Privacy policy

This Privacy Notice for Really Good Business Ideas, LLC ("we", "us" or "our") describes how and why we might access, collect, store, use and share ("process") your personal information when you use our services ("Services"), including when you:

• Download and use our mobile application, WanderSwell, or any other application of ours that links to this Privacy Notice
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have questions or concerns, contact us at privacy@wanderswell.app.

Summary of key points

What personal information do we process? When you use our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the features you use. Learn more in section 1.

Do we process any sensitive personal information? No.

Do we collect any information from third parties? Only when you choose to sign in with Google or Apple, in which case they give us your name and email address. See section 6.

How do 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 process your information only when we have a valid legal reason to do so. See section 2.

Who do we share personal information with? Service providers who run parts of the Services for us, in specific situations. See section 4.

How do we keep your information safe? We have organizational and technical measures in place to protect your personal information. No system can be guaranteed to be 100% secure. See section 9.

What are your rights? Depending on where you live, you may have rights over your personal information. See section 11.

How do you exercise your rights? In the app, Settings lets you export all your data or delete your account. You can also email privacy@wanderswell.app. We will act on any request in accordance with applicable data protection laws.

1. What information do we collect?

Personal information you give us

In short: we collect personal information that you provide to us.

We collect personal information that you give us when you create an account, use the app, or contact us. It may include:

• your name
• your email address
• sign-in and account data
• your contact preferences
• the photos you add to your stamps
• the spots you save, and the dates and notes on your stamps
• spot suggestions and reports you send us: the spot name, the place you mark on the map, and any note you add
• your email address, if you ask on our website to be told when the app launches

Sensitive information. We do not process sensitive information.

Payment data. Payments are made through Apple App Store and Google Play in-app purchases. We do not receive or store your payment card details. We receive only confirmation of your purchase and whether your subscription is active. Apple, Google and RevenueCat handle payments and subscription status; their privacy notices are at apple.com/legal/privacy, policies.google.com/privacy and revenuecat.com/privacy.

Sign-in with Google or Apple. If you choose to sign in with Google or Apple, we receive certain profile information from them, described in section 6.

Information from the app

• Location. If you allow it, the app uses your device's location when you ask for spots near you or tap Near me on a map. Your location is used only on your device and is never stored or sent to us. You can change this permission at any time in your device's settings.
• Device features. The app asks for access to your photo library so you can add photos to your stamps, and to file storage only to save a data export to a folder you choose. You can change these permissions in your device's settings.
• Usage and device data. When you use the app, we record which features are used, together with a random identifier, your account identifier if you are signed in, the type of device (mobile), and your IP address. Our analytics provider may work out an approximate location (city and country) from your IP address. This helps us understand how the app is used and fix problems. You can turn it off in the app under Settings, Privacy, Share usage data.

Google API

Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

2. 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 prior explicit consent.

• To create and manage accounts. So you can create and sign in to your account, and to keep it working. (Retention: until you delete your account. Deleted information may remain in backups for up to 7 days.)
• To deliver the Services. To provide the features you use. (Retention: until you delete it or your account. Deleted information may remain in backups for up to 7 days.)
• Account and sign-in. To create your account, sign you in with email, Google or Apple, and keep you signed in. (Retention: until you delete your account. Deleted information may remain in backups for up to 7 days.)
• Saving and syncing your surf history. To store the spots you save, and the dates, notes and photos on your stamps, so they are on every device you sign in on. (Retention: until you delete your account. Deleted information may remain in backups for up to 7 days.)
• Passport and sharing. To show your name and surf history on your passport and create a share card when you choose to share it. (Retention: the card is made on your phone and we do not keep a copy.)
• Export and deletion. To give you a copy of your data when you ask, and to delete your account and everything in it when you ask. (Retention: the export is made on your phone and we do not keep a copy.)
• To respond to inquiries and offer support. (Retention: as long as needed to answer you.)
• To send administrative information, such as the sign-in email, and changes to our terms and policies. (Retention: until you delete your account.)
• To fulfill and manage your purchases, including subscriptions. (Retention: while your subscription is active, and afterwards for as long as the law requires us to keep purchase records.)
• To request feedback about your use of our Services. (Retention: until you delete your account or ask us to stop contacting you.)
• To tell you when the app launches, if you gave us your email address on our website for that purpose. That address is held by our email provider, Kit, and is used to email you about WanderSwell. Every email has an unsubscribe link, and you can unsubscribe at any time. (Retention: until you unsubscribe.)
• To send you marketing and promotional communications, if you have agreed to receive them. These may be tailored to the spots on your lists. You can opt out at any time; see section 11. (Retention: until you unsubscribe or delete your account.)
• To protect our Services, including security, diagnosing problems and preventing fraud. (Retention: until you delete your account.)
• To identify usage trends so we can improve the Services. (Retention: until you delete your account. After that, usage data is kept only in a form that no longer identifies you.)
• To understand the effectiveness of our marketing. (Retention: until you delete your account. After that, usage data is kept only in a form that no longer identifies you.)
• To improve the spot catalog. When you tell us about a spot that is missing or has a mistake, we use the spot name, the place you mark on the map and any note you add. (Retention: kept while the catalog needs it. If you delete your account, the report stays but is no longer linked to you.)
• To save or protect an individual's vital interest, such as to prevent harm.

