WISE International Privacy Policy

Last updated: January 1, 2021

WISE is a growing global membership of like-minded business owners, executives, trainers and consultants all united with the purpose to bring about a saner, more ethical, more pro-survival and productive and flourishing world through the dissemination and use of the Hubbard Administrative Technology.

The privacy of your data is important to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights to your data. We will never sell your data.

This policy applies to all products and services offered by WISE International (hereinafter “WISE”).

What we collect and why

Our rule is to collect only what we need. Here is what that means in practice:

Identity & access

When you sign up on the WISE website at www.WISE.org we typically ask for identifying information such as your name, email address, physical address and if applicable, a company name. That is so you can personalize your new account, and we can send you invoices, updates, or other essential information. We sometimes also give you the option to add a profile picture that displays in our products, but we do not normally look at or access that picture. We will never sell your personal info to third parties, and we will not use your name or company in marketing statements without your permission either.

Billing information

When you pay for a WISE product, we ask for your credit card and billing address. That way we can charge you for service, calculate taxes due if applicable, and send you invoices. Your credit card is passed directly to our Stripe.com payment processor and does not ever get stored on our servers. We only store a record of the payment transaction, including the last 4 digits of the credit card number and billing address, for account history, invoicing, and billing support. We store your billing address and/or shipping address to calculate any sales tax due in the United States or VAT in any other country as applicable, to detect fraudulent credit card transactions, and to print on your invoices.

Geolocation data

Our payment processor at Stripe.com logs all access to all accounts by full IP address so that we can always verify no unauthorized access has happened. We keep this data for as long as your account is active.

We also log full IP addresses used to sign up a product account. We keep this record forever because they are used to mitigate spam signups.

Website interactions

When you browse our marketing pages or applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, page load timing, and which website referred you for statistical purposes. We sometimes track specific link clicks to help inform some design and/or course content decisions. These web analytics data are tied to your IP address and user account if applicable and you are signed into our Services.

Cookies and Do Not Track

We do use persistent first-party cookies to store certain preferences, make it easier for you to use our application, and support some in-house analytics. A cookie is a piece of text stored by your browser to help it remember your login information, site preferences, and more. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to view which cookies have been set and how to manage and delete them, please visit: www.allaboutcookies.org.

At this time, our sites and applications do not respond to Do Not Track beacons sent by browser plugins.

Voluntary correspondence

When you write to WISE with a question or to ask for help, we keep that correspondence, including the email address, so that we have a history of past correspondences to reference if you reach out in the future.

We will never give or sell your correspondence to any third parties, and we will not use your name or company in marketing statements without your permission either.

It is possible that you may be invited to write a success story and indicate if that success story is OK to be published (without your name, only your first and last name initials). We only do so if you give your express consent. If you indicate that your success story is not to be published, we will never use or publish your success story.

Information we do not collect

We do not collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity, gender expression, or physical and mental abilities or disabilities. You may provide these data voluntarily, such as if you include a pronoun preference in your email signature when writing into our Support team.

We also do not collect any biometric data. You are given the option to add a picture to your user profile, which could be a real picture of you or a picture of something else that represents you best. We do not extract any information from profile pictures: they are for your use alone.

When we access or share your information

Our default practice is to not access your information except as covered above with your interactions with us. The only times we will ever access or share your information are:

  • To help you troubleshoot a software bug, with your permission. If at any point we need to access your account to help you with a Support case, we will ask for your consent before proceeding.
  • To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We have an obligation to protect the privacy and safety of both our customers and the people reporting issues to us. We do our best to balance those responsibilities throughout the process.
  • When required under applicable law. If the appropriate law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring we share data, we have to comply. Otherwise, we reject requests from local and federal law enforcement when they seek data. And unless we are legally prevented from it, we will always inform you when such requests are made. We have never received a National Security Letter or Foreign Intelligence Surveillance Act (FISA) order.

Location of Site and Data

Our products and other web properties are operated in the United States. If you are located in the European Union or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using our Site, participating in any of our services and/or providing us with your information, you consent to this transfer.

Your Rights with Respect to Your Information

We apply the same data rights to all customers, regardless of their location. Currently some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”) in the US. We recognize all of the rights granted in these regulations, except as limited by applicable law.

