This privacy policy (“Privacy Policy”) explains and governs how we, Wekudo Tech, Inc., (12187 Rockledge Cir., Boca Raton, FL 33428, US) and its subsidiary (together: “Wekudo", “Confetti” “we”, “our” or “us”) independently use Personal Data (as defined below) that we collect, receive, store and share pertaining to you (“User”, or “you”) in connection with the following use cases:
When you browse, visit, interact with or use our Platform, available at https://www.withconfetti.com (“Platform”);
When you plan and customize, book and/or purchase goods and services, including without limitation, experiences, swag and gift cards, offered on the Platform (“Offerings”). For the avoidance of doubt, Offerings exclude Self-Guided Engagement, and any usage of Self-Guided Toolkits is subject to its own dedicated Privacy Policy accessible here;
When you create a user profile with us by signing up to the Platform (“User Profile”);
When you schedule a meeting with one of our booking specialists or leave us a message;
When you communicate with us through our available customer support channels, or provide us with feedback and testimonials, amongst others, in connection with your experience with our Offerings;
When we obtain your Personal Data from third-party sources (such as lead-generation companies) commonly used to connect between individuals and professionals to explore a potential business opportunity
When you interact with us on our social media profiles (e.g., Facebook, LinkedIn, etc.) and online advertisements;
When you provide your Personal Data during meetings we have, whether in person or virtually, including via phone call, email or video conference recordings;
When you register and join virtual webinars and free community events (hello&demo) we may organize;
When you sign up, download or receive our digital resources, such as our email campaigns, newsletters and blog posts; or
When you apply to a job-listing on our Platform.
If you are a User of our Platform and Offerings, please read the Privacy Policy carefully and make sure you fully understand it.
You are not legally required to provide us with any of your Personal Data, and may do so (or avoid doing so) at your own free will. By using our Platform and Offerings, you agree to the collection, use and disclosure of your Personal Data as described in this Privacy Policy. If you do not wish to provide us with your Personal Data or to have it processed by us or any of our services providers, please simply do not visit or interact with our Platform and do not book, use or participate in our Offerings.
To the maximum extent permitted by law, if you reside in a jurisdiction where “consent” is deemed the sole appropriate legal basis for the collection of Personal Data, your acceptance of our Terms of Service available at this link (“Terms of Service”) and this Privacy Policy establishes your consent to the processing activities described herein. You may revoke your consent by emailing personal-data@withconfetti.com.
Changes to this Privacy Policy. We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective ten (10) days following posting of the revised Privacy Policy on the Platform, and your continued use of the Platform and/or our Offerings thereafter means that you accept those changes.
Any uncapitalized terms used in this Privacy Policy shall have its meanings as given in our Terms of Service.
This Privacy Policy describes our practices in relation to:
Personal Data Collection & Legal Bases
Personal Data Location & Retention
Sharing of your Personal Data
How we protect your Personal Data
Links to and interaction with third party services
Cookies and other tracking technologies
Your privacy rights
How can I delete my user profile?
Use by children
Contact us
1. Personal Data Collection & Legal Bases
In this policy, “Personal Data" means any information that can uniquely identify a living individual, either alone or in combination with other information. This excludes information stored in a format that cannot reasonably be linked to an individual.
We collect various categories of Personal Data in relation to the use cases mentioned earlier and your use of our Platform and/or Offerings. If you are a User subject to the European GDPR, we are deemed a “data controller” with respect to your Personal Data.
We use and collect the Personal Data on the following legal bases: for the provision of the Platform and our Offerings (“performance of a contract”), to comply with our legal obligations (“legal obligations”), and to support, facilitate and improve our Platform and Offerings (“legitimate business interests”), all as further described below:
Device and usage information:
We automatically collect certain information about your interaction with the Platform and/or Offerings:
Data types.
Device Information: Browser information, IP address, date/timestamp, and other information we may collect from your browser.
Location information: approximate location (country, timezone), and phone number country-number).
Other information regarding interaction with the Platform: interactions with the Platform (recorded user sessions, referring/exit pages, session counts), logs files pertaining to your Platform usage.