3. What legal bases do we rely on to process your information?

In short: we only process your personal information when we have a valid legal reason to do so under applicable law.

If you are located in the EU or UK

The GDPR and UK GDPR require us to explain the legal bases we rely on:

• Consent. For example, marketing emails, which we send only if you have agreed. You can withdraw your consent at any time; see withdrawing your consent.
• Performance of a contract. To provide the Services you signed up for, including your account, your saved spots and stamps, and sync.
• Legitimate interests, where they are not outweighed by your interests and rights. We rely on them to:
  • analyze how our Services are used so we can improve them
  • support our marketing activities
  • diagnose problems and prevent fraud
  • understand how people use the Services so we can improve the experience
  • add missing spots and correct mistakes, so the catalog is accurate for everyone who uses it
• Legal obligations, such as cooperating with a law enforcement body or regulator, or defending our legal rights.
• Vital interests, to protect your vital interests or those of another person, such as where someone's safety is at risk.

If you are located in Canada

We may process your information if you have given us specific permission (express consent), or where your permission can be inferred (implied consent). You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted to process your information without your consent, for example: where it is clearly in your interests and consent cannot be obtained in time; for investigations and fraud detection; for business transactions under certain conditions; where required to comply with a subpoena, warrant or court order; where the information is publicly available as specified by the regulations; or to disclose de-identified information for approved research or statistics projects.

4. When and with whom do we share your personal information?

In short: with service providers who run parts of the Services for us, and in the specific situations below.

Service providers. We share data with third-party service providers who perform services for us and need access to do that work. We have contracts in place with them, designed to safeguard your personal information: they cannot use it except as we instruct, will not share it with anyone else, must protect it, and keep it only as long as we instruct. The categories of service providers are:

• Cloud computing services
• Data storage service providers
• User account registration and authentication services
• Data analytics services
• Communication and collaboration tools (sending and receiving email)
• Sales and marketing tools
• Maps providers
• App update and distribution services
• Testing tools
• Website hosting service providers
• Payment processors
• Performance monitoring tools

We may also share your information:

• Business transfers. In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or part of our business to another company.
• Google Maps. On Android, the app's satellite maps use Google Maps Platform. When a map loads, Google receives your IP address, device and operating system information, and the map area you are viewing. Google's use of this information is governed by the Google Privacy Policy. We do not store your location. You can stop the app using your location at any time in your device's settings.

5. Do we use cookies and other tracking technologies?

In short: the website uses none. The app stores two small identifiers on your device.

The wanderswell.app website does not use cookies or trackers.

The app stores:

• Your sign-in, so you stay signed in. This is necessary for the app to work.
• A random analytics identifier from our analytics provider, to understand how the app is used. You can turn this off in Settings, Privacy, Share usage data.

We do not use advertising trackers, and we do not allow third parties to track you in the app for advertising. On Android, Google Maps may store information on your device as described in the Google Privacy Policy.

To the extent any of these technologies are considered a "sale" or "sharing" under applicable US state laws, you can opt out as described in section 13.

6. How do we handle sign-in with Google or Apple?

In short: if you choose to sign in with Google or Apple, we receive your name and email address from them.

You can sign in with your Google or Apple account instead of by email. If you do, we receive your name, your email address, and, from Google, your profile picture. Apple may give us a private relay email address instead of your real one if you choose that option. We use this information only for the purposes described in this Privacy Notice. We do not control, and are not responsible for, how Google or Apple use your personal information; please review their privacy notices.

7. Is your information transferred internationally?

In short: yes. Our servers and service providers are in the United States.

Our servers are located in the United States. Wherever you are, your information may be transferred to, stored by and processed by us and our service providers (see section 4), including in the United States.

