THE APP APPLICATION PRIVACY POLICY

Your trust is our priority. Transparency and clarity are fundamental principles guiding our relationship with you.

1. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?

Contact Information:
Name: ARLAMOW PTY LTD (“THE APP”)
Registered Office: Level 5, 991 Whitehorse Road, Box Hill, Victoria 3128, Australia
ABN: 682 959 682
Data Protection Contact: privacy@law.theapp.com

2. SCOPE OF THIS POLICY

When you access and use the WAIWIN Application (the “Application“) or use any other means involving the processing of personal data, through the Application or any of the WAIWIN websites linked to the Application, you agree to accept this Privacy Policy.

References in this Privacy Policy to the Application, and the WAIWIN website(s), shall be interchangeable and shall be construed together.

In WAIWIN we provide you with information so that, prior to filling in your personal data, you can access the Privacy Policy and any other relevant information regarding Data Protection. 

This Privacy Policy may be modified by the owner of the Application, when necessary, but WAIWIN will communicate it to you by the appropriate means so that you can be aware of it and continue using its “Services”. The fact of continuing to enjoy its “Services” after having duly notified you of the modifications, will mean that you agree with them, except in those cases in which express consent is necessary.

3. FUNDAMENTAL PRINCIPLES

• • WAIWIN will never request personal information unless it is necessary to provide the services that are requested.
  • WAIWIN will never share Users’ personal information with anyone, except as provided in this Privacy Policy, to comply with the law or if expressly authorized by you, or when necessary to access or facilitate the services of this Application.
  • WAIWIN will never use your personal data for a purpose other than that expressed in this Privacy Policy.

4. FOR WHAT PURPOSE DOES WAIWIN USE YOUR PERSONAL DATA?

WAIWIN may process the personal data collected from this Application for the following purposes:

1. Contact: To manage the personal data provided by the Users of the Application, or who contact WAIWIN through any channel. Your data will be processed for the purpose of managing such contact and the relationship with the User, their use of the Application, offering information about WAIWIN services, as well as dealing with any query, doubt, request or comment that you send to WAIWIN through the channels provided for such purpose. 

Use of the Application. To treat and process the personal data provided or necessary for the effective use of the Application by the Users, as well as any additional or complementary service or provision that is necessary for that purpose, or for the purpose of optimizing and introducing improvements to the Application. The data will be processed in order to manage your use of the Application and the relationship with WAIWIN for the purposes of the same, that is, to manage payments from the virtual piggy bank of the same, as well as to offer you recommendations of activities in the different locations reported by the User, and to proceed to the contracting, if applicable, of the same.

5. WITH WHOM DOES WAIWIN SHARE YOUR PERSONAL DATA?

WAIWIN manages the disclosure of Users’ personal data, both internally and with specific third parties. This transfer of information includes external service providers, other external agents and is done in situations related to business transactions and legal requirements.

Users’ personal data is shared in the following circumstances:

1. Collaboration with External Service Providers: WAIWIN shares data with external entities to manage the Application and its services, fulfill requests or respond to inquiries. These providers perform tasks on behalf of WAIWIN, such as hosting or operating the Application or its websites, processing payments, analyzing data, or offering complementary tourism or leisure services or activities, when authorized and/or consented to by you. Although they access personal data necessary for their work, they are not authorized to use it for other purposes. They must comply with the guidelines of this Privacy Notice and with the laws and regulations in force regarding data protection.
2. Disclosure for Legal Requirements: WAIWIN may transfer and disclose Users’ personal data to third parties:
   1. To comply with legal obligations.
   2. When it is believed in good faith that an applicable law requires it.
   3. At the request of government authorities in ongoing investigations. 
   4. To verify or enforce compliance with the Application’s “Terms of Use” or other relevant policies.
   5. To detect and protect against fraud, technical or security vulnerabilities. 
   6. To respond to emergency situations; or
   7. To protect the rights, property, safety or security of third parties, visitors to WAIWIN´s website or the general public

6. INTERNATIONAL TRANSFER OF DATA

As part of our services, your personal data may be transferred to and processed in countries outside your jurisdiction of residence, including those that may not offer the same level of data protection as your country. 

At WAIWIN we ensure that all international data transfers comply with applicable data protection regulations. Where data is transferred outside the European Economic Area, Switzerland or the United Kingdom, we ensure that such transfers are carried out in accordance with appropriate and required security measures to ensure that your data is adequately protected. 

If you have any questions about the international transfer of your data, please do not hesitate to contact us.

7. WHERE DOES THE PERSONAL DATA THAT WAIWIN PROCESSES COME FROM?

The data that WAIWIN processes because of the User’s use of the Application and the interactions carried out by the User through the Application come from the following sources:

• Data provided by the User by filling in the forms made available by WAIWIN, by sending e-mails or by any other means by which the User enters communication with WAIWIN.
• Data generated because of navigation and use by the User of the Application.
• Data generated because of the development, processing and maintenance of the relationship established between the User and WAIWIN.

WAIWIN may process personal data of the following types, depending on the relationship established with the User:

• Identifying data (e.g., first and last name, e-mail address, postal address, telephone number, IP address, location, etc.).
• Financial data (e.g. payment data).
• Application navigation and location data.

Types of Data Processed:

• Identifying Data: Name, email, phone number, location, IP address.
• Financial Data: Payment details.
• Usage Data: Navigation history and location-based data.