These rights include:

  • Right to Know. You have the right to know what personal information is collected, used, shared or sold. We outline both the categories and specific bits of data we collect, as well as how they are used, in this privacy policy.
  • Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
  • Right to Correction. You have the right to request correction of your personal information.
  • Right to Erasure / “To be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession. Fulfillment of some data deletion requests may prevent you from using WISE services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
  • Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority. To identify your specific authority or find out more about this right, EU individuals should go to https://edpb.europa.eu/about-edpb/board/members_en.
  • Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information. (Again: we never have and never will sell your personal data).
  • Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
  • Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party.
  • Right to not be subject to Automated Decision-Making. You have the right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
  • Right to Non-Discrimination. This right stems from the CCPA. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights (such as the right “to be forgotten”) may, by virtue of your exercising those rights, prevent you from using our Services.

Many of these rights can be exercised by signing in and directly updating your account information.

If you have questions about exercising these rights or need assistance, please contact us at privacy@wise.org or at:

WISE International

6331 Hollywood Blvd., Ste 701
Los Angeles, CA 90028
USA

Phone: 323-960-3540
Fax: 323-960-3549

For requests to delete personal information or know what personal information has been collected, we will first verify your identity using a combination of at least two pieces of information already collected including your user email address. If an authorized agent is corresponding on your behalf, we will first need written consent with a signature from the account holder before proceeding.

If you are in the EU, you can identify your specific authority to file a complaint or find out more about GDPR, at https://edpb.europa.eu/about-edpb/board/members_en.

How we secure your data

All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted.

Most data are not encrypted while they live in our database (since it needs to be ready to send to you when you need it), but we go to great lengths to secure your data at rest. For more information about how we keep your information secure, please review our Security Overview page.

When you delete data in your product accounts

In some of our applications, we give you the option to trash data. Anything you trash on your product accounts while they are active will be kept in an accessible trash can for up to 30 days. After that, the trashed data are no longer accessible via the application. We may also have some backups of our application databases, which are normally kept. In total, when you trash things in our applications, they are not necessarily purged from all of our systems and logs unless you specifically request it. Retrieving data for a single account from a backup is cost-prohibitive and unduly burdensome so if you change your mind you will need to do so before your data are deleted from our active servers.

If you cancel your account, all of your content will be immediately be inaccessible upon cancellation. Although inaccessible, this does not mean that the data is automatically deleted entirely from all backups and logs unless you send us a written request to do so, at which point all content will be permanently deleted from all backups and logs. This information cannot be recovered once it has been permanently deleted.

Please refer to our Cancellation and Refund policy for more details.

EU-US and Swiss-US Privacy Shield policy

The GDPR requires that data transfer out of the EU must only happen to countries deemed as having adequate data protection laws. The United States generally doesn’t meet that requirement. Privacy Shield is an agreement between certain European jurisdictions and the United States that allows for the transfer of personal data from the EU to the US. Participation in the Privacy Shield program is voluntary.

We comply with the frameworks for EU, UK, and Swiss data that are transferred into the United States

WISE complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland to the United States, respectively. We adhere to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles take precedent. To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov/.

The Privacy Shield Frameworks uphold specific principles. For clarity, pursuant to the Privacy Shield Frameworks, the following principles apply to all EU, UK, and Swiss data that has been transferred into the United States:

  • Members have the right to access their personal data and to update, correct, and/or amend information that is incomplete. Members also have the right to request erasure of personal information that has been processed in violation of the principles. Members wishing to exercise these rights may do so by signing in and directly updating your account information. If you have questions about exercising these rights or need assistance, please contact us privacy@wise.org or at:
    WISE International

    6331 Hollywood Blvd., Ste 701
    Los Angeles, CA 90028
    USA

    Phone: 323-960-3540
    Fax: 323-960-3549

  • We do not sell personal data, nor do we permit it to be used for reasons other than those for which it was originally provided. If this practice should change in the future, we will update this policy accordingly and provide individuals with opt-out or opt-in choice as appropriate.
  • We may be required to release personal data in response to lawful requests from public authorities including to meet national security and law enforcement requirements.

We commit to resolving all complaints

In compliance with the EU-US and Swiss-US Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. European Union, United Kingdom, or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact privacy@wise.org or at:

WISE International

6331 Hollywood Blvd., Ste 701
Los Angeles, CA 90028
USA

Phone: 323-960-3540
Fax: 323-960-3549

Changes & questions

We may update this policy as needed to comply with relevant regulations and reflect any new practices.

Have any questions, comments, or concerns about this privacy policy, your data, or your rights with respect to your information?

Please get in touch by emailing us at: privacy@wise.org and we’ll be happy to answer them!