If you are in the European Economic Area, the United Kingdom or Switzerland, these countries may not have data protection laws as comprehensive as those in your country. We use the European Commission's Standard Contractual Clauses for transfers of personal information between us and our service providers. These require the recipients to protect personal information from the EEA or UK in accordance with European data protection laws. Our Standard Contractual Clauses can be provided on request.

8. How long do we keep your information?

In short: for as long as necessary for the purposes in this Privacy Notice, unless the law requires otherwise.

We keep personal information only for as long as necessary for the purposes set out in this Privacy Notice, unless a longer period is required or permitted by law (such as tax or accounting requirements). The retention period for each purpose is listed in section 2.

Deleted information may remain in our database backups for up to 7 days before it is permanently removed. Photos are not kept in backups: a deleted photo is removed straight away.

When we have no ongoing legitimate need to process your information, we delete or anonymize it. If that is not yet possible, for example because it is in a backup, we store it securely and isolate it from any further processing until it can be deleted.

9. How do we keep your information safe?

In short: through organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the personal information we process. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise that unauthorized third parties will never be able to defeat our security. You should only use the Services in a secure environment.

10. Do we collect information from minors?

In short: WanderSwell is for people aged 13 and over.

The Services are not directed to children under 13, and we do not knowingly collect personal information from them. In the EU and UK, if you are under the age at which you can consent for yourself in your country, a parent or guardian must agree to your use of the Services. If we learn that we have collected personal information from a child under 13, or without a required parent's agreement, we will delete the account and that information. If you believe this has happened, please contact us at privacy@wanderswell.app.

11. What are your privacy rights?

In short: depending on where you live, you may have rights that give you more access to and control over your personal information. You can review, change or delete your account at any time.

In some regions, like the EEA, UK, Switzerland and Canada, you may have the right (i) to request access to and a copy of your personal information, (ii) to request correction or erasure, (iii) to restrict processing, (iv) 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 processing. You can make a request using the details in section 17. We will act on any request in accordance with applicable data protection laws.

If you are in the UK and unhappy with how we have handled your personal information, you can complain to us at privacy@wanderswell.app or by post (see section 17). We will acknowledge your complaint within 30 days, investigate without undue delay, and keep you informed. If you are not happy with our final response, you can refer your complaint to the Information Commissioner's Office: ico.org.uk/make-a-complaint, helpline 0303 123 1113, or by post to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

If you are in the EEA or UK and believe we are processing your personal information unlawfully, you also have the right to complain to your Member State data protection authority or the UK data protection authority. In Switzerland, you can contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent. Where we rely on your consent, you can withdraw it at any time by contacting us or by changing your preferences in the app's Settings. This will not affect processing that happened before you withdrew it, or processing based on other legal grounds.

Opting out of marketing. You can unsubscribe from marketing emails at any time with the link in any of those emails, or by contacting us. We may still send you service messages that are necessary for your account, such as sign-in emails.

Your account. In the app's Settings you can change your name, export a copy of everything you have added, and delete your account. When you delete your account, we delete your information from our active databases. We may retain some information where needed to prevent fraud, troubleshoot problems, assist with investigations, enforce our terms or comply with legal requirements.

If you have questions about your privacy rights, email privacy@wanderswell.app.

12. Controls for do-not-track features

Some browsers and mobile operating systems include a Do-Not-Track ("DNT") setting. No uniform technology standard for recognizing DNT signals has been finalised, so we do not currently respond to them. If a standard is adopted that we must follow, we will describe it in a revised version of this Privacy Notice. California law requires us to tell you how we respond to DNT signals: because there is no industry or legal standard for recognizing them, we do not respond to them at this time.

13. Do United States residents have specific privacy rights?

In short: if you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah or Virginia, you may have the right to access, correct, get a copy of or delete your personal information, and to withdraw your consent. These rights may be limited in some circumstances by applicable law.

Categories of personal information we collect

The categories of personal information we have collected in the past twelve months:

We keep each category:

• A and B: as long as you have an account with us. After you delete it, it may remain in backups for up to 7 days.
• D: while your subscription is active, and afterwards for as long as the law requires us to keep purchase records.
• F: until you delete your account. After that, usage data is kept only in a form that no longer identifies you.
• G: approximate location (city and country) worked out from your IP address by our analytics provider. Your precise location is used only on your device and is never sent to us.
• H: until you delete the photo, the stamp or your account. Photos are not kept in backups.
• K: until you unsubscribe from updates or delete your account.

We may also collect other personal information when you contact us for support or take part in surveys.

Sources, use and sharing

The sources of personal information are described in section 1, and how we use it in section 2. We collect usage information through a product analytics identifier (PostHog).

