Detailed Information of the provacy policy and cookies of Wayra

2. What data do we handle about you?

‍Summary: We have information about who you are and how you use the services of Wayra.

‍

Detail:The information we have about you includes information about who you are and how you use the services of Wayra.

• Who you are: Your name and surnames, user ID and email.
• ‍How do you use the services of Wayra: Calls to which you have applied and startup profiles that you have created in Wayra.

‍

3. How do we obtain and where does the data come from?

‍Summary: It is mainly you who directly provides us with your data.

‍

Detail:

‍Mainly we obtain your data directly from you:

• You provide them to us directly through the registration form, the configuration options of your profile once logged in https://wayra.co.uk/, or when you contact us so that we can give you support and contribute additional data. Remember that the personal information provided directly must always be real, accurate and up-to-date. We will put at your disposal the necessary tools so you can update or rectify this information.
  
• We observe them when you use or we obtain them from your device (eg the operating system of your device or the network from which you connect). Remember that you can review and manage the permissions you grant to Wayra to obtain data from your device through the options available on your terminal (Android, iOS or web).

‍

‍

4. For what and why do we use your data?

‍Summary: We use your data to provide you with the service of Wayra. We also use them for other legitimate purposes with the goal of communicating with you, knowing the use you give to Wayra or even complying with some legal obligations that are applicable to us.

Detalle:

We manage your data to:

• That you can enjoy Wayra and all its functionalities (rendering the service).
• Communicate and be in contact with you with the goal of informing you about the products andservices that are relevant to you through various channels such as, for example, the email, from Wayra. To be honest with you, our goal is that you download and register in Wayra (if you have not already done so), as well as that you are happy with the services Wayra, know them and use them actively.
• Know how you use the products and services Wayra to:

                ○ Detect trends and correlations in order to understand and predict in an aggregate way the use of these services and the needs you may have as a user.

                ○ Make better business decisions, such as how to improve the products and services Wayra, as well as your experience, or how to make the communication actions that we indicated in the previous point more effective.

                ○ Prepare reports with added data on the evolution in the number of active users or how certain functionalities are used.

                ○ Check if you have performed a specific action through Wayra.○ Monitor compliance with quality of service levels (eg to debug and detect errors).

                ○ Prevent and detect fraudulent, malicious or illegal activities (especially when this may affect other users).

• Conduct surveys in order to ask you and know your opinion about the Wayra or its services and functionalities.
• Collaborate and respond to orders or requirements of the authorities.
• Report or make known to the authorities fraudulent, malicious or presumably illegal actions.
• Defend against lawsuits, complaints and / or claims of any kind.
• Guarantee the physical security of the networks and the information technologies that we use to provide you with our services and products.

Lastly, it is possible that in the future we need to manage your data for additional purposes with the aim of continuing to innovate and offer you added value services.

Do not worry, in that case we will always analyze if these purposes are compatible with your expectations and with the principles that govern our privacy policy and cookies.

In any case, we will previously take all necessary actions to ensure compatibility such as, for example,additional transparency, control or security measures.

We use your data for the above purposes because:

• We need them so that you can enjoy Wayra and its functionalities in accordance with its conditions of use.
• We need them to comply with certain legal and regulatory obligations (eg, obligation to collaborate and respond to the requirements of the authorities).
• Some of the purposes are necessary for the legitimate business interests of Telefónica S.A. ,although you can always oppose them (eg, communicate and be in contact with you to inform you about products and services Wayra).
• Because you have given us your permission for us to process your data for certain purposes (eg,those permissions you grant us during registration so that we can access information about your device).

‍

5. How long do we keep your data?

‍Resumen: There are certain reasons that legitimize us to conserve your data, although we will only conserve and manage them as long as they are necessary for the purposes indicated in point 4 of this policy. The specific conservation period will depend on the type of data and for what and why they are used.

Detalle: In general, we will no longer keep your data at the time it is not necessary to continue providing you with the service of Wayra. However, there are some exceptions to this general rule that we explain below.

‍

In this matter, there are some purposes that persist and continue even after the removal of Wayra account.Specifically, we must continue to keep some information about you and how you used Wayra to:

• Have a history of how you used Wayra.
• Comply with certain legal data conservation obligations applicable to Telefónica S.A.
• Collaborate with the authorities and respond to their information requirements.
• Defend against lawsuits, complaints and / or claims.
• Prevent fraud, abuse or illicit actions.
• Test and verify that you had a user account in Wayra.

However, during this additional period we will apply a series of additional measures and actions to ensurethe protection of your information and your privacy. This type of measures may include, for example, the functional separation, pseudonymization, and / or encryption of your data and information.

Also, we will take all reasonable measures to ensure that your data is rectified or deleted when inaccurate.

6. Who has access to your data (besides Telefónica S.A.)?

‍Summary: Besides Telefónica S.A., others who have access to your personal data are: our suppliers and collaborators, other companies of the Telefónica Group, as well as the authorities with whom we collaborate and interact. The access to your data that we provide to these third parties is always for lawful purposes and only during the period of time strictly necessary for it.

