1. Introduction

This website, www.notesonhope.com (“Site”), is operated by Wallflower Limited (hereinafter referred to as “we”, “our”, “us” or “the Company”).

For the purpose of the relevant data protection laws, we are the data controller of Your Personal Information (as defined below) for the purpose of Data Protection Legislation (as defined below).

For any access request, questions, or inquiries about how we use Your Personal Information, please contact us at contact@notesonhope.com.

We do not take Your trusting us with Your information for granted. The privacy of our Users is important to us, and we are committed to safeguarding it responsibly and in accordance with the legal requirements of the countries in which we operate.

Hence, this Privacy Policy explains the type of Your Personal Information which we collect, why we collect it, and what we do with it.

2. Overview

This Privacy Policy describes Your privacy rights regarding how and when we collect, use, store, share and protect Your Personal information. We will tell you in detail how we use and share your personal information and explain your rights regarding how we use your personal information.

By visiting and accessing our Site, you are accepting and consenting to the terms and conditions in this Policy.

3. Definitions

Data Protection Legislation: means the applicable data protection laws and all other application legislation relating to privacy or data protection.

Personal Information: means any information that relates to you and that identifies you either directly from that information or indirectly, by reference to other information that we have access to. The personal data that we collect, and how we collect it, depends upon how you interact with us.

Categories of personal data that we might collect include ; Contact information such as name, email address and telephone number; Billing and financial information such as billing address, bank account and payment information; and Device Data, including information on the devices with which you access the Site.

User, You, or Your: user of the Site.

4. Personal Information We May Collect About You

We may collect, record, and use information about You in physical and electronic form and will hold, use, and otherwise process this data in accordance with the Data Protection Legislation and as set out in this Policy.

The Personal Information we collect and use may include, amongst other things:

• • Identity Data: Information such as, Your full name(s), Your government-issued identity number, and Your date of birth;
  • Contact Data: This is data that we use to contact You, such as Your name, residential address, email address, telephone number, details of the device You use and billing details;
  • Usage Data: When You access the Site, our servers automatically record information about how You our Site including links You have clicked on, length of visit on certain pages, unique device identifier, log-in information, location and other device details;
  • Financial Data: Information, such as credit card, Bank Verification Number, debit card, personal account number or bank account information, the date and the total amount of transaction, and other information provided by financial;
  • Marketing and Communications Data: This includes both a record of Your decision to subscribe or to withdraw from receiving marketing materials from us or from our third parties;
  • Records of Your discussions with us if we contact You and if You contact us; and
  • Information about Your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.

We may also collect, store, use and transfer non-Personal Information or anonymised data such as statistical or demographic data. [Aggregated data could include Your personal data but is not considered personal data in law as this data will not directly or indirectly reveal Your identity. For example, we may aggregate Your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data to include Your personal data so that it can directly or indirectly identify You, we treat the combined data as personal data, which will be subject to the terms of this Privacy Policy and the Data Protection Legislation.]

5. How We Collect Your Personal Information and Why We Have It

The Personal Information we have about You is directly made available to us when You:

• • Access our Site;
  • Contact our customer support team;
  • Fill our online forms;
  • Use our Site and we collect information about your visit and how you interact with our website; or
  • Contact Us.

6. Our Legal Basis for Processing Your Personal Information

We only use Your Personal Information for a specific purpose; and before we do so, we must have a legal reason. For example, when it is necessary for us to perform a contract with You for our services, for our legitimate interest, or where You have given us Your consent, or to fulfil our legal obligations. These are all known as the “legal or lawful basis for processing”.

The legal or lawful basis we rely on for processing Your Personal Information by using our services:

• • Your consent: Where You agree to us collecting Your Personal Information by using our services.
    • With your consent, we may send marketing and promotional communications by email, SMS and push notifications (depending on your choice of contact). For more information please see the Marketing section of this policy;
    • Surveys: engaging with You for the purposes of obtaining Your views on our services.
  • We have a contractual obligation: Without Your Personal Information, we cannot provide our services to You.
  • We have a legal obligation: To ensure we are fully compliant with all applicable Data Protection Legislation.
  • We have a legitimate interest: We may also collect Your Personal Information where we have a legitimate interest to do so, provided that Your rights do not override such interests.

7. How We May Use Your Personal Information

We may Use Your Personal Information we collect to:

• • carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
  • provide you with information about other services we offer that are similar to those that you have already purchased or enquired about;
  • provide you with information about goods, services, opportunities or events that may be of interest you;
  • notify you about changes to our service;
  • ensure that content from our website is presented in the most effective manner for you and for your computer;
  • to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our website to ensure that content is presented in the most effective manner for you and for your computer;
  • as part of our efforts to protect our business and keep our website safe and secure;
  • comply with Data Protection Legislation and any other applicable laws.

Please note that we may process Your Personal Information without Your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

8. Data Security and Retention
   • The security of Your Personal Information is important to the Company. We are committed to protecting the information we collect. We maintain administrative, technical, and physical controls designed to protect the Personal Information You provide, or we collect against loss or theft, as well as against any unauthorized access, risk of loss, disclosure, copying, misuse or modification.
   • Other security measures include but not limited to, secure servers, firewall, data encryption and granting access only to employees in order to fulfil their job responsibilities.
   • We are committed to conducting our business in accordance with the principles set out in this Privacy Policy in order to ensure that the confidentiality of Your Personal Information is protected and maintained. Transmitting information online is not entirely secure. As such, we cannot guarantee that all information provided online is secure. We would take all reasonable steps to ensure that Your Personal Information is secured and well protected.
   • We will only retain Personal Information on our servers for as long as is reasonably necessary as long as we are providing services to You. Your information is stored on our servers to the extent necessary to comply with regulatory obligations and for the purpose of fraud monitoring, detection and prevention.
   • To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of Your Personal Information, the purposes for which we process Your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Where we retain Your Personal Information, we do so in compliance with limitation periods under the applicable law.

