At WIOLP, your privacy is a top priority. WIOLP is committed to being a good steward of your Personal Information, handling it in a responsible manner, and securing it with administrative, technical, and physical safeguards.

We also believe in being honest, direct and transparent when it comes to your data. WIOLP follows three guiding principles when it comes to your privacy:

• Transparency. We work hard to be transparent about what Personal Information we collect and process.
• Simplicity. We try to use easy-to-understand language to describe our privacy practices to help you make informed choices.
• Control. We give you control over the Personal Information you provide to us, and how it is used, shared, and retained.

Other Important Things for You to Understand When You Use Our Services

When you make new discoveries with us, you should feel confident and informed about how we use your Personal Information. Our full Privacy Statement is below and we encourage you to read it.

Effective as of December 10, 2023

1.  Introduction

At WIOLP, we enable journeys of discovery. As a result, we collect, process and store your Personal Information as you use our websites, mobile applications, and services (collectively the “Service”). Personal Information is information that can identify you, such as your name, email or street address, or it may be information that could reasonably be linked back to you. This Privacy Statement describes our practices for collecting, storing and processing your Personal Information and the controls we provide you to manage it within our Services. 

2.  Membership Creation and Your Engagement with WIOLP Services

The Personal Information required to create a membership of WIOLP is only your name, an email address, and a password.
Access to WIOLP records or to our features requires additional personal information, including payment details.

Membership creation also requires you to agree to the WIOLP Terms and Conditions and this Privacy Statement (include US State Privacy Notice) by clicking “Binding order” on the Get started page (Price list).

By clicking “Binding order,” you are telling us that you consent to WIOLP collecting, processing, and sharing your Personal Information as described in this Privacy Statement and in any other documents referenced in this Privacy Statement.

At any time, you can request WIOLP delete information you have uploaded into your account, such as a names of ancestors and/or names of relatives. Please see Section 11. for specific details about deleting your data.

3.  What Information Does WIOLP Collect From You?

The table below describes the information we collect from you to provide the Services. In this Privacy Statement, we refer to this as your “Personal Information.”

Information category	Use Description
Account Information	Your name An email address A password that you provide us when you create an WIOLP account
Credit Card/Payment Information	Payment information, such as your credit card number, and your billing information.
Profile Information	We collect the information that you provide when you voluntarily create a user profile.  Additional personal details that you provide in your profile.
User Provided Content	Information you provide about yourself or other living individuals when you voluntarily contribute to the Services, or participate in community discussions. Information about deceased persons is not Personal Information under this Privacy Statement.
Social Media Information	If you use Facebook, we collect information from your Facebook profile that you choose to provide to us (for example your Facebook profile information).
Additional User Information	Information that you provide to us when you answer email surveys or online questionnaires offered through the Services.
Your Communications	Your communications through our communications features, as well as information you provide in communications with WIOLP Member Services.
Contests and Promotions	Personal Information when you voluntarily participate in contests and special promotions we run through our Services.

4.  What Information Does WIOLP Collect Through Your Use of the Services?

Information category	Use Description
Computer and Mobile Device Information	Information about how you access our Services, including the website you visited before and after WIOLP’s site. The Internet protocol (“IP”) address of your computer, mobile device, or the proxy server that you use to access the Internet, in addition to other technical information, such as: your computer operating system your web browser your mobile device identifier provided by your mobile device operating system and your mobile operating system the name of your internet service provider or mobile carrier
Information shared through social media features	If you interact with social media through the Services, for example “Like,” “Tweet,” “Pin,” or “Follow Us” links to sites such as Facebook, Twitter, Pinterest, Instagram, LinkedIn, and YouTube, WIOLP will collect these interactions and whatever account information these services make available to us. Your interactions with these features are governed by the Privacy Statement of the applicable third-party company.
Information from your use  of the Services	Information about your use of the Services, such as when you search or access records, which pages you view or links you click on, etc.

5.  Information We Collect From Other Sources

Information category	Use Description
Information from Public Records	WIOLP collects records from various sources, usually from official record sources. These records are generally part of WIOLP’s subscription Services.
Information from Third Parties	We may also receive information about you from third parties. For example, we may supplement the data we collect with demographic information licensed from third parties in order to personalize the Services and our offers to you. If you purchase a gift subscription, we will collect Personal Information to complete the gift and notify the recipient.

6.  How does WIOLP use your Personal Information?

Information category	Use Description
Personal Information (generally)	We use your Personal Information to provide, personalize, improve, update and expand our Services. This includes: authenticating your access to the Services and improving WIOLP information security; processing your payments for subscriptions and other premium products and features; building new and improving existing products and Services; helping you create, and providing insights about lost patrimony based on data in WIOLP’s databases; issuing surveys and questionnaires to collect Additional User Information for use in the Services, as well as facilitating product development and research initiatives; conducting scientific, statistical, and historical research; and detecting and protecting against error, fraud, or other criminal or malicious activity and enforcing our Terms and Conditions.
Communications	We use your Personal Information to communicate with you about the Services, such as when we: respond to your inquiries to Member Services; alert you to new records in our database; inform you of product changes or new products and services; ask you to participate in WIOLP media productions or testimonials; and provide you with information or request action in response to technical, security, and other operational issues.
Market new products and offers from us or our business partners.	We use your Personal Information to market new products and offers from us or our business partners. This includes advertising personalized to you based on your interests. Note: You can control how we market to you by using the unsubscribe link in any email you receive, or by following the instructions in any other marketing communications you receive.