We may disclose your personal information to our service providers under a written contract with each of them; see section 4. We may use your personal information for our own business purposes, such as internal research and development, which is not "selling" your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve months. In the same period we have disclosed the following categories to service providers for a business purpose: A, B, D, F, G, H and K.

Your rights

Under certain US state laws you have rights that are not absolute; in certain cases we may decline a request as permitted by law. They include the right:

• to know whether we are processing your personal data
• to access your personal data
• to correct inaccuracies in your personal data
• to request deletion of your personal data
• to obtain a copy of the personal data you shared with us
• to non-discrimination for exercising your rights
• to opt out of processing of your personal data for targeted advertising (or "sharing" under California law), sale of personal data, or profiling that produces legal or similarly significant effects

Depending on your state, you may also have the right to access the categories of personal data being processed (for example Minnesota); to a list of the categories of third parties we have disclosed personal data to (for example California, Delaware and Maryland); to a list of the specific third parties we have disclosed personal data to (for example Minnesota and Oregon); to a list of third parties we have sold personal data to (Connecticut); to review, question and correct how personal data has been profiled (for example Connecticut and Minnesota); to limit use and disclosure of sensitive personal data (California); and to opt out of collection of sensitive data and data collected through voice or facial recognition (Florida).

How to exercise your rights

Email us at privacy@wanderswell.app, or use the app: Settings lets you export all your data or delete your account. You can also use the contact details at the end of this notice. Under certain US state laws, you can designate an authorized agent to make a request on your behalf; we may deny a request from an agent who cannot show they are validly authorized.

Request verification

When we receive your request, we need to verify your identity. We will only use personal information in your request to verify your identity or authority to make it. If we cannot verify you from the information we already hold, we may ask for more, only for verification and security purposes. If an authorized agent makes the request, we may need more information to verify your identity, and the agent will need your written and signed permission.

Appeals

Under certain US state laws, if we decline to act on your request, you may appeal by emailing privacy@wanderswell.app. We will tell you in writing what action we took or did not take and why. If your appeal is denied, you may complain to your state attorney general.

California "Shine the Light" law

California Civil Code Section 1798.83 allows California residents to request, once a year and free of charge, information about the categories of personal information (if any) we disclosed to third parties for direct marketing purposes in the previous calendar year, and the names and addresses of those third parties. To make a request, write to us using the details in section 17.

14. Do other regions have specific privacy rights?

In short: you may have additional rights depending on the country you live in.

Australia and New Zealand

We collect and process your personal information under Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020. This Privacy Notice sets out what personal information we collect, from which sources, for which purposes, and who else receives it. If you do not provide the personal information needed for a purpose, we may not be able to offer you the Services, respond to your requests, manage your account, or confirm your identity and protect your account. You can request access to or correction of your personal information at any time; see section 18. If you believe we are processing your personal information unlawfully, you can complain to the Office of the Australian Information Commissioner or the Office of the New Zealand Privacy Commissioner.

Republic of South Africa

You can request access to or correction of your personal information at any time; see section 18. If you are unhappy with how we handle a complaint, you can contact the Information Regulator (South Africa): general enquiries enquiries@inforegulator.org.za; complaints (complete POPIA/PAIA form 5) PAIAComplaints@inforegulator.org.za and POPIAComplaints@inforegulator.org.za.

15. How WanderSwell handles your location, photos and sharing

Your location. If you allow it, WanderSwell uses your device's location to show spots near you and to move the map to where you are. Your location is used only on your device and is never stored or sent to us.

Your photos. Before a photo you add to a stamp is uploaded, we remove the location information your phone may have saved in it. Your photos and notes are private to your account.

Sharing. Nothing you add to WanderSwell is visible to anyone else unless you choose to share it, for example by sharing your passport.

Your choices in the app. In Settings you can turn off sharing usage data, export a copy of everything you have added, and delete your account and everything in it.

16. Do we make updates to this notice?

In short: yes, as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will show a new "Last updated" date at the top. If we make material changes, we may notify you by prominently posting a notice or by sending you a notification directly. We encourage you to review this Privacy Notice regularly.

17. How can you contact us about this notice?

Email privacy@wanderswell.app, or write to us at:

18. How can you review, update or delete the data we collect from you?

You may have the right to request access to the personal information we collect from you, details about how we have processed it, correction of inaccuracies, or deletion. You may also have the right to withdraw your consent. These rights may be limited in some circumstances by applicable law. In the app, Settings lets you export all your data or delete your account. For anything else, email privacy@wanderswell.app.

This Privacy Policy was created using Termly's Privacy Policy Generator.