ‘policy’ we’re talking about this privacy policy. If we say ‘user terms’ we’re talking about the rules for using of the Site. The rules vary by services and each service makes them separately available and seeks consent to them separately to this policy.

Our website address is https://www.wixlu.com.

What personal data we collect and why we collect it

The type of personal information we collect:

We collect certain personal information about visitors and users of our Site. The most common types of information we collect include things like: names, email addresses, other contact details, blogs, (already with WiXLu) – payment information such as payment agent details, transactional details, support queries, content you direct us to make available on our Site, and web analytics data. We will also collect personal information from job applications (such as your CV, the application form itself, and cover letter).

How we collect personal information:

We collect personal information directly when you provide it to us, automatically as you navigate through the Site, or through other people when you use services associated with the Site.

We collect your personal information when you provide it to us when you complete the ticket to provide us your inquiries, or would like to sign a contract for a project or long-term services with us, subscribe to a newsletter, email list, submit feedback, or just sending us a communication.

The personal information we collect about you from others:

Although we generally collect personal information directly from you, on occasion, we also collect certain categories of personal information about you from other sources. In particular: 

–  financial and/or transaction details from payment providers located in the US, UK, and APAC in order to process a transaction; 

– third-party service providers (like Google, Facebook, LinkedIn) who are located in the UK, US, and APAC, which may provide information about you and when you link, connect, or log in to your account with the third party provider and they send us information such as your registration and profile from that service, this only occurs if you are using the services that WiXLu offered. The information varies and is controlled by that service provider or as authorized by you via your privacy settings at that service provider;

– and other third-party sources/and or partners from UK, US, and APAC whereby we receive additional information about you (to the extent permitted by applicable law), such as demographic data or fraud detection information, and combine it with information we have about you. For example, fraud warnings from service providers like identity verification service. We also receive information about you and your activities on and off the WiXLu platform through partnerships, or about your experiences and interactions from our partner and networks. We also receive information about you as a rights holder from our third-party partners. For example, our partner would refer you to us or vice versa, the information we receive and made available for us to contact.

How we use personal information

 We will use your personal information:

– To fulfill a contract, or take steps linked to a contract: in particular, in facilitating and processing transactions.

–  Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests include:

  • operating the Site;
  • providing you with services described on the Site;
  • verifying your identity when you sign in to any of our Sites;
  • responding to support tickets, and helping facilitate the resolution of any disputes;
  • updating you with operational news and information;
  • carrying out technical analysis to determine how to improve the Site and services we provide;
  • monitoring activity on the Site, e.g. to identify potential fraudulent activity and to ensure compliance with the user terms that apply to the Site;
  • managing our relationship with you, e.g. by responding to your comments or queries submitted to us on the Site or asking for your feedback or whether you want to participate in a survey;
  • managing our legal and operational affairs (including, managing risks relating to content and fraud matters);
  • training WiXLu staff about how to best serve our existing clients, new clients, new member, and user or visitor of the Sites;
  • improving our services;
  • providing general administrative and performance functions and activities;
  • processing your job application to WiXLu.

– Where you give us consent:

  • Providing you with marketing information about services which we feel may interest you; and customizing our services and website, like advertising that appear on the Site – where this involves the use of cookies or similar technologies – in order to provide a more personalised experience.

–  For purposes which are required by law.

–  For the purpose of responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.

Marketing Choices regarding your personal information

–  Where we have your consent to do so (e.g. if you have subscribed to one of our e-mail lists or have indicated that you are interested in receiving offers or information from us), we send you marketing communications by email about the services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.

–  You also have choices about cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies some parts of our Site may not work properly in your case.

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Who we share your data with

We will disclose personal information to the following recipients:

  • companies that are in the WiXLu group which are located in the UK, and in the Philippines;
  • services made available to you, so they can facilitate support
  • subcontractors and service providers who assist us in connection with the ways we use personal information (as set out above), in particular: technical and customer support services which are located in Philippines, and in UK; marketing and analytics services which are located in the UK, US, and APAC; subscription management and payment processing services which are located in the UK and Philippines; identification verification services located in the UK, and APAC; and operational tooling services which are located in the Philippines. Noting that our subcontractors and services providers may also transfer and access such information from other countries in which they have operations.
  • our professional advisers (lawyers, accountants, financial advisers etc.) which are located in the UK, and the Philippines;
  • regulators and government authorities in connection with our compliance procedures and obligations;
  • an interested party, prospect or potential clients, part of our assets or our business, and their professional advisers, in connection with the services availed;
  • a third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity;
  • a third party, in order to enforce or defend our rights, or address financial or reputational risks;
  • a right holder in relation to an allegation of intellectual property infringement or any other infringement; and
  • other recipients where we are authorised or required by law to do so.