7.  When Do We Share Your Information and Who are the Recipients?

WIOLP does not share your individual Personal Information with third-parties without your additional consent other than as described in this Privacy Statement. The circumstances described below explain when sharing might occur:

People with whom your Information may be shared / Circumstances in which sharing might occur	Description
Others	If you share details of yourself, your family members or patrimony outside the Services, you do so at your own risk.
Service Providers	We use other companies to help us provide the Services to you. As a result, these partner companies will have some of your information in their systems. Our partners are subject to contractual obligations governing data security and confidentiality consistent with this Privacy Statement and applicable laws. These processing partners include our: financial institutions; payment processors; cloud services infrastructure providers; reCaptcha provider; vendors that assist us in marketing; analytics, and fraud prevention; and some Member Services functions.
Partners	We share your Information with partners only when you provide us with your express consent to do so through our Informed Consent. Partners may include commercial or financial organizations. In some circumstances, a partner or WIOLP may have a financial interest in the arrangement.
Legal or Regulatory Process	We may share your Personal Information if we believe it is reasonably necessary to: comply with valid legal process (e.g., subpoenas, warrants); enforce or apply the WIOLP Terms and Conditions; protect the security or integrity of the Services; or protect the rights, property, or safety of WIOLP, our employees or users.
If WIOLP is Acquired	If WIOLP or its businesses are acquired or transferred (including in connection with bankruptcy or similar proceedings), we will share your Personal Information with the acquiring or receiving entity. The promises in this Privacy Statement will continue to apply to your Personal Information that is transferred to the new entity.
A note about Aggregated data	WIOLP may disclose user information in an aggregated form as part of the Services or our marketing, or in publications published by us or our partners. Such disclosure will never include Personal Information.

8. Cookies

WIOLP collects some information about you automatically when you visit our websites or use our Services. Some of this information is collected using cookies and similar tracking technologies. 

WIOLP may use cookies to collect, store, and track information for statistical purposes to use our Services. The types of information a Cookie collects include a user’s username, the date and time of their visits to the website, their browsing history, and preferences. You have the ability to accept or decline cookies. If you choose to decline cookies, you may not be able to fully experience the features of the website and Services.

10.  What are WIOLP’s Retention Practices?

WIOLP services are fundamentally premised on the notion that the personal voyage of discovery is not a one-time event and continues over lengthy periods of time. Additionally, and with particular regard to our customers who pay fees or purchase membership, the ongoing enhancement of WIOLP’s records features provide benefits and insights to our users over time. As a result, WIOLP’s retention practices reflect this ongoing value by retaining user accounts on our system until our users inform us of their desire to delete their data or close their accounts.

11.  How can I delete my Personal Information?

You can delete your Personal Information from WIOLP in a number of ways.

Information Category	How to delete
Personal Information	You can delete your Personal Information to the extent you have shared information through the Services. We will consider requests for removal of Personal Information we hold on a case-by-case basis in accordance with law.
General	Please note that there may be some latency in deleting your Personal Information from our backup systems after it has been deleted from our production, development, analytics, and research systems. Also, our partners may retain information they receive from us in order to comply with laws. WIOLP may also retain certain information as reasonably necessary to comply with our legal obligations (including law enforcement requests), resolve disputes, maintain security, prevent fraud and abuse, as well as to comply with tax, payment industry, securities, and clinical regulatory compliance requirements.

12.  Security

WIOLP maintains a comprehensive information security program designed to protect our customers’ Personal Information using administrative, physical, and technical safeguards.

The specific security measures used are based on the sensitivity of the Personal Information collected. We have measures in place to protect against inappropriate access, loss, misuse, or alteration of Personal Information under our control.

WIOLP’s Security Team regularly reviews our security and privacy practices and enhances them as necessary to help ensure the integrity of our systems and your Personal Information.

We use secure server software to encrypt Personal Information, and we only partner with security companies that meet and commit to our security standards. While we cannot guarantee that loss, misuse or alteration of data will not occur, we use reasonable efforts to prevent this.

It is also important for you to guard against unauthorized access to your Personal Information by maintaining strong passwords and protecting against the unauthorized use of your own computer or device.

13.  Changes to this Statement

We may modify this Privacy Statement at any time, but we will provide prominent advance notice of any material changes to this Statement, such as posting a notice through the Services, on our websites, or sending you an email, to provide you the opportunity to review the changes and choose whether to continue using the Services.

We will also notify you of non-material changes to this Statement as of their effective date by posting a notice through the Services, on our websites, or sending you an email. Your continued use of our Services after notice of non-material changes means that you consent to the updated Privacy Statement.