Any other information that you choose to include in communications with us. For example, sending us emails and messages.
Collection method. The data is generated and/or collected automatically, including by using analytics technologies (as further described in Section 6 below).
Purposes.
To administer, provide and secure the Platform and Offerings;
For internal operations, to conduct troubleshooting and fix technical errors, data and statistical analysis, testing, and gather demographic information;
To develop and improve the Platform and Offerings;
To enhance your user experience;
To personalize your experience, to ensure content is presented in most effective manner for you and your device;
To facilitate and optimize our marketing campaigns, ad management and sales operations, including to provide targeted, contextual and behavioral advertisements based on your interests, create audiences;
To personalize your experience and increase your engagement with our Platform and Offerings.
Profile and contact information:
Certain features of the Platform may require you to directly provide certain information about yourself. You may elect not to provide this information, in doing so, may prevent you from using and accessing these functionalities.
Data Types.
Basic contact details: (name, email address, phone number), job title, company name, avatar (profile picture).
Account information: contract and billing address, account information (username and password), and such other information you share with us in connection with the Platform and/or Offerings.
Collection method. You provide us this information on the Platform (including when using Google’s Sign-In), from the Customer Entity you represent, or via tools commonly used to connect between individuals and professionals to explore potential business opportunities. Information we obtain from third parties will be treated in accordance with this Privacy Policy. We are not responsible for the accuracy of the information provided to us by third parties, and are not responsible for third party’s policies or practices. For more information, see the section below, Links to and interaction with third party services.
Purposes.
To create, verify and maintain your User Profile, and provide you with our Platform and Offerings, other content, and Platform functionality;
To process bookings and handle payments;
To communicate about current and future bookings of Offerings;
To personalize your booking experience of Offerings and send digital resources like newsletters;
To explore potential business opportunities, to communicate with you about our Services, webinars and free community events we think may be of interest to you;
To pursue business opportunities and establish brand presence through partnerships;
To comply with our legal obligations, enforce our contractual arrangements and policies, and to protect the Services, our rights, rights of our users or others.
Communications & Feedback and Testimonials from Users:
You may choose to provide information about yourself in your communication with us:
Data types. Basic contact details (name and email address) and any Personal Data shared or submitted through communications with us.
Collection method. Directly from you when you reach out for support, leave feedback and testimonials, schedule a meeting with our sales team, submit inquiries, apply for a job-listing, interact with us on social media or during events, request access to our digital resources, and contact us through the available support channels. This includes interactions with our AI-powered customer support tools and chatbots.
The information may be provided in-person and virtually through our support system and channels, email, phone, and video conferences, webinars and free community events. Video conferences may be recorded for quality assurance, training purposes and internal record keeping.Purposes.
To assist you with queries and booking of Offerings;
To offer support services, including using artificial intelligence tools (AI) to analyze requests and automate responses to improve response efficiency;
To provide requested resources;
To send you personalized offers and quotes, and communications that might interest you;
To develop and improve our Offerings;
To process your job application.
Finally, we may aggregate and/or de-identify your Personal Data before analyzing, using or sharing it with third-party service providers for the above purposes, such that it reasonably be used to infer information about you or otherwise be linked to you (“de-identified information”). We will use the information in de-identified format and not attempt to re-identify the information, except where legally required or in order to verify and/or enforce and facilitate our internal policies.
CCPA Law Requirements. This section applies to you only if you are a California resident (“resident”). References to “personal information" shall refer to the definition in California Civil Code Section 1798.83. For the purposes of the California Consumer Privacy Act (“CCPA”), we collect the following categories of personal information: identifiers (such as, name and email address), commercial information (such as, records of Bookings made on the Platform), internet network activity (information related to your interaction with the Platform), geolocation data (such as, approximate geolocation and IP address), and professional or employment information, and Account and User Profile access credentials. We do not use or disclose sensitive information as defined by the CCPA.
