Privacy Policy

Last updated: November 28, 2023 This Privacy Policy ("Policy") for Wreno ("Wreno", "we", "us" or "our"), describes how and why we might collect, store, use and/or share ("process") your information when you use our services, such as when you:

Visit our website at https://wreno.io/, https://vendorease.wreno.io/, https://homebase.wreno.io/ or any other website of ours that links to this Policy.
Download and use our mobile application or any other application of ours that links to this Policy.
Engage with us in other related ways, including any sales, marketing or events

Questions or concerns?

Reading this Policy will help you understand your privacy rights and choices. Please note our Services are subject to our policies and practices and aim to protect your rights and choices. If you disagree, please refrain from using our Services. Contact us at support@wreno.io for assistance.

Summary of Key Points

This summary provides key points from our Policy, but you find out more details about any of these topics by using our table of content below to find the section you are looking for.

What personal information do we process?

When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Wreno and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information?

We may collect and process the following types of personal information: a) Basic Contact Information: This includes your name, email address, phone number, and mailing address. b) Background Check Information: Depending on the requirements of the third-party software we use for background checks, we may collect additional personal information. This could range from basic information such as your first and last name and address(es), to more sensitive information such as your Social Security Number (SSN). Please note that the collection of such information will be conducted with utmost respect for your privacy and in compliance with all applicable laws and regulations. c) Password: We collect and store passwords to ensure the security of your account and protect your personal information. d) SSN, TIN, professional license and certification information, W9 information: In certain circumstances, such as for employment purposes or business-related interactions, we may collect Social Security Numbers (SSN), Tax Identification Numbers (TIN), professional license and certification information, and W9 information. This data is collected in accordance with applicable laws and regulations and is handled with the utmost care and security. e) Insurance Information: If you engage in transactions with us that require insurance coverage, we may collect relevant insurance information to facilitate those transactions. f) Business Information: If you are engaging with us in a business capacity, we may collect relevant information including your company name, job title, professional certifications (with specific details), and professional contact details.

Do we receive any information from third parties?

We may receive information from public databases, marketing partners, social media platforms, and other outside sources.

How do we process your information?

We process your information to provide, improve and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information?

We may share information in specific situations and with specific third parties.

What are your rights?

Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights?

The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us at support@wreno.io. We will consider and act upon any request in accordance with applicable data protection laws.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT? 2. HOW DO WE PROCESS YOUR INFORMATION? 3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? 4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? 5. HOW LONG DO WE KEEP YOUR INFORMATION? 6. HOW DO WE KEEP YOUR INFORMATION SAFE? 7. DO WE KEEP INFORMATION FROM MINORS? 8. WHAT ARE YOUR PRIVACY RIGHTS? 9. CONTROLS FOR DO-NOT-TRACK FEATURES? 10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? 11. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? 12. SMS SERVICE AND TCPA COMPLIANCE 13. DO WE MAKE UPDATES TO THIS POLICY? 14. HOW CAN YOU CONTACT US ABOUT THIS POLICY? 15. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us. We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

names
phone numbers
email addresses
mailing addresses
job titles
passwords
contact preferences
contact or authentication data
billing addresses
debit/credit card numbers

Sensitive Information

When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information: Personal Information SSN/EIN: In certain circumstances, such as for employment purposes or business-related interactions, we may collect Social Security Numbers (SSN) or Employer Identification Numbers (EIN). This information is collected in accordance with applicable laws and regulations and is handled with the utmost care and security. Insurance Information: If you engage in transactions with us that require insurance coverage, we may collect relevant insurance information to facilitate those transactions. Business Information: If you are engaging with us in a business capacity, we may collect information such as company name, job title, and professional contact details. Payment Data When you make a purchase or pay for a service, we collect payment information from you. This includes details such as your name, billing address, payment card, CVV code and expiration date. Payment information is processed and secured by authorized third-party processors according to industry standards. Sensitive data such as credit card numbers are encrypted during transmission using TLS/SSL encryption. We do not directly collect or store full payment card details on our servers. The payment processors we work with may retain some payment information in accordance with industry regulations to prevent fraud and verify transactions. If you choose to pay by invoice, we will collect necessary billing details to generate the invoice and process payment. This information is securely stored in our billing system and only authorized staff have access. We ensure that all invoicing processes comply with relevant regulations and safeguards to protect your personal information. We may add or remove payment methods over time to improve our service and offer you additional options. Any changes to the accepted payment methods will be updated on our website and communicated to you through appropriate channels. Application Data If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's and other features. If you wish to change our access or permissions, you may do so in your device's settings.
Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.
Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s), and/or for marketing purposes. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, and other outside sources. To enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties. We may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). We use certain Google Maps Platform APIs to retrieve certain information when you make location-specific requests. This includes: Data for geolocating addresses and displaying map information.; and other similar information. A full list of what we use information for can be found in this section and in the previous section titled "HOW DO WE PROCESS YOUR INFORMATION?". We obtain and store on your device ("cache") your location for as long as necessary to fulfill the purposes outlined in this Policy, unless otherwise required by law. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document. The Google Maps Platform APIs that we use store and access cookies and other information on your devices.
Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
Other Users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

