Privacy Policy
Updated: February 13, 2024
Your privacy is important to us. This privacy notice explains how The Wolf Ltd. A Limited Liability Company (“The Wolf Ltd.,” "we," "us," "our," or “Company”), gathers, stores, uses, and/or shares ("processes") personal information or personal data from all sources, including our website thewolfltd.co (the “Site”) and related services (the "Services"), such as when you:
• visit our website at http://www.thewolfltd.co, or any website of ours that links to this privacy notice
• engage with us in other related ways, including any sales, marketing, or events
By using the Site or Services or allowing someone to use them on your behalf, you are consenting to our collection, use, disclosure, processing, transfer and storage of any personal data or other information received by us in accordance with this privacy notice.
By accessing the Site, you represent to The Wolf Ltd. that you have the authority to visit this website according to the Terms of Use. The Site is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to the Site who are under the age of 18 or knowingly collect personal information from anyone under the age of 18. If we learn we have collected or received personal information from an individual under the age of 18, the information collected will be deleted.
Questions or concerns? Please read this privacy notice carefully before using or submitting information via our service. Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. For any questions or concerns, please contact us at info@thewolfltd.co.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
Do we process any sensitive personal information? We do not process sensitive personal information.
Do we receive any information from third parties? We do not receive any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
How do you exercise your rights? The easiest way to exercise your rights is by contacting us at info@thewolfltd.co. We will consider and act upon any request in accordance with applicable data protection laws.
INFORMATION WE COLLECT and HOW WE USE IT
Personal information you disclose to us
In Short: We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include:
• names
• phone numbers
• email addresses
• business information
Sensitive Information. We do not process sensitive information.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
The information we collect includes:
• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your “location” setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
Email and security
By providing your email address to The Wolf Ltd., you consent to our use of your email for services rendered and other related communication, including any notices required by law. We may store personal information itself or such information may be included in databases owned and maintained by our affiliates, agents or service providers. We take what we believe to be reasonable steps to protect the personal information provided via the Services from loss, misuse, unauthorized access, inadvertent disclosure, alteration, and destruction. However, no Internet or e-mail transmission is ever fully secure or error free. E-mail sent to or from our company may not be secure. You should take exceptional care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any personal information via the Internet.
HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services, to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
• develop and display personalized and relevant advertising content for our users
• diagnose problems and/or prevent fraudulent activities
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
WHEN and WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
When users submit information to us via our Services, we may use such information for business purposes, but will not disclose any personal information about our users to anyone, except as set forth in this privacy notice, or as otherwise permitted or required by law. There are, however, certain circumstances in which we may disclose, transfer, process or share your personal information with certain third parties without further notice to you, as set forth below:
i. Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, financing, acquisition of all or a portion of our business to another company, dissolution or similar event, personal information may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of The Wolf Ltd. (or its assets) will continue to have the right to use your personal information and other information in accordance with the terms of this privacy notice.
ii. Subsidiaries and Affiliates. We may also share your personal information with our subsidiaries and/or affiliates for purposes consistent with this privacy notice. Our subsidiaries and affiliates will be bound to maintain that personal information in accordance with this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
iii. Agents, Consultants and Related Third Parties. We, like many businesses, sometimes engage other companies to perform certain business-related functions. Examples of such functions include mailing information, fraud prevention, maintaining databases and processing payments. When we engage another company to perform such functions, we may provide them with information, including personal information, in connection with their performance of such functions.
iv. Legal Requirements. We may disclose your personal information if required to do so by law (including, without limitation responding to a subpoena or request from law enforcement, court or government agency) or in the good faith belief that such action is necessary.
v. Non-Personal Information. Because non-personal information cannot be used to personally identify you, we may disclose, transfer or share non-personal information for any lawful purpose.
Although we make an effort to protect your personal information, we cannot guarantee the security of any information or data transmitted to or through the website; any transmission of information or data by you to or through this website is at your sole risk.
IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in the United States. We may, from time to time, partner with other companies outside of the U.S. to fulfill our business obligations and, therefore, your information may be shared with our partners and affiliates outside of U.S. jurisdiction. By using our services, you consent to the transfer of information outside the U.S. or your country of origin, even if your country has more rigorous data protection standards.
If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WHEN and WITH WHOM DO WESHARE YOUR PERSONAL INFORMATION?" above), in and other countries.
EU-UK Residents
If you are a resident in the European Union (EU), European Economic Area (EEA), United Kingdom (UK), Cayman Islands, Lichtenstein, Norway, Iceland or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law. You may also have additional rights under the EU-UK General Data Protection Regulation (the “GDPR”) with respect to your personal information.
This privacy notice does not apply to any processing of personal information by or on behalf of The Wolf Ltd. and/or one or more of its affiliates that is covered under a more specific privacy notice (including, without limitation, our contractor or vendor privacy notices/agreements). For questions regarding this privacy notice, please contact info@thewolfltd.co.
The privacy notice outlines the personal information that we collect (as described in the section named “INFORMATION WE COLLECT and HOW WE USE IT”). We do not collect any specific categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life or sexual orientation, political opinions, trade union membership or information about your health or genetic or biometric data).