2. Personal Data Location & Retention
Location. The Personal Data we collect from you will be accessed from, transferred to and stored and used by us, and our third party service providers, in the United States, European Union, Israel (recognized by the European Commission as offering adequate protection to individuals residing in EU member states), or other locations necessary for Services' delivery or legal compliance. We take reasonable steps to ensure your information is treated securely and in accordance with this Privacy Policy.
Retention. We retain your Personal Data until it is no longer necessary for the purposes it was collected or until you submit a valid data deletion request. In some cases, we may retain Personal Data longer, to the extent necessary based on the various criteria, including:
To comply with our legal and/or regulatory requirements (including tax and accounting obligations);
As permitted by applicable data retention laws;
To resolve disputes;
If we reasonably anticipate legal action regarding your Personal Data;
To enforce our contractual agreements and policies;
To promote safety, security and integrity our Services, our rights, of our users and of others.
If you send us a request to delete your User Profile, we will store your information in an aggregated and pseudonymized format; we may use this information indefinitely without notice to you.
3. Sharing of your Personal Data
We may share your Personal Data as follows:
Service providers. With third-party service providers providing services on our behalf and assisting us with business operations, like cloud computing, content delivery, data security, analytics and error monitoring, billing and payment processing, support and customer relations management, email communications and video conferencing, marketing, advertising and email campaigns management, lead generation and data enrichment, and AI tools used to analyze support requests, generate automated responses, and develop and provide new Offerings;
Professional advisors. With our legal, security, marketing and financial advisors and auditors in our legitimate interest or as required by law;
Company / entity you represent. With the company / entity you represent to perform our contractual obligations;
Legal obligations. To the extent necessary, for compliance with applicable laws, regulations, court orders and governmental requests. In such case, we would carefully validate these requests before any Personal Data is disclosed and provide solely such Personal Data that would be reasonably necessary to comply with the request;
Subsidiary or prospective buyer, seller, new owner or other relevant third party. With our subsidiary in our legitimate interests. In addition, if, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events;
Consent. Where you have provided your consent to sharing the Personal Data (e.g., where you provide us with marketing consents and interactions on our social media channels);
Enforce our rights and the rights of others. We have good faith that disclosure of Personal Data is necessary to enforce our Terms of Service, including investigations of potential violations thereof; detect, prevent, or otherwise address fraud or security issues; or protect against harm to the rights, property or safety of us, our users, yourself or the public.
We use commercially reasonable efforts to only engage or interact with trusted third party service providers and partners.
The extent to which such third-party service providers have access to your Personal Data depends on the services they provide and their respective roles. We limit the information we share to the minimum extent necessary to fulfill the relevant purposes for which we engage them.
4. How we protect your Personal Data
We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to Personal Data appropriate to the nature of the information concerned. However, despite our efforts to protect your information, no security measures are impenetrable, and we cannot guarantee “perfect security”. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the manner in which you protect your login credentials, please make sure to take appropriate measures to protect this information and we recommend that you do not use unsecure channels to send us sensitive or confidential information.
5. Links to and interaction with third party services
The Platform may enable you to interact with or contain links to third party websites or platforms (each a “Third Party Service”). We are not responsible for the privacy and security practices of, or the content found on such Third Party Services. Information you provide on public or semi-public venues (such as social media platforms), may also be viewable by our other users and the users of those Third Party Services.
Please be aware that Third Party Services may collect Personal Data from you. Accordingly, we encourage you to read the privacy policy of each Third Party Service that you choose to use or interact with.
6. Cookies and other tracking technologies
We use Tracking Technologies, including “cookies”, anonymous identifiers, pixels and similar technologies to track your browsing activities over time and across websites following your use of the Platform. A “cookie” is a small text file that may be used, for example, to collect information about your activity on the Platform, count numbers of users, and see how users move around the Platform. Certain cookies and other technologies may serve to recall Personal Data, such as an IP address.
We use such Tracking Technologies to provide, monitor and improve our Platform, present you with information that is customized for you, and to analyze our performance and facilitate our marketing activities. You can find more information about cookies and how to manage them here.