Third-Party Tools Disclaimer We may utilize various third-party tools and services to enhance the functionality and efficiency of our operations. This section serves as a disclaimer to inform you about the involvement of these third-party tools and to clarify our responsibilities and liabilities in relation to their use. Third-Party Tools and Services We may engage third-party tools and services, including but not limited to software applications, plugins, APIs, and cloud-based solutions, to support different aspects of our business operations. These tools are carefully selected to ensure their reliability, security, and compatibility with our services. However, it is important to note that these third-party tools are independent entities and have their own terms of service and privacy policies. Use of Third-Party Tools While we strive to collaborate with reputable and trustworthy third-party providers, we cannot guarantee the performance, availability, or accuracy of these tools. We rely on the representations and warranties made by these providers regarding the functionality, security, and compliance of their tools. However, we strongly recommend that you review the terms of service, privacy policies, and security measures of these third-party tools independently to understand their practices and ensure their suitability for your needs. Limitation of Liability We emphasize that our use of third-party tools does not imply our endorsement or control over their operations or any potential risks associated with their use. We shall not be held liable for any damages, losses, or consequences arising from the functionality, performance, or security of these third-party tools. By using our services, you agree to release us from any claims, liabilities, or disputes arising from your use of these third-party tools, including but not limited to any data breaches, service interruptions, or inaccuracies in the provided information. Your Responsibility It is your responsibility to assess the suitability, reliability, and security of any third-party tools that you choose to utilize in conjunction with our services. We encourage you to conduct your own due diligence, including reading the terms of service, privacy policies, and security measures provided by these third-party providers. You should also consider implementing appropriate safeguards, such as encryption, access controls, and regular data backups, to protect your own data and information. Updates and Changes We reserve the right to modify or discontinue the use of any third-party tools at our discretion. In such cases, we will make reasonable efforts to inform you in a timely manner and suggest alternative options if available. Please note that this disclaimer applies solely to third-party tools and services utilized by us and does not extend to any external websites, platforms, or resources that may be linked to our services. We encourage you to review the terms and policies of these external sources independently. If you have any questions or concerns regarding our use of third-party tools or their impact on your privacy and security, please contact us using the information provided below.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information. We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Policy unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this Policy will require us keeping your personal information for longer than the period of time in which users have an account with us. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age. We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under the age of 18, please contact us at support@wreno.io.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time. If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner. Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS POLICY?" below. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS POLICY?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. Account Information If you would at any time like to review or change the information in your account or terminate your account, you can:

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements. Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Policy.

