"Personal Information" means information that is about any individual, or from which any individual is directly or indirectly identifiable.

"Process", "Processing" or "Processed" means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

We may Process the following categories of Personal Information about you:

Personal details: your name; username or log in details; password; areas or topics of interest; and photograph (if you or another user posts a photo on the Service).
Demographic information: gender; age/date of birth; nationality; salutation; job title, company information, education, work experience and other professional information; and language preferences.
Contact details: postal address; telephone and/or mobile number; email address; and your public social media handles or profile(s).
Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
Location information: location data that describes the precise geographic location of your device ("Precise Location Data").
Purchase and payment details: records of purchases and prices; invoice records; payment records; billing address; payment method; cardholder or accountholder name; payment amount; and payment date.
Employer details: where you interact with us in your capacity as an employee, the contact information of your employer (including name, address, telephone number and email address) to the extent relevant.
Views and opinions: any views and opinions that you or other users choose to send to us, or publicly post about us on social media platforms or in the Services, including on forums.

We also collect other kinds of information from you or other sources, which we refer to as "Other Information" in this Policy, which may include but is not limited to:

Information about your use of the Services, such as usage data and statistical information, which may be aggregated.
Browsing history including the websites or other services you visited before and after interacting with the Services.
Searches for and interactions with e-commerce opportunities, such as merchants and offers contained in the Services.
Non-precise information about the approximate physical location (for example, at the city or zip code level) of a user's computer or device derived from the IP address of such computer or device ("GeoIP Data").
Device identification ("ID"), which is a distinctive number associated with a smartphone or similar handheld device, but is different than a hardware serial number.
Advertising ID, which is a unique, user-resettable identification number for advertising associated with a device (e.g., iOS uses the Identifier for Advertising (or "IDFA") and Android uses Google Advertising ID).
Internet Protocol ("IP") address, which is a unique string of numbers automatically assigned to your device whenever you access the Internet.
Internet connection means, such as internet service provider ("ISP"), mobile operator, WiFi connection, service set identifier ("SSID"), International Mobile Subscriber Identity ("IMSI") and International Mobile Equipment Identity ("IMEI").
Information collected through the use of cookies, eTags, Javascript, pixel tags, device ID tracking, anonymous identifiers and other technologies, including information collected using such methods and technologies about (i) your visits to, and interaction and engagement with, the Services, content and ads on third party websites, applications, platforms and other media channels ("Channels"), and (ii) your interaction with emails including the content and ads therein (collectively, "Online Data").
Device type, settings and software used.
Log files, which may include IP addresses, browser type, ISP referring/exit pages, operating system, date/time stamps and/or clickstream data, including any clicks on customized links.
Web Beacons, which are electronic files that allow a website to count users who have visited that page or to access certain cookies.
Pixel Tags, also known as clear GIFs, beacons, spotlight tags or web bugs, which are a method for passing information from the user's computer to a third party website.
Local Shared Objects, such as Flash cookies, and Local Storage, such as HTML5.
Mobile analytics to understand the functionality of our mobile applications and software on your phone.

Under certain circumstances and depending on applicable law, some of this Other Information may constitute Personal Information. Personal Information together with Other Information is hereinafter referred to as "User Information".

We do not collect or otherwise Process Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, or any other information that may be deemed to be sensitive under GDPR (collectively, "Sensitive Personal Information") in the ordinary course of our business. Where it becomes necessary to Process Sensitive Personal Information under GDPR, we would rely on one of the following legal bases:

Compliance with applicable law: We may Process your Sensitive Personal Information where the Processing is required or permitted by applicable law;
Detection and prevention of crime: We may Process your Sensitive Personal Information where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);
Establishment, exercise or defense of legal rights: We may Process your Sensitive Personal Information where the Processing is necessary for the establishment, exercise or defense of legal rights; or
Consent: We may Process your Sensitive Personal Information where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Information.