Please note that - like many websites - we do not change our practices in response to a “Do Not Track” or “Opt-Out Reference” signal in the HTTP header from a browser or mobile application. To learn more about “do not track” signals, please click here.
Most browsers accept cookies automatically, but you may be able to control the way your devices permit the use of Tracking Technologies. If you choose to block cookies, it may cause some of the Platform’s functionalities and features to work incorrectly or differently. If you have questions regarding the specific information about you that we may process or retain, as well as your as well as your choices regarding our collection and use practices, please contact us using the information listed below, or refer to our Cookie Policy available here.
We use Google Analytics to collect information about how you use the Platform, such as how often you visit the Platform, which pages you view, and what other websites led you here. This information helps us maintain and improve our Platform. Google’s use of this information is governed by the Google Analytics Terms of Service and the Google Privacy Policy. To opt out of tracking by Google Analytics, click here.
We use marketing pixels, including Facebook’s pixels, to target ads and measure their effectiveness. Third parties, including Facebook, may use cookies and similar technologies to collect data from our Platform and elsewhere on the internet to deliver and target ads. Facebook’s use of this data is governed by their Tools Terms. To opt out from ad targeting, please visit About Ads or Your Online Privacy Choices.
We reserve the right to use other marketing and analytic tools for the purposes as further described in Section 1 and 6 above.
7. Your privacy rights
If you wish to exercise your privacy rights available under applicable data privacy laws (including, the European GDPR or CCPA) in connection with your Personal Data we retain - such as the rights to access, portability, correction, erasure, restriction of processing to storage only, objection to processing, objection to marketing, right to non-discrimination - you may do so by emailing personal-data@withconfetti.com. Your email should include adequate details of your request, and we may need to collect information about you to verify the request.
Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. For example, where fulfilling your request would adversely affect other individuals, our trade secrets or intellectual property, where there are overriding public interests or where we are required by law to retain your personal data.
We may request information to reasonably verify your identity prior to fulfilling the request. In addition, we may ask you to use the self-serve features available on the Platform in order for you to fulfill the request independently within your User Profile.
If you are a User to whom the European GDPR applies, you may also lodge a complaint with a supervisory authority. We will respond to requests to exercise these rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances).
CCPA Requirements: We “sold” and “shared” your personal information over the preceding 12 months with authorized third parties for the business purposes as described in Section 3 above. However, we do not knowingly “sell” and/or “share” personal information of residents under the age of 16. The CCPA, affords our Users who are California residents the right to opt-out of the “sale” or “sharing” of their Personal Information (as defined in the CCPA). Notwithstanding the foregoing, To make such a request under the CCPA, please send an email to personal-data@withconfetti.com. Alternatively, you may use the “Do Not Sell or Share my Personal Information” button on the footer of our Platform. In addition, California law permits residents to request certain details about how their personal information is shared with third parties for their direct marketing purposes. We may from time to time elect to share certain personal information about you with third parties for those third parties’ direct marketing purposes. Residents may, under certain circumstances, obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year. To make such a request, please contact us using the information listed below. Please note that we are only required to respond to one request per resident each year.
Residents of other US States. If you are a resident of another U.S. state, depending on the U.S. state you live in, you may have some or all of the rights listed above in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law, including in the event you reside in a U.S. state that does not currently grant you these rights.
8. How can I delete my User Profile?
Should you decide to delete your User Profile registered on the Platform, you may do so by emailing personal-data@withconfetti.com or alternatively, use the self-serve features available on the Platform. If you delete your User Profile, any association between your User Profile and information we store will no longer be accessible through your User Profile. However, any activity related to your User Profile before deleting it will remain stored on our servers in aggregated and pseudonymous format.
If your User Profile is part of an account of the Customer Entity you represent, any inquiries relating to your User Profile, including deletion requests, should be directed to the relevant Account’s Admin.
9. Use by children
Our Platform and Offerings are not intended for children. If you are under the age of 18, you may not use the Platform, or provide any information on the Platform without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.
10. Contact us
If you have any questions, concerns or complaints regarding our compliance with this notice and applicable data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at personal-data@withconfetti.com or legal@withconfetti.com.