Where we transfer and/or store your personal information: We are based in the Philippines so your data will be processed in the Philippines. Some of the recipients we have described above, and to whom we disclose your personal information, are based outside the Philippines in places like APAC, Germany, Canada, UK, and the US. We do this on the basis of your consent to this policy. In order to protect your information, we take care of where possible to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.

How we keep your personal information secure: We store personal information on secure servers that are managed by us and our service providers, and occasionally hard copy files that are kept in a secure location in the Philippines, and UK. Personal information that we store or transmit is protected by security and access controls, including username and password authentication, two-factor authentication, and data encryption where appropriate.

How you can access your personal information: You have the right to make a request to access your personal information we hold about you and to request corrections of any errors in that data. You can also close the account you have with us at any time. To make an access or correction request, contact our privacy champion using the contact details at the end of this policy.

The information you make public or give to others:  If you make your personal information available to other people, we can’t control or accept responsibility for the way they will use or manage that data. There are lots of ways that you can find yourself providing information to other people, like when you post a public message on a forum thread, share information via social media, or make contact with another user (such as a third party) whether via our Site or directly via email. Before making your information publicly available or giving your information to anyone else, think carefully. If giving information to another user via our Site, ask them how they will handle your information. If you’re sharing information via another website, check the privacy policy for that site to understand its information management practices as this privacy policy will not apply.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

We retain your personal information for as long as is necessary to provide the services to you and others, and to comply with our legal obligations. If you no longer want us to use your personal information or to provide you with the WiXLu services, you can request that we erase your personal information and close your WiXLu account. Please note that if you request the erasure of your personal information we will retain information from deleted accounts as necessary for our legitimate business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the terms of service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

What rights you have over your data

If you have an account on this site or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

When we need to update this policy

  • We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.
  • When we do change the policy, we’ll make sure to notify you about such changes, where required. A copy of the latest version of this policy will always be available on this page.

How you can contact us

If you have any questions about our privacy practices or the way in which we have been managing your personal information, please contact our privacy champion in writing at 17th Level, Unit 1704, Tower 2, Winland Towers, Juana Osmeña Extension, Brgy. Camputhaw, Cebu City, Philippines, 6000 or through email at info@wixlu.com.

If you’re a user or visitor in the European Economic Area these rights also apply to you:

  • For the purposes of applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “GDPR”), we are a ‘data controller’ of your personal information.

Additional information

GDPR compliance

The General Data Protection Regulation (GDPR) takes effect from 25 May 2018. The GDPR is a standardized user data protection framework which operates across Europe and imposes obligations on organizations, like WiXLu, that handle the personal data of people in the European Economic Area.

This page briefly explains what WiXLu is doing to work towards GDPR compliance.

First, we are improving our transparency by updating our Privacy Policy to identify the information that we collect about our users, how we use that information and keep it safe. If you continue to use or still with WiXLu after we introduce these updates, it means you agree to this new policy.

Second, we recognize that it’s important for you to control your information so we are investing in features that will help you to easily manage and access some of your information within WiXLu. We will provide more information on these features as they become available.

Third, since we use some third-party (e.g. Amazon Web Services, LinkedIn, Facebook, and Google) to make WiXLu available, we are reviewing these tools with a view to ensuring that they comply with applicable laws, including GDPR. Where amendments to these agreements are required as we are entering into Data Processing Agreements.

Fourth, we recognize that the protection of your data involves us so we are improving our internal controls around employee access to data and data security incidents.

None of these steps are likely to impact the way WiXLu’s process your information day to day – you and all our many users will remain free to reach us anytime for any concerns you may all have.

For support on anything related to GDPR, including how to access, inspect, update and remove your personal information with respect to WiXLu, please email us at info@wixlu.com.

Both personal information and personal data have the same meaning in the context of this Privacy Policy.

 WiXLu Privacy Policy v2, effective date 25 May 2018