9. Disclosing Your Personal Information

We may disclose or share Your Personal Information with third parties which include our affiliates, employees, officers, service providers, agents, suppliers, subcontractors as may be reasonably necessary for the purposes set out in this policy.

The Company only shares Personal Information with external third parties in the following limited circumstances:

• • We have Your consent. We require opt-in consent for the sharing of any Personal Information to a third party. The use of Your Personal Information by an authorized third party is subject to the third party’s Privacy Policy and the Company shall bear no liability for any breach which may arise from such authorization by You;
  • We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing Personal Information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures;
  • We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to
    • satisfy any applicable law, regulation, legal process or enforceable governmental request;
    • enforce applicable terms of service, including investigation of potential violations thereof;
    • detect, prevent, or otherwise address fraud, security or technical issues;
    • assess financial and insurance risks; or
    • protect against imminent harm to the rights, property or safety of the Company, its users or the public as required or permitted by law.
  • If the Company becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice before Personal Information is transferred and becomes subject to a different Privacy Policy.

10. Marketing

We may process Your Personal Information in order to contact You or send You marketing content and communication about our products, services or surveys. You may exercise Your right to object to such contact from us or opt out from the marketing content. Please note however that if You opt-out of marketing content, we may still send You messages relating to transactions and our services related to our ongoing business relationship. 

11. Your Data Protection Rights and Choices

Based on Your location and applicable laws, below are the rights You have as a user in relation to Your Personal Information:

• • Right to be informed;
  • Right to request access or copies to Your Personal Information by contacting us;
  • Right to request that the Company erases Your Personal Information. You have the right to ask us to erase Your Personal Information. Please note that this is a limited right which applies where the data is no longer required in relation to the purpose for which the data was collected and processed by us, or the processing has no legal justification. The exceptions to this right include where the applicable law requires the Company to retain a historical archive for public interest or such other related purposes, for the establishment, exercise or defence of legal claims or where we retain a core set of Your Personal Information to ensure we do not inadvertently contact You in future where You object to Your data being used for marketing purposes;
  • Right to correct or rectify any Personal Information that You provide which may be incorrect, out of date or inaccurate. You also have the right to ask us to complete information You think is incomplete;
  • Right to object to the processing of Your Personal Information for marketing purposes. You have a right to ask us not to contact You for marketing purposes by adjusting Your notification preference on the settings page or by opting out via the unsubscribe link in marketing emails we send You;
  • Right to object to processing: You have the right to object to the processing of Your Personal Information in certain circumstances. Please note that where You object to us processing Your Personal Information, we might be unable to provide the services to You;
  • Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

The basis of us processing Your Personal Information is Your consent. You also have the choice at any time to withdraw consent which You have provided.

If You wish to exercise any of the rights set above, please contact us using the contact information provided in the Contact Us segment below. Where we are unsure of Your identity, we might ask You for proof of Your identity for security reasons before dealing with Your request.

12. Minor

Our websites and applications are not directed at persons under the age of eighteen (18) and we do not collect any Personal Information knowingly or directly from minors.

Where You have any belief that the Company has mistakenly or unknowingly collected information from a minor, please contact us using the information provided under the Contact Us section to enable investigate and restrict such data.

13. Dispute Resolutions and Filing a Complaint

If You have any complaints regarding this Privacy Policy, please contact us. We will investigate and work on resolutions for complaints and disputes regarding use and disclosure of Personal Information within reasonable time in accordance with this Privacy Policy and in accordance with applicable data protection laws.

All access requests, questions, comments, complaints and other requests regarding the Privacy Policy should be sent to the email provided under the Contact Us section.

We may request additional details from You regarding Your complaints and keep records of Your requests and resolution.

14. Advertising and Sponsorship

Part of the Site may contain advertising and sponsorship. Advertisers and sponsors are responsible for ensuring that material submitted for inclusion on the Site complies with relevant laws and codes. We will not be responsible to you for any error or inaccuracy in advertising and sponsorship material.

We do not exercise control over the sites displayed or linked from within our Site. These other sites may place their own cookies, plug-ins or other files on Your computer, collect data or solicit Personal Information from You. The Company does not control these third-party websites and we are not responsible for their privacy statements. Please consult such third parties’ privacy statements and set appropriate controls from Your setting when using any third-party services.

15. Cookies

We use cookies (small files that we store on your browser or the hard drive of your computer if you agree) to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. By continuing to browse our website, you are agreeing to our use of cookies

We may use the information collected to make our website more relevant to your interests. We may also share this information with third parties for this purpose.

• • Essential cookies: These are cookies that are required for the operation of our website.
  • Analytical/performance cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it.
  • Functionality cookies: These are used to recognise you when you return to our website.
  • Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed.

Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) some parts of our website may become inaccessible or not function properly.

16. Updates to our Privacy Policy

From time to time, we may change, amend or review this Privacy Policy to reflect new services or changes in our Privacy Policy and place any updates on this page. All changes made will be posted on this page and where changes will materially affect You, we will notify You of this change by placing a notice online or via mail. If You keep using our services, You consent to all amendments of this Privacy Policy.

17. Contact Us

If you have any questions, comments or requests regarding this privacy policy please contact us at contact@notesonhope.com. We treat all complaints seriously, and investigate all issues brought to our attention.

Last updated: February 2023.