Detail: We need to share your data with certain third parties that we indicate below, always in relation to the specific purposes for which we treat your data, described in point 4, and for a period strictly necessary for it.

Specifically, this involves giving access to your data to:

• Our suppliers and collaborators, as well as the companies that they subcontract, which help us to provide the services of Wayra, to communicate and be in contact with you, as well as to conduct surveys and to know how you use Wayra. Some of these suppliers and collaborators (eg,Amazon, Google or Telefonica USA) are located in the United States and their services,infrastructure, systems or contracted tools are always contracted by Telefónica S.A. under theEU-US agreement PrivacyShield, which gives maximum guarantees for the transfer of your datathat is made to that country
• Other Telefónica Group companies whose identity can be consulted in the following link, with aninternal administrative and commercial management purpose, so that companies cancommunicate and contact you with information about products, promotions, offers and / orservices.
• Authorities (eg, security forces and state security forces or judicial bodies), national and / or international, that require legal access to your information, as well as, those other Authorities with whom we need to share your information to defend ourselves against possible law suits,complaints and / or claims of any kind, as well as to bring to your knowledge fraudulent, maliciousor allegedly illegal actions.

In any case, Telefónica S.A. always guarantees the highest level of protection during the access that these third parties have to your data and information, for example, reaching data management agreements with them or through the establishment of measures of appropriate protection to ensure confidentiality and secure treatment of your data.

7. What are your rights and how can you control your data?

‍Summary: The regulations give you a series of rights regarding the data and information that we manage about you.Specifically, the rights of access, rectification, deletion, limitation, opposition, portability, as well as not being subject to automated decisions and to remove your consent at any time. Some of these rights can be made directly through the Wayra app and for others you will have to write to the address privacidad@wayra.co to execute them.

Detail:

You can perform the following data protection rights against Telefónica S.A.:

• Access right: right to request the details of the data we have about you and how we treat them,as well as obtaining a copy of them.
• Right of rectification: right to obtain the rectification of your inaccurate or erroneous data, as well as to complete those that are incomplete.
• Right of removal: right to request the elimination or deletion of your data and information under certain circumstances. However, keep in mind that there are certain occasions in which Telefónica S.A. is legally entitled to continue to keep and process your data (eg, for compliance with a legal obligation to conserve data).
• Right of limitation: right to restrict or limit the management of your data in certain circumstances(eg, if data deletion applies but, instead of eliminating them, you prefer that we block them and handle them only for the purpose of their preservation since you will need them later to file aclaim). Again, keep in mind that there may be times when Telefónica S.A. is legally entitled to reject your limitation request.
• Right of opposition: right to oppose Telefónica S.A. to manage your data for a specific purpose,in certain circumstances provided in the regulations and related to your personal situation. In some cases we provide you with simple options to oppose you directly through the app (eg,opposition to receive commercial communications sent by Telefónica S.A.) and in other cases you must contact us through email so that our Privacy team can evaluate your request in more detail.
• Right to data portability: right to receive your data in a commonly used format that allows you to transport them to another company, as well as, if applicable, to request Telefónica S.A. direct transmission to another company if it is technically possible. Remember that the right to data portability is different from the right to portability of your phone number.
• Right to not be the subject of automated decisions: the right to oppose being the subject of a decision based solely on the automated processing of data (without human intervention),including the preparation of profiles, which produces legal effects on you or affects you from a meaningful way.
• Right to remove consent at any time: right to remove your consent at any time to the management of your data for a specific purpose, when based on legitimating basis.

You can check the full scope and detail of these rights on the website of the Spanish Data ProtectionAgency (SDPA).

‍

In general, you will be able to execute all these rights (at any time and for free) by writing to the privacy team of Telefónica S.A. at privacidad@wayra.co

‍

For this, it is important to bear in mind that:

• When you exercise a right, you must provide a copy of your official identity document (Example:DNI, NIE or Passport) and, if possible, send your request from the same email address that you used to register with Wayra.In the event that you decide to exercise one of these rights through a representative, it will be necessary to provide in the application, the documentation proving this condition (Example: in the case of a voluntary representative, the power of representation in which shows the powers that allow the exercise of such rights in your name).
• The requests for the exercise of rights must be as specific and detailed as possible, indicating in them the specific right that you wish to exercise.

However, you can exercise your right to oppose the receipt of commercial communications, by any channel, from Telefónica S.A., just send us an email to privacidad@wayra.co

Lastly, remember that you also have the right to file a complaint with a Data Protection Control Authority(eg, the Spanish Data Protection Agency, whose contact information you can consult it here), especially if you estimate or understand that Telefónica S.A. has not correctly fulfilled the exercise of your data protection rights.

8. How do we use cookies and how can you manage them?

‍Summary: Telefónica S.A. uses own and third-party cookies to give you a more personalized service, to know how you use the services and products of Wayra and, where appropriate, to show you advertising related to your preferences and browsing habits. If you use Wayra, we understand that you accept its use.