European Commission's Standard Contractual Clauses:
We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.
PURPOSE OF PROCESSING
We rely on various legal bases under the EU-UK GDPR to process your personal information, including our legitimate interests, contractual necessity, and as required by law. We use the personal information we collect to operate our business and perform essential business functions in order to provide you with the services and products we offer.
If we require your personal information due to a legal requirement or obligation or to perform a contract with you, we will inform you at the time we collect your personal information, and the possible consequences if you fail to provide this personal information. Failure to provide this data may result in the cancellation of a product or services you have with us. If a cancellation occurs, we will notify you in writing on or before the time of cancellation. Please note that we may process your personal information on more than one legal basis depending on the specific purpose for which we are using your personal information.
We will only use your personal information for the purpose(s) for which we collected it. Should we need to use your personal information for an unrelated purpose, we will notify you in writing and provide an explanation.
No automated decision-making, including profiling, is used when processing your personal information.
DISCLOSURE and TRANSFER OF PERSONAL DATA
If collected, your personal information may be shared with and processed by our affiliates, agents, and certain service providers, as necessary, to fulfil the purposes set forth in this privacy notice, including professional advisors and data hosting providers.
We reserve the right to disclose your personal information as required by law or legal process, or when we believe that disclosure is necessary or appropriate to protect our rights, prevent physical harm or financial loss, and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving our company. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition, or otherwise sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation), we may disclose your personal information to the new owner of the relevant business and their advisors on the basis of our legitimate interest.
SHARING and TRANSFERS OF PERSONAL DATA
The Services are hosted and operated in the United States (U.S.) through The Wolf Ltd. and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any personal information about you, regardless of whether provided by you or obtained through a third party, is being provided to The Wolf Ltd. in the U.S. and will be hosted on U.S. servers, and you authorize The Wolf Ltd. to transfer, store and process your information to and in the U.S., and possibly other countries.
To the extent any personal data is transferred from the EEA or UK to a destination outside the EEA or UK, we will take steps to ensure that your personal data is protected by appropriate organizational and security measures, and that any such transfers are only made in accordance with the EU-UK GDPR (which may include implementing the EU standard contractual clauses and/or the UK International Data Transfer Addendum). For further information about the safeguards or details of any relevant non-EEA/UK countries, please contact info@thewolfltd.co.
HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
The Wolf Ltd. and its affiliates consider the protection of personal information to be a sound business practice, and to that end, employ appropriate technical and organizational measures, including robust physical, electronic and procedural safeguards to protect personal information in their possession or under their control. Personal information may be kept for as long as it is required for legitimate business purposes, to perform contractual obligations or, where longer, it is required to comply with applicable regulatory or legal obligations (such as tax, accounting, or other legal requirements), resolve disputes or collect fees owed. Personal information will be retained throughout the life cycle of any applicable service account managed by The Wolf Ltd. However, some personal information will be retained after a client ceases to obtain services from The Wolf Ltd.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
DIRECT COMMUNICATIONS
We may send you direct marketing communications where we have obtained your prior consent to keep you informed of our products and services in which you might be interested, or where we have an existing relationship with you, and we wish to contact you about similar products or services in which you may be interested.
You have the right to ask us not to send you marketing communications. You can also let us know at any time that you wish to change your mind and to start receiving such communications. You can do this by replying directly to the marketing communication, or at any time emailing us at info@thewolfltd.co.
DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to minors.
The Services are intended for users who are at least 18 years old. Persons under the age of 18 are not permitted to use or register for the Services. By using the Site, you represent and warrant that you are of legal age and that you have the authority to visit the Site according to the Terms of Use. We do not knowingly encourage or solicit visitors to the Site who are under the age of 18 or knowingly collect personal information from anyone under the age of 18. If we learn we have collected or received personal information from an individual under the age of 18, the information collected will be deleted.
WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. Please note that the right to erasure is not absolute, and it may not always be possible to erase personal information on request, including where the personal information must be retained to comply with a legal obligation.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person other than the intended recipient. We may also contact you to ask you for further information regarding your request to help expedite our response. You may email all requests related to the processing of your personal information to info@thewolfltd.co.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by emailing us at info@thewolfltd.co.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If you have questions or comments about your privacy rights, you may email us at info@thewolfltd.co.
CONTROLS FOR DO-NOT-TRACK FEATURES
Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device which may include “cookie” information. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and operating.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
Technology and security
Our website contains links to other websites which are not hosted or operated by us. These websites may use automated means to collect information regarding your use of the websites. This information is subject to the privacy policies or notices of the provider’s website.
We use a variety of security measures, including encryption and authentication tools, to maintain the confidentiality of your personal information. Your personal information is stored behind firewalls and is only accessible by a limited number of people who are required to keep the information confidential.
DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, you are granted specific rights regarding access to your personal information.
What categories of personal information do we collect?
