Privacy Policy

Effective date: May 29, 2018

WTR Group LLC (“us”, “we”, or “our”) operates the www.watchthereview.com website (the “Service”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from www.watchthereview.com

Definitions

Service

Service is the www.watchthereview.com website operated by WTR Group LLC

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small pieces of data stored on your device (computer or mobile device).

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Important Notices

California Privacy Rights. The California Consumer Privacy Act (“CCPA”) of 2018 enhances privacy rights and consumer protection for residents of California. For specific information related to the CCPA, please see California Residents section.

EU Privacy Rights. For users that are citizens of the European Union (“EU”), this Privacy Notice is subject to the provisions of the EU’s General Data Protection Regulation (“GDPR”) and other applicable privacy laws. For specific information related to the GDPR, please see Additional Terms for EU Visitors section.

California Residents

The California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws provides California residents (i.e., consumers) with specific rights regarding personal information. This section of the Privacy Notice describes those CCPA rights and how to exercise those rights. This section does not apply to publicly available information.

Access to Specific Information and Data Portability Rights

California residents have the right to request that Watch the Review LLC disclose certain information to you about Watch the Review LLC’s collection and use of your personal information over the past twelve (12) months. Once Watch the Review LLC receives and confirms a verifiable consumer request from you, Watch the Review LLC will disclose to you, to the extent permitted by law:

• The categories of personal information Watch the Review LLC collected about you.
• The categories of sources for your personal information Watch the Review LLC collected about you.
• Watch the Review LLC’s business or commercial purpose for collecting your personal information.
• The categories of third parties with whom Watch the Review LLC shares your personal information.
• If we disclosed your personal information for a business purpose, the personal information categories that each category of recipient obtained.

You shall have the right to request that the information described above be provided to you in a portable and readily usable format, to the extent technically feasible (“data portability”).

Watch the Review LLC does not sell your personal information.

Deletion Request Rights

You have the right to request that Watch the Review LLC delete certain of your personal information that Watch the Review LLC collected from and/or related to you and retained, subject to certain exceptions.

To the extent that Watch the Review LLC can delete your personal information, once Watch the Review LLC receives and confirms your verifiable consumer request, Watch the Review LLC will delete (and direct our service providers to delete) your personal information, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected your personal information, provide a good or service that you requested, or take actions reasonably anticipated within the context of our ongoing business relationship with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Your Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Watch the Review LLC by either:

• Contacting us at https://www.watchthereview.com/contact-us/

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows Watch the Review LLC to reasonably verify you are the person about whom Watch the Review LLC collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows Watch the Review LLC to properly understand, evaluate, and respond to it.

Watch the Review LLC cannot respond to your request or provide you with your personal information if Watch the Review LLC cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Any disclosures provided pursuant to the CCPA will only cover the 12-month period preceding the receipt of the verifiable consumer request.

Watch the Review LLC will respond to a verifiable consumer request within 45 days of its receipt, or notify you that Watch the Review LLC requires more time to respond and the reason for the extended response time. Watch the Review LLC will deliver its written response by mail or electronically, at your option.

To the extent that your verifiable consumer request is excessive, repetitive, or manifestly unfounded, Watch the Review LLC may charge a reasonable fee to respond to such request.

Watch the Review LLC will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, Watch the Review LLC will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Additional Terms for EU Visitors

To the extent that you are accessing this website from a location within the European Union, the following information shall apply to the collection and processing of your Personal Information.

EU Privacy Rights

The data controller for the Sites is Watch the Review LLC. Watch the Review LLC processes personal information it collects through the Sites for Watch the Review LLC’s legitimate business purposes, as described above. You are a Data Subject with certain privacy rights concerning your personal information.

Explanation and copies of your data

You have the right to request an explanation of the personal information that Watch the Review LLC has about you and how Watch the Review LLC uses that information. You also have the right to receive a copy of the personal information that Watch the Review LLC collects about you if collected on the basis of consent or because Watch the Review LLC requires the information to provide the services that you request.

