Privacy Policy

INTRODUCTION

This Privacy Notice (the “Privacy Notice”) describes the privacy policies applicable to access and use of the online financial system simulation service offered by Wadagso, Inc. (the “Service”). As a user of the Service, you are referred to in this Privacy Notice as “you” or “your”. Wadagso, Inc. is the developer of the Service and is referred to in this Privacy Notice as “Wadagso”, “we”, “us” or “our.” Wadagso is a Massachusetts corporation located at 649 Massachusetts Avenue, Suite 8, Cambridge, MA, 02139, United States.

This Privacy Notice is applicable to each person that uses the Service and outlines our privacy practices with respect to information that is collected when using the Service, including the ways in which personal information and data is collected, stored, used, disclosed and shared and an explanation of your choices and rights with respect to such information. By using the Service, you are acknowledging the terms of this Privacy Notice and consenting to our processing of your information as set forth in this Privacy Notice now and as amended by us from time to time. “Processing” means using or handling information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information and transferring it within the United States and internationally.

The Service is currently available as a non-chargeable beta offering, meaning that it is in a testing stage and only provides a limited set of features. You may access and use the Service without providing any personal information and without the Service collecting any information about you.

SCOPE

This Privacy Notice applies to the Information we obtain through your use of the Service. It does not apply to any other information collected by us through other means. If you have other agreements with us for our products and services, then those agreements control to the extent of any conflict. Further, this Privacy Notice does not cover the activities of third parties except as specifically stated.

WHAT INFORMATION DOES THE SERVICE COLLECT?

The Service collects information in the following instances:

  • Pre-registration: Use of our beta offering does not require you to provide personal information nor does it collect information about you or your device or location. At your option, you may pre-register for our product launch later in the year and if you do so, you will be required to provide your email address and, on an optional basis, other information about you, such as your name, your employer or your profession.
  • Support: If you have questions about the Service, you may contact us via our contact form. You may be asked to provide personal information in connection with your request, such as contact information. Any personal information shared will be used for support services only. You are not required to provide your name or other identifying information to request support. In some jurisdictions, an email address is considered to constitute personal information even if your name is not part of your email address.
  • Feedback: You may optionally provide feedback on features and functionality of the Service. It is not required for you to provide personally identifiable information in conjunction with your feedback.

HOW IS YOUR PERSONAL INFORMATION USED?

Wadagso uses personally identifiable information in the following ways:

  • To notify you when we launch the Service and to provide information regarding the Service.
  • When you request support in connection with your use of the Service we will respond to the email address used in your request.

YOUR CHOICES AND ACCESS TO YOUR INFORMATION

Accessing, Changing or Deleting Information

For individuals for which we do not collect personally identifiable information we do not provide any mechanism to access, change or delete such information.

If you have provided any personally identifiable information in the form of a pre-registration for the Service, a support request or as feedback, you can request at any time that we delete such information, as well as all email communications between you and us and not retain any copies. We will promptly do so. Requests can be made at support@wadagso.com.

HOW WE SHARE PERSONAL INFORMATION

Wadagso will not share any personally identifiable information that it obtains from you with third parties for any purpose other than to provide the Service. For example, we will not provide your information to third parties to enable them to market complementary products or services to you.

Wadagso uses service providers and other third party services to help perform essential business functions on our behalf, such as providing hosting services. We only share the information that these parties need to provide their services. Use by such third parties for their own purposes of any information collected from or about you is not permitted.

Compliance with Laws and Law Enforcement.

If legally requested, Wadagso may cooperate with government and law enforcement officials or private parties, to enforce and comply with the law. We may disclose any information about you, including personally identifiable information, to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims or legal process (including subpoenas), to protect the property and rights of Wadagso or a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.

INFORMATION SECURITY AND RETENTION

Information Security

We utilize reasonable administrative, physical, and electronic measures to reduce the risks of damage, loss of information, and unauthorized access or use of information. Information is stored internally and only those individuals with a need to know have access to such information. We require all third party service providers to adhere to comparable standards. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

The Service is available to users located throughout the world. Information collected by us or on behalf of us may be stored on our computers, on our mobile devices, or on our servers, and may be transferred to, accessed from, or stored and processed in the United States. Wadagso is based in the United States and processes information in the United States, which may not provide equivalent levels of data protection as your home jurisdiction.