We collect limited types of personal information through our website and other electronic communications (e.g., emails). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we may have collected from individuals through our website or other forms of communication over the last twelve (12) months as outlined in the definitions of the CCPA may include and are defined below as follows:
A. Identifiers, such as: real name, alias, postal address, phone numbers, e-mail addresses, unique personal identifier, online identifier, Internet Protocol (IP) addresses, or other similar identifiers. Collected: No.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) such as: a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. Collected: No.
C. Protected classification characteristics under California or federal law such as: age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Collected: No.
D. Commercial information obtained, purchased or considered, such as records of personal property, records of products or services purchased or other purchasing or use histories or tendencies. Collected: No.
E. Biometric information. Collected: No.
F. Activity information relating to internet or other electronic networks such as browsing or searching history, or interaction with a website, ad or app. Collected: No.
G. Geolocation or device information. Collected: No.
H. Audio, visual, thermal, electronic, olfactory or other similar information. Collected: No.
I. Information related to employment or other professional standings. Collected: No.
J. Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Collected: No.
K. Any inferences drawn using any of the above information to profile a consumer and reflect the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes. Collected: No.
L. Sensitive personal information. Collected: No.
We will use and retain the collected personal information as needed to provide the Services or for:
• Category B - As long as the user has an account with us
We may use, or disclose the personal information we collect for one or more of the following business purposes:
• To perform services or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our services, we will use that personal information to respond to your inquiry.
• To provide you with support and respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• Complying with U.S., state, local and non-U.S. laws, rules and regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
• Ongoing operations, administrative, accounting, reporting, account maintenance, and other processes.
• Maintaining the safety, security and integrity of our products and services, databases, technology assets and business, including detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity.
Will your information be shared with anyone else?
We may disclose your personal information to a third party for business purposes. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
• We share your personal information with the following categories of third parties: payment processors or the purposes of facilitating a payment.
• Disclosures of personal information for a business purpose.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.
We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.
Personal information sources
We obtain the categories of personal information listed above directly from you (e.g., from forms you complete on our website), or indirectly from you (e.g., from observing your actions on our website).
Information excluded from our privacy notice
Under this privacy notice, personal information does not include (i) publicly available information from government records; (ii) de-identified or aggregated consumer information; (iii) information excluded from the CCPA’s scope and covered by certain sector-specific privacy laws, including but not limited to Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
California Residents
California Civil Code Section § 1798.83, also known as the "Shine The Light" law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to info@thewolfltd.co. For more information on California’s “Shine the Light” law, please visit the California Legislative Information website at: https://leginfo.legislature.ca.gov.
If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us at info@thewolfltd.co and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below.
The California Code of Regulations defines "residents" as:
1) every individual who is in the State of California for other than a temporary or transitory purpose and
2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.
Your rights and choices
This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
• whether we collect and use your personal information;
• the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell or share personal information to third parties;
• the categories of personal information that we sold, shared, or disclosed for a business purpose;
• the categories of third parties with whom we share that personal information for a business purpose;
• the business or commercial purpose for collecting, selling or sharing personal information;
• the specific pieces of personal information we collected about you (also called a data portability request);
• we may share your personal information with the following categories of third parties: payment processors or the purposes of facilitating a payment.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Deletion Request Rights. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Please send a request for “Deletion of Data” to info@thewolfltd.co. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Correction Rights. You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
Right to Non-Discrimination. We will not discriminate against you for exercising your rights under the CCPA. Unless permitted by the CCPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Right to Limit Use and Disclosure of Sensitive Personal Information. We do not process consumer’s sensitive personal information.
Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, you need to submit a verifiable consumer request to us by sending us a request in writing to info@thewolfltd.co. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Other privacy rights
• You may object to the processing of your personal information.
• You may request correction of your personal data if it is incorrect or no longer relevant or ask to restrict the processing of the information.
• You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
• You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To exercise these rights, you can contact us at info@thewolfltd.co, or by referring to the contact details at the bottom of this privacy notice. If you have a complaint about how we handle your data, we would like to hear from you.
DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: You may have additional rights based on the country you reside in.
Australia and New Zealand
We collect and process your personal information under the obligations and conditions set by
Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).
This privacy notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.
If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:
• offer you the products or services that you want
• respond to or help with your requests
At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us at info@thewolfltd.co.
If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.
Republic of South Africa
At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us at info@thewolfltd.co.
If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:
The Information Regulator (South Africa)
General enquiries: enquiries@inforegulator.org.za
Complaints (complete POPIA/PAIA form5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za
CHANGES TO PRIVACY NOTICE
We reserve the right to update or modify this privacy notice at any time by posting the latest version of this privacy policy on our website. This privacy notice was last updated on the date indicated at the top of this page. Please review this policy periodically, and prior to providing any personal information. Your continued use of the Services after any changes or revisions to this privacy notice shall indicate your agreement with the terms set forth in the revised privacy policy.
MISCELLANEOUS
The provisions in our Terms of Use are hereby incorporated by reference.
CONTACT US
If you have any questions or concerns regarding this privacy notice, please contact us at info@thewolfltd.co or by post at:
The Wolf Ltd. A Limited Liability Company
21200 Oxnard Street #6214
Woodland Hills, CA 91365
United States