Children. The Services are not intended for use by children, especially those under 13. No one under the age of 13 should provide any Personal Information or use our public discussion areas, forums or chats. Minors under the age of 18 are not permitted to make purchases through the Services or obtaining coupons or codes from the Services to purchase goods or services on third party websites. If, notwithstanding these prohibitions, your children disclose information about themselves in our public discussion areas, consequences may occur that are not intended for children (for example, they may receive unsolicited messages from other parties). If it is discovered that we have collected Personal Information from someone under 13, we will delete that information immediately.

Collection of User Information: We may collect User Information about you from the following sources:

Data you provide: We may obtain your Personal Information when you provide it to us across our Services (e.g., where you sign up for emails, newsletters, bulletins, webinars or white papers; register for site membership or create a profile or account on any part of the Services; enter a sweepstakes, contest, competition or prize draw; receive promotional information by SMS text message; participate in surveys; perform search queries through the Services; contact us via email, telephone or by any other means; purchase a subscription, software license or product; or when you provide us with your business card, etc.).
Relationship data: We may collect or obtain your Personal Information in the ordinary course of our relationship with you (e.g., if you purchase a service from us).
Data you make public: We may collect or obtain your Personal Information that you clearly choose to make public, including via social media (e.g., we may collect information from your social media profile(s) if you make a public post about us) or through our chats, forums or communities on the Services.
Service data: We may collect or obtain your Personal Information when you visit, download, use or register to use any part of our Service.
WiTest by Wellink LLC: When conducting a test through WiTest on any device or platform, we collect: (a) the test results; (b) non-precise information about the approximate physical location of your computer or device-derived from GeoIP Data and/or Precise Location Data (if your mobile device settings allow it); and (c) Other Information, including, but not limited to, the IP address, the ISP, college or organization that operates the network you test, and network, hardware and device identifiers such as your SSID or IMEI (if the test is conducted on a smartphone). If you install WiTest on your smartphone or other mobile device, Wellink LLC may collect your Precise Location Data, both while you are running a test and when the application is not actively in use but is running in the background on your device. If you install the WiTest extension on your web browser, in addition to allowing you to run a test of your internet speed, the extension uses our Web Speed feature, which measures the load time for a particular website and allows you to measure how long it takes for a particular website to load. Through the Web Speed feature, we collect page load metrics for the websites you visit, including page URLs, load times, and GeoIP Data. Web Speed does analyze your IP address when you run a test to ascertain the approximate location of your device, but the IP addresses analyzed by Web Speed are not retained by Wellink LLC and are deleted automatically after the test is completed. Note, however, that we also combine this information with recent WiTest information collected from the same device.
Content and advertising information: If you choose to interact with any third party content or advertising on the Services or Channels, we may receive User Information about you from the relevant third party.
Third party information: We may collect or obtain your Personal Information from third parties who provide it to us. This may include offline channels such as through telephone or direct mail efforts; from customers, vendors, suppliers, third parties, commercially available or publicly-available sources (e.g., data brokers, data aggregators, public databases, etc.); third party affiliate network operators; referral sources; social network sites or services (e.g., Facebook, Twitter, LinkedIn, etc.). If you use a third party connection or log-in (e.g., Facebook Connect, Twitter, or Google+) to access the Services, create a membership or profile on any part of the Services, access our content or forward our content to another person, platform or service, we may also receive your username or email address for those third party services or other information available about you or collected from you on those services.

Please note that Wellink LLC is not responsible for the information you volunteer about yourself in the discussions in certain public areas of the Services, such as forums, blogs, wikis, chat rooms, private messages, message boards or other publicly accessible interaction, or information that you choose to make public in your member profile or other areas of the Services that allow users to upload or post content. We discourage users from posting such Personal Information in this fashion. You can change your publicly available information at any time via your profile page. To request removal of your Personal Information from these areas, please see Section 17 in this Privacy Policy for further details. In some cases, we may not be able to remove your Personal Information, in which case we will let you know we are unable to do so and why.

This Privacy Policy does not cover the practices of third parties, including those that may disclose information to Wellink LLC.