8. WHAT IS THE LEGAL BASIS FOR WAIWIN TO PROCESS YOUR PERSONAL DATA?

WAIWIN processes the personal data provided by the Users in its Application in accordance with the following legitimate basis: the processing of their data for the purpose of “Contact” and “Use of the Application” is based on the management and processing of the legal relationship established between the User and WAIWIN, that is, in the management of their own request, in the maintenance of contact between the parties and, where appropriate, the use of the tools of the Application to facilitate the fulfillment of the obligations of the users of the directory managed by the entity.

9. HOW LONG WILL WAIWIN KEEP YOUR PERSONAL INFORMATION?

The retention period of personal data will vary depending on the processing. In any case, your data will be kept for the duration of the legal relationship. Once the legal relationship has ended, WAIWIN will keep your data blocked during the prescription periods of the obligations that may have arisen from the processing and/or the applicable legal periods, remaining at the disposal of the competent authorities for the attention of the possible responsibilities arising from the processing.

By way of example and not limitation, the following are some of the conservation periods.

• When there is a contract or any type of legal relationship that links you to WAIWIN, it will keep the data provided for the time necessary to comply with the contractual relationship or legal obligations and, in any case, during the statute of limitations required by current legislation. The data will be eliminated afterwards in general, except if it is necessary to keep them to comply with any legal provision or administrative and/or judicial requirement. 
• If it complies with the legal requirements, WAIWIN will process your data for the time necessary to deal with and manage the queries you make through the “Contact” section of the Website and, in the case of sending you information about WAIWIN‘s services, for as long as you do not object to such sending.

WAIWIN will keep your personal data processed because of browsing the Application, as long as you do not revoke your consent to it, and in any case, for a period of 1 year.

10. HOW YOU CAN EXERCISE YOUR RIGHTS

As the right holder of your personal information, you have control over such data. In this way, WAIWIN also ensures that the information is accurate and truthful.

The rights that can be exercised are:

• Right of Access: you may consult whether WAIWIN is processing personal data concerning you.
• Right of Rectification and Deletion: you may access your personal information and request the rectification or deletion of your data when they are inaccurate, or you consider that they are no longer necessary for the purposes for which they were collected. To exercise the right of deletion of your data as an employer, or to limit its use in the future, or to oppose the indicated processing, you must justify or prove the existence of a legitimate and well-founded reason, which prevails over the legitimate interest of WAIWIN for the processing of the data in order to comply with the legal obligation to enforce the rights of remuneration that it administers. In turn, the “right of erasure” is not applicable when the processing is necessary for compliance with a legal obligation requiring the processing of data imposed by Union or Member State law applicable to the controller, or for the formulation, exercise or defense of claims.
• Right of Opposition: you may oppose the processing of your data, unless, for compelling legitimate reasons, or in the exercise or defense of possible claims, WAIWIN keeps them duly blocked for the corresponding periods while the legal obligations subsist.
• Right of Limitation to the processing: you may request the limitation of the processing of your personal information while the accuracy or lawfulness of your data is being challenged, during the exercise or defense of possible claims or litigation.
• Right of Portability: you may request the portability of the data you have provided to us to another data controller, under certain circumstances.

You may exercise your rights free of charge.

How can you complain to the Control Authority?

If you believe that there is a problem with the way in which WAIWIN is handling your data, you can address your complaints to the Data Protection Officer team at privacy@law.theapp.com, or to the appropriate data protection supervisory authority.

11. SECURITY

WAIWIN maintains the highest levels of security required by law to protect your personal data against accidental loss and against unauthorized access, processing, or disclosure, taking into account the state of technology, the nature of the data stored and the risks to which they are exposed. When WAIWIN receives your data, it uses rigorous procedures and security features to prevent any unauthorized access. 

The actions described in this section and aimed at ensuring an adequate level of security for the detected risk shall include, if necessary, the following measures:

1. Pseudonymization and encryption of personal data.
2. Measures capable of ensuring the permanent confidentiality, integrity, availability and resilience of processing systems and services.
3. Measures capable of restoring availability and access to personal data quickly in the event of a physical or technical incident.
4. Existence of a process of regular verification, evaluation and assessment of the effectiveness of technical and organizational measures to ensure the security of processing.
5. Periodic assessment of the risk of accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized disclosure of or access to such data.
6. Measures to ensure that any person acting under the authority of WAIWIN who has access to personal data can only process such data on instructions from WAIWIN.

12. CONFIDENTIALITY

The personal data that may be collected will be treated with absolute confidentiality, and WAIWIN undertakes to keep them secret and to guarantee the duty to store them by adopting all the necessary measures to avoid their alteration, loss and unauthorized processing or access, in accordance with the provisions of the applicable legislation.

13. ACCEPTANCE AND CONSENT

You declare that you have been informed of the conditions on the protection of personal data, accepting and consenting to the processing of the same by WAIWIN in the manner and for the purposes indicated in this Privacy Policy.

14. CHANGES IN THE PRIVACY POLICY

WAIWIN reserves the right to modify this Policy in order to adapt it to new legislation or jurisprudence, as well as to practices in the sector. In such cases, WAIWIN will announce on this page the changes introduced reasonably in advance of their implementation.

15. RESPONSIBILITY

You will be solely responsible for the completion of the forms with false, inaccurate, incomplete or outdated data.

You are viewing the latest version as of February 2025.