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information. California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. CCPA Privacy Policy The California Code of Regulations defines a "resident" as: (1) every individual who is in the State of California for other than a temporary or transitory purpose and (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose All other individuals are defined as "non-residents." If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information. What categories of personal information do we collect? This section explains the categories of personal information we may collect, as well as how we use and retain this information in compliance with applicable laws and regulations. A. Identifiers: This category includes contact details such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, and account name. Please note that we may collect this information. B. Personal Information Categories Listed in the California Customer Records Statute: This category includes name, contact information, education, employment, employment history, and financial information. Please note that we may collect this information. C. Protected Classification Characteristics Under California or Federal Law: This category includes gender and date of birth. Please note that we may collect this information. D. Commercial Information: This category includes transaction information, purchase history, financial details, and payment information. Please note that we may collect this information. E. Biometric Information: This category includes fingerprints and voiceprints. Please note that we do not collect this information. F. Internet or Other Similar Network Activity: This category includes browsing history, search history, online behavior, interest data, and interactions with our websites, applications, systems, and advertisements. Please note that we may collect this information. G. Geolocation Data: This category includes device location. Please note that we may collect this information. H. Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information: This category includes images and audio, video, or call recordings created in connection with our business activities. Please note that we may collect this information. I. Professional or Employment-Related Information: This category includes business contact details necessary to provide our services at a business level, job titles, work history, and professional qualifications if you apply for a job with us. Please note that we may collect this information. J. Education Information: This category includes student records and directory information. Please note that we may collect this information. K. Inferences Drawn from Other Personal Information: This category includes inferences drawn from any of the collected personal information listed above to create a profile or summary about an individual's preferences and characteristics. Please note that we may collect this information. L. Sensitive Personal Information: This category includes precise geolocation and account login information. Please note that we may collect this information for the purpose of providing our services to you as long as you have an account with us. Additionally, we may collect other personal information from you in instances where you interact with us through our customer support channels, participate in customer surveys or contests, or when we need to facilitate the delivery of our services and respond to your inquiries. If you have any questions or concerns regarding the collection, use, or retention of your personal information, please contact us using the information provided below. How do we use and share your personal information? More information about our data collection and sharing practices can be found in this Policy. You may contact us by email at support@wreno.io, or by referring to the contact details at the bottom of this document. If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf. Will your information be shared with anyone else? We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA. We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" your personal information. We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers. Your rights with respect to your personal data Right to request deletion of the data — Request to delete You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities. Right to be informed — Request to know Depending on the circumstances, you have a right to know:

whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell or share personal information to third parties;
the categories of personal information that we sold, shared, or disclosed for a business purpose;
the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
the business or commercial purpose for collecting, selling, or sharing personal information; and
the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights We will not discriminate against you if you exercise your privacy rights. Right to Limit Use and Disclosure of Sensitive Personal Information If the business collects any of the following:

social security information, drivers' licenses, state ID cards, passport numbers
account login information
credit card numbers, financial account information, or credentials allowing access to such accounts
precise geolocation
racial or ethnic origin, religious or philosophical beliefs, union membership
the contents of email and text, unless the business is the intended recipient of the communication
genetic data, biometric data, and health data
data concerning sexual orientation and sex life

you have the right to direct that business to limit its use of your sensitive personal information to that use which is necessary to perform the Services. Once a business receives your request, they are no longer allowed to use or disclose your sensitive personal information for any other purpose unless you provide consent for the use or disclosure of sensitive personal information for additional purposes. Please note that sensitive personal information that is collected or processed without the purpose of inferring characteristics about a consumer is not covered by this right, as well as publicly available information. To exercise your right to limit use and disclosure of sensitive personal information, please visit: contact us at support@wreno.io. Verification process Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate. We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additional provided information as soon as we finish verifying you. Other privacy rights

You may object to the processing of your personal information.
You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by email at support@wreno.io, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

11. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information. Virginia CDPA Privacy Policy Under the Virginia Consumer Data Protection Act (CDPA): "Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context. "Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information. "Sale of personal data" means the exchange of personal data for monetary consideration. If this definition "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data. The information we collect, use, and disclose about you will vary depending on how you interact with us and our Services. Your rights with respect to your personal data

Right to be informed whether or not we are processing your personal data.
Right to access your personal data.
Right to correct inaccuracies in your personal data.
Right to request deletion of your personal data.
Right to obtain a copy of the personal data you previously shared with us.
Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling").

We have not sold any personal data to third parties for business or commercial purposes. We will not sell personal data in the future belonging to website visitors, users, and other consumers. Exercise your rights provided under the Virginia CDPA More information about our data collection and sharing practices can be found in this Policy. You may contact us by email at support@wreno.io. If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf. Verification process We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request. Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension. Right to appeal If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at support@wreno.io. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

12. SMS SERVICE AND TCPA COMPLIANCE

For users who opt to receive SMS text message communications from us, we collect and store user phone numbers and the content of those text messages. This information is solely used to deliver the SMS services users have requested and consented to receive as part of our services. User phone numbers and text message content are stored by our SMS providers in compliance with all TCPA regulations for text messaging services. We provide three distinct options to opt-out of receiving future SMS communications: replying "STOP" directly within the SMS program or by contacting customer support via support@wreno.io to request removal.

13. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this Policy as necessary to stay compliant with relevant laws. We may update this Policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Policy frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this Policy, you may email us at support@wreno.io.

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us at support@wreno.io.