This Privacy Statement describes how WIGGWIGG INC. (“we”, “WIGGWIGG”) collects, processes, uses and shares personal information and/or personal information about individuals browsing the WIGGWIGG website (“Website”) and about individuals using the WIGGWIGG web application or mobile application (collectively the “WIGGWIGG Service”).
The use of the second person (“you”, “your”, “yours”) refers to a visitor of the Website or user of the WIGGWIGG Service.
The contact details of the person responsible for processing personal information under this Privacy Statement are as follows:
Privacy Officer WIGGWIGG INC. privacy@wiggwigg.ca (For any inquiry concerning the WIGGWIGG Service, please contact us through the WIGGWIGG Service)
1. Collection of personal information
1.1. User Information
We minimize our collection of personal information as much as possible. We only collect personal information that you provide directly to us through the interface of the WIGGWIGG Service. You do not have to provide any personal information to use the WIGGWIGG Service.
Data and information uploaded to the WIGGWIGG Service by users (such as password, login information, notes) is encrypted on your device before upload. We use a zero-knowledge architecture and therefore have no means of decrypting this information unless you provide us with your password.
1.2. Calls and Messages
Calls, SMS and voicemails sent through telephone or mobile networks are not encrypted and may be monitored by automated means to ensure compliance with acceptable use policies by WIGGWIGG, by our service providers or by telecommunication carriers involved in the delivery of telecommunications through the WIGGWIGG Service.
We automatically save a copy of any audio recordings and messages sent through the WIGGWIGG Service in your account, but we do not use such information for any purpose other than to provide our services. Saved messages and audio recordings are encrypted at rest, but are not subject to the zero-knowledge architecture, which means we could decrypt this information.
1.3. Information collected through the Website
We only collect information you provide voluntarily, such as your email address if you subscribe to our newsletter. We encourage you to use an email address that does not identify you. We do not collect any other information nor use any analytics tools on the Website.
1.4. The community forum
WIGGWIGG operates an optional community forum (community.wiggwigg.ca), hosted on cloud infrastructure we operate in Canada and not on a third-party community platform. Access is only through your WIGGWIGG account; the forum creates no separate password and sends no email.
You take part under a display name that you choose. We send the forum this display name, a pseudonymous identifier irreversibly derived from your account, and a synthetic email address, never your real name, your account identifier, or your real email address. We do not publicly link your identity to your messages, but if you reveal personal information in what you post, it may be associated with you.
The forum does not receive your real IP address: it is replaced with a constant value before reaching the forum. As with the rest of the WIGGWIGG Service, our load balancer briefly logs connection IP addresses for security purposes, retained for at most 90 days.
The forum offers an anonymous mode that hides your display name from other members, but not from the system: the technical link between the anonymous profile and your membership still exists.
Unlike data subject to our zero-knowledge architecture (section 1.1), the content you post on the forum is readable by the forum software and visible to the public or to members, depending on the category. Post accordingly.
2. Processing of personal information
We process personal information collected through WIGGWIGG Service for the sole purpose of operating the WIGGWIGG Service and for no other purpose.
We may use the content of the messages and calls to enforce acceptable use policies and to prevent misuse of the WIGGWIGG Service.
3. Personal Data storage and retention
User Data is stored electronically on servers operated by Amazon Web Services located in Canada.
Any information transmitted on telecommunication networks transits through infrastructure located in the United States and operated by Telnyx, our telecommunication services provider. We do not store any information at rest in the United States.
We retain User Data for as long as the relevant User has an active account on the WIGGWIGG Service or if we are required by law to retain User Data.
4. Security Measures
User data is hosted on servers operated by our service providers and are protected by industry standard security measures. Our zero-knowledge architecture puts you in control of the security of your data, as your data is not usable without your password.
Our employees and suppliers are informed of the confidential nature of personal information collected through the WIGGWIGG Service and are made aware of the appropriate security measures to prevent unauthorized access to personal information.
5. Disclosure of Personal Information
We only share or disclose personal information in the manner described in this Privacy Statement or when we have obtained your express consent. Your personal information may be disclosed to the categories of persons described below for the following purposes.
5.1. Employees
Personal data is accessible to our officers and employees who must access it in order to use the same as set forth in this Privacy Statement and to provide our services to our Customers.
5.2. Service Providers
We process encrypted personal information through our service providers, who undertake to keep this information confidential and to limit its use to what is necessary to support our services.
Our current service providers (subprocessors) are:
- Amazon Web Services (AWS): cloud hosting of our databases, encrypted media storage and application servers, located in Canada.
- Telnyx: voice, SMS/MMS and 911 (E911) connectivity, located in the United States.
- Stripe: payment and subscription processing, in the United States and globally.
- Blockonomics: cryptocurrency payment processing (Bitcoin), for subscription and donation payments, global.
- Resend: delivery of transactional emails (account, billing and notification messages), located in the United States.
- Microsoft (PhotoDNA): automated scanning of media messages to detect child sexual abuse material (CSAM), which we are legally required to detect and report.
- Apple (APNs): push notification delivery to iOS devices (device tokens and encrypted notification payloads).
- Google (FCM): push notification delivery to Android devices, as a fallback to our self-hosted relay (device tokens and encrypted notification payloads).
- Vercel: hosting for our marketing website only, not the WIGGWIGG application.
We may update this list as our services evolve. The current, detailed list is available on our Subprocessors page.
The content of calls and SMS sent through telephone or mobile networks may be monitored by our telecommunication services providers and telecommunication carriers. This is not specific to WIGGWIGG and happens with all audio calls and SMS transmitted through the telephone or mobile networks. We never associate your identity with your calls and SMS, but if you reveal personal information in your messages or calls, they may be associated with you.
5.3. Legal obligations
We may also disclose personal information to third parties if we are required to do so by law, or if we are compelled to do so by a competent authority. We may disclose personal information in connection with legal proceedings if absolutely necessary to protect our rights.
6. What are your rights regarding your personal information?
6.1. Access your data
You may access your data through your user account on the WIGGWIGG Service. Any personal information we have about you is only accessible through the WIGGWIGG Service. We do not collect your email address, so you cannot request access to your personal information through email.
6.2. Withdrawal of Consent
You may withdraw you consent to our processing of your personal information by unsubscribing to our newsletter, by removing information on your WIGGWIGG account or by deleting your WIGGWIGG account altogether.
6.3. Deletion
You may delete all personal information we have about you through the WIGGWIGG Service. You can delete your account entirely through the interface of the WIGGWIGG Service. If you delete your account, we will not retain any information except as strictly necessary to comply with applicable law.
6.4. Complaint
Depending on your jurisdiction of residence, you may have the right to file a complaint regarding the processing of your personal information with a supervisory authority responsible for the protection of privacy.
7. Modifications
We may modify this Privacy Statement from time to time to reflect changes in our personal information processing practices or applicable law. If a modification is made, we will notify you through the WIGGWIGG Service and the modified statement will be available through the WIGGWIGG Service and on the Website at the following address https://wiggwigg.ca/en/privacy-policy/. We will not do any additional processing of your personal information without your express consent.
8. Additional Information
For any additional information with respect to our processing of personal information, please contact us through the WIGGWIGG Service. Any inquiry made by email should concern information collected through the Website only.