Creation of User Information. We may also create User Information about you, such as records of your interactions with us and details of your purchase history, for internal administrative purposes and analysis. We may also combine data you have provided to us with data obtained from third parties such as social networks and other data collection entities.

The purposes for which we may Process User Information, subject to applicable law, include:

Provision of the Services to You: providing the Services to you from Wellink LLC or its partners including (i) offering of contests, as well as chat areas, forums and communities, (ii) posting of your personal testimonial alongside other endorsements, (iii) display of your personal reviews of products or services, (iv) allowing you to search for other website members using information you may already know about that member such as username, full name or gamer profile and identify users matching that criteria, (v) management of your account, and (vi) customer support and relationship management.
Offering and Improving the Services: operating and managing the Services for you; providing personalized content to you; communicating and interacting with you via the Services; identifying issues with the Services and planning improvements to or creating new Services; and notifying you of changes to any of our Services.
Surveys: engaging with you for the purposes of obtaining your views on our Services.
Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) regarding news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required. We may provide direct marketing to you as set out in Section 6 below.
Advertising: providing advertising based on your interests and interactions with the Services and Channels, including using User Information to serve you advertisements on the Services and Channels, as well as licensing segments of User Information to third parties. For further information, please see Section 7 below.
Audience Engagement: identification and development of audience engagement, advertising and promotional strategies on various platforms and channels, both within the Service and on Channels.
User Engagement and Purchases: tracking purchase traffic and activity across the Service and on Channels, including review of your browsing history (if available); provision of analytics and measurement of cost of traffic against money being made.
Commerce Offerings: using cookies to track your browsing history and the amount of money spent at a particular third party merchant's site to offer coupons and other offers that are relevant to your shopping experience; offering of coupons via SMS messages if a mobile phone number is provided.
Lead Generation: business-to-business lead generation in the provision of leads to customers to improve customer's target marketing campaigns and services through different strategies. This includes generating leads through phone calls and email newsletter marketing to drive you to content, such as white papers and webinars, offered by Wellink LLC B2B, emedia and Salesify, whereupon your contact information will be shared with our customer.
B2BSignals Offering: providing a software product that offers customers to filter through a database of contacts by revenue, employee size, functional roles and more, that allows customers to find the right business-to-business leads to improve their marketing campaigns and services.
WiTest Offerings: WiTest by Wellink LLC is offered on multiple devices, products and platforms, such as an extension on your web browser or as an application in certain products such as routers. It enables you to test the speed, latency and other primary network characteristics of your TCP/IP network connections and be provided with the results. Your WiTest results may be used by Wellink LLC to conduct analyses and prepare product enhancements, as well as to prepare market reports. Wellink LLC licenses the WiTest results to its business customers. Wellink LLC also licenses the WiTest application to business customers who wish to have their end users test their own networks' internet connectivity or to test an end user's connection(s) between a product and the Wellink LLC network of servers.
Marketing to Customers: We may market to current and prospective customers and their employees who have indicated an interest in doing business with, or have previously conducted business with, Wellink LLC in order to further generate and promote our business. Such efforts include sending marketing emails or conducting phone calls to drive the purchase of advertising, WiTest and Online Data licensing, lead generation and other business services offered by Wellink LLC.
IT Administration: administration of Wellink LLC' information technology systems; network and device administration; network and device security; implementing data security and information systems policies; compliance audits in relation to internal policies; identification and mitigation of fraudulent activity; and compliance with legal requirements.
Security: electronic security measures (including monitoring of login records and access details) to help mitigate the risk of and provide the ability to identify and rectify a security incident.
Financial Management: general business and financial management purposes, including: economic, financial and administrative management; planning and reporting; personnel development; sales; accounting; finance; corporate audit; and compliance with legal requirements
Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
Legal Proceedings: establishing, exercising and defending legal rights.
Legal Compliance: Subject to applicable law, we reserve the right to release information concerning any user of Services when we have grounds to believe that the user is in violation of our Terms of Use or other published guidelines or has engaged in (or we have grounds to believe is engaging in) any illegal activity, and to release information in response to court and governmental orders, other requests from government entities, civil subpoenas, discovery requests and otherwise as required by law or regulatory obligations. We also may release information about users when we believe in good faith that such release is in the interest of protecting the rights, property, safety or security of Wellink LLC, any of our users or the public, or to respond to an emergency.