Correction/Rectification

If Watch the Review LLC has personal information about you that you believe is inaccurate, you have the right to request correction of your personal information. Please see below for more information on correcting, or requesting correction of, your information.

Deletion

You may request deletion of your personal information at any time. We may retain certain information about you as required by law and for legitimate business purposes permitted by law. Please see the “Reviewing, Correcting and Deleting Personal Information Collected Through the Site” section above for more information regarding Watch the Review LLC’s retention and deletion practices.

Objections and complaints

Members and visitors in the EU have the right to object to Watch the Review LLC’s processing of personal information, including for marketing purposes based on profiling and/or automated decision making. Watch the Review LLC may continue to process your information notwithstanding the objection to the extent permitted under applicable law.

In addition, you have the right to lodge a complaint with a supervisory data protection authority, contact information is available at https://edpb.europa.eu/about-edpb/board/members_en.

You may also submit questions, comments or complaints to Watch the Review LLC at https://www.watchthereview.com/contact-us/

Grounds for Processing

The European Union’s General Data Protection Regulation (“GDPR”) requires that companies processing the personal information of EU users do so on the basis of specific legal grounds. As described below, Watch the Review LLC processes the information of EU users based on one or more of the grounds specified under the GDPR:

• The processing is necessary for Watch the Review LLC’s legitimate interests
• Watch the Review LLC collects and uses personal information to the extent necessary for its legitimate interests. This includes collecting and using information:
  • To understand how people use our products and services.
  • To perform background checks necessary to verify employment eligibility.
  • To provide customer support.
  • To optimize our service and develop new services.
  • For research and analytical purposes.
  • For direct marketing purposes. This includes, for example, analyzing data to identify trends and tailor marketing messages to user needs.
• The processing is necessary to fulfill Watch the Review LLC’s legal obligations
• Watch the Review LLC may process your personal information when we have a legal obligation to do so, for example, if we’re responding to a legal process or an enforceable governmental request.
• Watch the Review LLC may collect and use your personal information on the basis of your consent. You may revoke your consent at any time. If you revoke your consent, you will not be able to use any service or feature that requires collection or use of the information we collected or used on the basis of consent.

Exercising Your Data Rights

To exercise the data rights described above, please submit a request to Watch the Review LLC by contacting us at https://www.watchthereview.com/contact-us/. Only you, or a person authorized to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child.

Watch the Review LLC cannot respond to your request or provide you with your personal information if Watch the Review LLC cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a data rights request does not require you to create an account with us. We will only use personal information provided in a data request to verify the requestor’s identity or authority to make the request.

Watch the Review LLC will respond to a request within 30 days of its receipt, or notify you that Watch the Review LLC requires more time to respond and the reason for the extended response time. Watch the Review LLC will deliver its written response by mail or electronically.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Usage Data

We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.
• Advertising Cookies. Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

Use of Data

Watch the Review LLC uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), WTR Group LLC legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

WTR Group LLC may process your Personal Data because:

• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests and it’s not overridden by your rights
• To comply with the law

Retention of Data

WTR Group LLC will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

WTR Group LLCwill also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

WTR Group LLC will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Disclosure for Law Enforcement

Under certain circumstances, WTR Group LLC may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

WTR Group LLC may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of WTR Group LLC
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

Security of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

“Do Not Track” Signals

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. WTR Group LLC aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Data.

The right of restriction. You have the right to request that we restrict the processing of your personal information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where WTR Group LLC relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Clicky

Clicky is a web analytics service. Read the Privacy Policy for Clicky here: https://clicky.com/terms

Advertising

We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.

Google AdSense DoubleClick Cookie

Google, as a third party vendor, uses cookies to serve ads on our Service. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.

You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

• By visiting this page on our website: https://watchthereview.com/contact-us/