Data Retention

We do not retain personally identifiable information for any longer than is needed for the uses described herein.

OTHER ISSUES

Children’s Privacy

We do not knowingly or intentionally collect personally identifiable information about people who are under 18 years of age.

Contacting Us

You may contact us with questions, requests and support issues, at support@wadagso.com.

Right to Non-Discrimination

If you exercise your consumer rights:

  • We will not deny goods or services to you
  • We will not charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties
  • We will not provide a different level or quality of goods or services to you

Cookies

We place cookies on the user’s device for the sake of retaining the user’s login status (session token). We do not place third-party cookies on the user’s device. Cookies are small text files that are stored on your computer. They are designed to hold a small amount of data specific to a website or server that can be accessed either by the website or your computer. We use cookies to capture information such as IP address and electronic activity data.

Do Not Track

Most modern web browsers give you the option to send a Do Not Track signal to the sites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a site should respond to this signal, and we do not take any action in response to this signal. Instead, in addition to publicly available third-party tools, we offer you the choices described in this policy to manage the collection and use of information about you.

Updates

This Privacy Notice was last updated on the date indicated above. This Privacy Notice may be updated from time to time at our discretion. We will notify you of any material changes by posting the revised Privacy Notice on our Website at smlt.io and updating the “Last Updated” date. Your continued use of the Service constitutes your consent to the amended Privacy Notice. You are advised to consult this Privacy Notice regularly for any changes we have made to it.

EU GDPR

GDPR Notice

The following disclosure is made pursuant to the European General Data Protection Regulation (GDPR). As a data controller of your personal data, we are committed to protecting and respecting your privacy in compliance with EU- General Data Protection Regulation (GDPR) 2016/679, dated April 27th 2016. This Privacy Notice explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure. This Privacy Notice applies to the use of our products and to our sales, marketing and customer contract fulfillment activities. You have the right to withdraw your consent at any time and to submit a complaint to the relevant supervisory data protection authority.

Collecting personal data based on consents:

Your consent to collection of personal data is based on voluntarily provided name, email address(es) and other personal information.

Collecting personal data based on contracts:

We use personal information in connection with providing support for our Service, as referenced in the Terms of Service for the Service.

Collecting personal data based on legitimate interest:

We may use personal information if it is considered to be of legitimate interest and if the privacy interests of the data subject do not override this interest. Normally, to establish the legal basis for data collection, an assessment has been made during which a mutual interest between Wadagso and the individual person has been identified. This legal basis is primarily related to our support function. We will always inform individuals about their privacy rights and the purpose for collecting personal data. Please refer to the Privacy Notice to understand What Information does Wadagso Collect along with our retention policy.

Your rights to your personal data

You have the following rights with respect to your personal data to the extent applicable:

  • The right to request a copy of your personal data that Wadagso holds about you.
  • The right to request that we correct your personal data if inaccurate or out of date.
  • The right to request that your personal data be deleted when it is no longer necessary for Wadagso to retain such data.
  • The right to withdraw any consent to personal data processing at any time.
  • The right to request that we provide you with your personal data and, if possible, to pass on this information directly (in a portable format) to another data controller when the processing is based on consent or contract.
  • The right to request a restriction on further data processing in case there is a dispute in relation to the accuracy or processing of your personal data.
  • The right to object to the processing of personal data in case data processing has been based on legitimate interest and/or direct marketing.

Contact Us

To ask questions or comment as regards the processing of Personal Data concerning persons within the European Union, Wadagso has designated the following representative:

Representative: Wadagso Data Protection Officer

Contact details: privacy@wadagso.com

The representative is mandated by Wadagso to be the recipient on behalf of Wadagso of all issues related to the processing of Personal Data concerning persons within the European Union.

The Company’s DPO: Wadagso Data Protection Officer