We may Process your User Information to contact you via email, telephone, direct mail, SMS or other methods of communication to provide you with information regarding the Services that may be of interest to you. We may send information to you regarding the Services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.

You may unsubscribe from our newsletter lists at any time by following the unsubscribe instructions included in every email we send. We will not send you any emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any other Services you have requested or for additional emails you have signed up for. You may opt out of any telephone marketing by contacting us at the contact details set out in Section 17 below. You may opt out of SMS messages by texting STOP to the received SMS. You can also text HELP for assistance, or contact Offers. You will not be charged by us for receiving or sending SMS messages, however, we make no representations, warranties or guarantees that a particular wireless service program will enable you to participate in an SMS program.

In Processing your User Information in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:

Consent: We may Process your User Information where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);
Contractual necessity: We may Process your User Information where the Processing is necessary in connection with any contract that you may enter into with us;
Compliance with applicable law: We may Process your User Information where the Processing is required by applicable law;
Vital interests: We may Process your User Information where the Processing is necessary to protect the vital interests of any individual; or
Legitimate interests: We may Process your User Information where we have a legitimate interest in carrying out the Processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.

As described above, we have identified WiTest offerings by Wellink LLC, our lead generation services and how we market our business to our current and prospective customers as having a legitimate interest.

For WiTest, Wellink LLC has a legitimate interest in sharing your WiTest results with internet providers, hardware manufacturers and industry regulators to help them understand and create a better and faster internet.

We may disclose your User Information to other entities within the Company group, for legitimate business purposes (including operating the Services, and providing services to you), in accordance with applicable law. In addition, we may disclose your User Information to:

legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality;
third party Processors (such as analytic providers; data centers; etc.), located anywhere in the world, subject to the requirements noted below in this Section 9;
any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;
any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;
any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation);
any relevant third party provider, where our Services use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, information about your activities on the Services and Channels to provide you targeted advertising based upon your interests may be shared with the relevant third party provider. If you click or tap on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria;
any sponsors of contests, competitions, sweepstakes and prize draws, or white papers, webcasts or other downloads, the registration data for such events is to be used by us as part of User Information, and may be shared with the sponsor and others, subject to this Policy and the sponsor's privacy policy. We may also share your information with third party vendors involved in the administration of such events. For contests, competitions, sweepstakes and prize draws, please read the official rules or terms and conditions carefully before you submit your information; and
to third parties whose practices are not covered by this Privacy Policy (e.g., third party providers of goods and services, marketing and advertising companies and agencies, content publishers and retailers).

For some of our Services, we may make some information, such as the name of our users, their mailing address, phone number, email address—and in certain circumstances their employer's name, company size and other industry data—available on a rental or other basis (e.g., sale) to third party providers of goods and services, for example, when such information is provided in connection with webcasts, white papers or other sponsored downloads.

When you use a co-branded service (a service operated with a partner of Wellink LLC), or register or otherwise provide information on a co-branded site, you grant us permission to pass the collected information back to that partner, which may include third party service providers whose services are embedded into and/or appear within the Services;

With respect to surveys, in the event that responses are publicly disclosed, users will be notified at the time they take the survey. Otherwise we will disclose only aggregate information regarding its users' responses in surveys to other participants in the survey. Where surveys allow users to submit written comments, and where Wellink LLC advises users of the possibility of such disclosure at the time they take the survey, Wellink LLC reserves the right to disclose any information provided by users, provided that no User Information identifying a specific user is disclosed.

Wellink LLC and some of our advertisers may use third party advertising service companies to serve advertisements, for OBA or otherwise, and perform related services when you interact with the Services. Often, these third party advertising companies employ cookies and other technologies to measure the effectiveness of website, app and email advertisements and to create a record of interaction with our content that they use in conjunction with their advertising which appears on other sites or applications, or for reporting website traffic, app use, statistics, advertisement data and/or other activities on the Services. We also engage third party providers to assist with the segmentation of this data.