14. Your Rights

You may revise your personal information by adjusting your account settings. You also have the right to ask WIOLP to amend any personal information it holds about you if it is inaccurate or misleading as to any matter of fact. We may ask you to provide identifying information to compare it to the personal information already maintained by us. We may require a more stringent verification process depending on the sensitivity of the personal information involved. Any request to amend personal Information in WIOLP’s records should be in writing and addressed by email to info@wiolp.com.

15. Data Subject Right

WIOLP members residing in the European Union, the European Economic Area, Andorra, Argentina, Australia, Brazil, California, Canada, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, Uruguay, and other jurisdictions have certain data subject rights. For members located in the European Economic Area, those rights include those set out below (and related limitations). For those members residing outside of the European Economic Area, these rights vary, but they may include the following rights, which may be subject to certain exemptions: 1.1 The right to access information held about you. This right can normally be exercised free of charge. However, we reserve the right to charge an appropriate administrative fee where permitted by applicable law. 1.2 The right to object to processing which has our legitimate interests as its lawful basis (see “Legal Grounds for the Processing of Personal Information” section above). 1.3 The right to obtain a portable copy of personal information which is processed on the basis of your consent, or which is necessary for the performance of a contract between us (see “Legal Grounds for the Processing of Personal Information” section above). 1.4 The right to request rectification or restriction of the information we process about you. 1.5. The right to withdraw your consent when we rely on this legal basis to process your personal information (see “Legal Grounds for the Processing of Personal Information” section above). 1.6 The right to request deletion of your personal information. Any request should be in writing and addressed to WIOLP by email at info@wiolp.com or through customer support. WIOLP will use reasonable efforts to supply personal information about you on its files. WIOLP shall endeavor to respond as soon as practicably possible. WIOLP will make every effort to resolve all requests that we receive. However, if you are dissatisfied with our response to a request, you may have the right to lodge a complaint. Without limitation, in jurisdictions where the GDPR applies (i.e., the European Economic Area and the United Kingdom), you have the right to lodge a complaint with the data protection supervisory authorities.

GDPR

WIOLP has taken steps to ensure compliance with all applicable privacy laws, including the General Data Protection Regulation (GDPR).

US STATE PRIVACY NOTICE

For information regarding privacy rights you may have under US state laws and related disclosures, please see our US State Privacy Notice.

BRAZIL’S DATA PROTECTION LAW

This section addresses the legal obligations and rights laid out in the Lei Geral De Proteção De Dados (“LGPD”), which are applicable if:

• The processing operation is carried out in Brazil
• The purpose of the processing activity is to offer or provide goods or services, or the processing of data of individuals located in Brazil
• The personal data was collected in Brazil

Under the foregoing circumstances, you have the following rights:

• confirmation of the existence of processing;
• access to your personal information;
• correction of incomplete, inaccurate, or out-of-date information;
• portability of your personal information;
• deletion of your personal information;
• information about third parties with whom personal information is shared;
• access to this Privacy Policy and the Terms and Conditions;
• to revoke your consent.

SOUTH AFRICA’S DATA PROTECTION LAW

This section addresses the legal obligations and rights laid out in the Protection of Personal Information Act, 2013 (“POPIA”), which are applicable when the processing of personal information falls under the scope of POPIA, i.e. when personal information that is entered in a record is processed in South Africa.

Under the above circumstances, you have the following data subject rights:

• to request access to, and information regarding the nature of personal information held and to whom it has been disclosed. Such request for access may be refused on the basis of the grounds of refusal in the Promotion of Access to Information Act, 2000;
• to request the restriction of processing of personal information in the circumstances contemplated in POPIA;
• to not have personal information processed for direct marketing purposes by means of unsolicited electronic communications, save for in the circumstances permitted by POPIA;
• to not be subjected to a decision that is based solely on the automated processing of personal information intended to provide a profile of such person, save for in the circumstances permitted by POPIA;
• to request to rectify or correct personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully, subject to POPIA;
• to request deletion of personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully or where we are no longer authorized to retain it, subject to POPIA;
• to object to the processing of personal information where the processing is on the basis that it protects the data subject’s legitimate interests; where the processing is on the basis that it is necessary for pursuing our legitimate interests or a third party to whom it is disclosed; or where the processing is for the purposes of direct marketing other than by unsolicited electronic communications;
• to lodge a complaint with the Information Regulator in South Africa using the details below:

The Information Regulator
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, South Africa
email: POPIAComplaints@inforegulator.org.za / PAIAComplaints@inforegulator.org.za

16. Children

Our Services are not directed or targeted to children under the age of 13, and WIOLP does not knowingly collect personally identifiable information from children under the minimum age. If you provide information about a child, you, as a parent or legal guardian, consent to the processing and use of such information by us in accordance with this Privacy Statement.

17. Identity and Contact Details of the DataController

For more information concerning matters relating to your Personal Information, or the information processing activities of WIOLP, please contact us using the web form.

Official correspondence must be sent via postal mail to:

WIOLP, s.r.o., Tallerova 4, 811 02 Bratislava, Slovak republic, Central Europe