Details: A cookie is a file that is downloaded to your device when accessing certain web pages and / or applications. Cookies allow, among other things, store and retrieve information about your number of visits, browsing habits or the type of device and, depending on the information they contain and the way you use it, they can be used to recognize you as a user

Please note that in order to use Wayra it is necessary that you have cookies enabled, especially those of a technical nature that are necessary for Telefónica S.A. to identify you as a registered user each time you access our website or application. Telefónica S.A uses the following types of cookies, which are treated either by us directly or by collaborating third parties:

• Technical cookies: These are those used by Telefónica S.A that allow the user to navigate and use the different options or services offered, such as controlling traffic and data communication,identifying the session, access restricted parts, remember the items that are in an order, perform the purchase process of an order, make the registration request, use security elements during navigation or store, disseminate and / or share content
• Personalization Cookies: Those used by Telefónica S.A that allow the user to access Wayra with some predefined general characteristics based on a series of criteria in their device, such as language, the type of browser, the regional configuration from where you access, etc.
• Analysis Cookies: These are those used by Telefónica S.A. and by third parties (GOOGLEANALYTICS, GOOGLE TAG MANAGER, GOOGLE FIREBASE, AKAMAI, COMSCORE,MIXPANEL, HOTJAR, HOCKEY APPS and HUBSPOT) that allow quantifying the number of users and thus perform the measurement and statistical analysis of the use and activity that users do, as well as develop navigation profiles to be able to introduce improvements in products and services of Wayra.
• Advertising and behavioral advertising cookies: These are those used by Telefónica S.A. and by our collaborators who manage the spaces that serve advertising of Telefónica S.A.(APPSFLYER, PUBMATIC, ADSRVR, RUBICON PROJECT, SMAATO, CONNEXITY , TURN,SIMPLIFI, AFFILINET, BING ADS, BLUEKAI, DOUBLECLICK, YOUTUBE, CRITEO,MOVISTAR, GOOGLE, YAHOO, FACEBOOK, TWITTER, ROCKETFUEL, MEDIAMATH,SMART, APPNEXUS, OPENX, ADGRAVITY, SMARTCLIP, ADFORM, HUBSPOT, CRAZY EGG,PLATFORM161 , ROCKET FUEL and / or THE TRADE DESK) that allow us to disseminate adequate and relevant advertising, measure the effectiveness of our online campaigns, as well as adapt the content of the ads to the navigation profile of each user on the Internet.

‍

Remember that you can allow, block or delete these cookies at any time through the configuration options of your device or terminal, as well as your internet browser. To do this, you can find the most up-to-date support information on these devices or browsers to know how you can eliminate cookies, since the way to do it can be different between different versions and operating systems. As an example:

• For Internet Explorer, click here
• For Mozilla Firefox, click here
• For Google Chrome, click here
• ForSafari, click here

In case you use any other Internet browser, we recommend that you look for the different cookie management options that may be available, as well as, in general, any other tools available in the market for the blocking and / or administration of cookies (eg, Ghostery o Disconnect)

For more information, you can write to us at privacidad@wayra.co

9. How do we protect your data?

‍Summary: Telefónica S.A. guarantees the security, secrecy and confidentiality of your data, communications and personal information adapted to the most demanding and robust security measures, and putting at your disposal tools and functionalities that allow you to control access to your Wayra account.

Details: Telefónica S.A. is Controler for ensuring the security, secrecy and confidentiality of your data,communications and personal information. Therefore, as part of our commitment and in compliance with current legislation, we have adopted the most demanding and robust security measures and technical means to prevent their loss, msuse or access without your authorization.

Also, we promise to act quickly and responsibly in the event that the security of your data may be in danger, and to inform you if necessary.

10. What do you have to keep in mind especially when using Wayra?

‍Summary: You Have to keep in mind certain aspects related to the minimum age of use of Wayra, the quality of the data you provide us, as well as the removal of your user account.

Detail:

We recommend that you pay special attention to the following when registering and using Wayra::

• Minimum age of use: in order to register and use Wayra you must be over 16 years old or have the authorization of your parents and / or legal guardians. Therefore, by signing up for Wayra, you guarantee to Telefónica S.A. that you are older than that age or, otherwise, that you have the proper authorization. We can contact you at any time to verify if you meet this condition.
• Quality of the data you provide: your personal data, mobile phone number and other information that you provide us with in the registration and / or use of the services of Wayra must always be real, accurate and up-to-date. We provide you with the necessary tools and options to control and update your personal information.
• Removal of your user account: in general, there may be two situations in which the technical deactivation of your user account is carried out: 1) that you voluntarily request us to proceed to unsubscribe your user account in Wayra as explained in point 7 of this policy, and 2) that fromTelefónica S.A. proceed to the technical deactivation of your user account (eg, in cases in which we detect that you have breached the conditions of use of the service). In case of removal, you will lose the information and data that you may have in Wayra, as well as the right to use any benefits or services that you may have had at the time of removal and / or have previously contracted as a user of Wayra.

‍