We may also sell or transfer Online Data to certain third parties such as advertisers who will use this data to serve ads that they believe are relevant to your interests, and who agree to maintain the confidentiality of this information. Some of these third parties may combine the Online Data with their own data about you to form a more detailed picture.

We may engage third party providers to assist with the collection, storage and segmentation of Online Data and the providers are required to maintain the confidentiality of this information. These third party providers may collect User Information from our Services for their own purposes, including but not limited to monitoring fraud around the web.

We may also engage third parties for the purpose of recognizing our users and delivering interest-based content and advertisements to them. We may share your User Information with our partners such as your name, postal address, email, or other identifier. Our partners may also: (i) collect information directly from your device, such as your IP address, device ID, advertising ID, and information about your browser or operating system; (ii) combine User Information about you received from Wellink LLC with information about you from other sites or services; and (iii) place or recognize a unique cookie on your browser.

Except as otherwise described herein, the information we gather from all tests run through Wellink LLC is collected anonymously and then aggregated to provide performance data to users on the Wellink LLC websites, including its WiTest server hosts, and/or to third parties to whom we license the information. We do this with the express intent of providing a neutral and unbiased monitoring and reporting resource for users around the world. The only WiTest results we do not license to third parties are those test results from instances of WiTest Custom which are made available pursuant to a paid subscription. In such instances, the WiTest results are owned by the subscriber and are subject to that subscriber's privacy policy.

Information collected through WiTest may not be anonymous as follows: for some ISPs and mobile carriers, Wellink LLC will provide full IP addresses and/or network, hardware or device identifiers for such ISP or mobile carrier's customers upon request. Wellink LLC may also provide full IP addresses and/or network, hardware and device identifiers, to equipment manufacturers and core network, or wholesale providers on a case-by-case basis for network research purposes. Wellink LLC may also collect GeoIP Data and/or Precise Location Data, and such data may also be licensed and/or transferred to third parties.

If we engage a third-party Processor to Process your User Information, the Processor will be subject to binding contractual obligations to: (i) only Process the User Information in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the User Information; together with any additional requirements under applicable law.

The Services contain links to other sites or partners whose information practices may be different from ours. You should consult the privacy policy of these third parties to learn how your privacy is protected.

We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances we may use Secure Sockets Layer encryption and/or transfer certain User Information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.

We take every reasonable step to ensure that your User Information that we Process is accurate and, where necessary, kept up to date, and any of your User Information that we Process that you inform us is inaccurate (having regard to the purposes for which they are Processed) is erased or rectified.

We take every reasonable step to ensure that your User Information that we Process is limited to the User Information reasonably necessary in connection with the purposes set out in this Policy or as required to provide you services or access to the Services.

We take every reasonable step to ensure that your User Information is only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will keep your User Information are as follows: we will retain copies of your User Information in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need.

Except as may be set forth in this Privacy Policy, Online Data related to OBA is retained by Wellink LLC for not more than 180 days after which it shall expire. However, the 180 day period may commence again if the same user subsequently visits or interacts with an ad, email, the Services or a Channel.

For more information concerning your use of the websites and services of Wellink LLC (including WiTest), please visit the  Wellink LLC Terms of Use. The  Wellink LLC Terms of Use is incorporated by reference into this Privacy Policy.

We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.

We may change this Privacy Policy from time to time, and all changes will be effective at the time we post them. If we believe there is a significant change to this Privacy Policy or our data collection and use practices, we will indicate on our websites that our Privacy Policy has changed prior to the change becoming effective. The then-posted version of the Privacy Policy supersedes all prior versions. Your continued access to or use of any of the Services shall be deemed your acceptance of the Privacy Policy.

We urge you to come back to this web page and review this Privacy Policy regularly so that you remain aware of the terms and conditions that apply to you.