Definitions and about WiseClean and this policy

WiseClean operations OÜ trading as WiseClean (a private limited company incorporated and registered under the laws of Republic of Estonia with registration code 16551370 registered office in Harju maakond, Rae vald, Peetri alevik, Vägeva põik 2, 75312, Republic of Estonia (e.g. subsidiaries of WiseClean operations OÜ)) (hereinafter referred to as "WiseClean" or "we");

WiseClean Platform is an information service platform containing the WiseClean website, WiseClean app, and WiseClean support service (hereinafter referred to as the "WiseClean Platform") that allows its Users to organize and plan the purchase of cleaning services available on the WiseClean Platform if any offered by independent individual Cleaners.

User – an individual who has reached the age of 18, registered on the WiseClean Platform as a User and accepted the Terms and Conditions of the WiseClean platform for Users for the purpose of placing Offers for the purchase of Cleaners services available through the WiseClean Platform;

Cleaner – an individual who has reached the age of 18, registered on the WiseClean Platform as a Cleaner and accepted the Terms of Use of the WiseClean platform for Cleaners in order to accept (Accept) for execution User' orders for the provision of services on an independent basis as economic and professional service providers;

WiseClean is the data controller of your personal data. Should you have any questions or concerns relating to this privacy policy or your personal data, you can contact us at contact details provided in sections "Questions and updates" below.

WiseClean collects and processes personal data in the course of installation and use of the WiseClean Platform; and in relation to registration and on-boarding and provision of services, in accordance with the relevant terms of use. Please note that the processing of geographical location data is generally necessary for use of the WiseClean Platform.

WiseClean may also collect personal data about individuals that interact with us, including by browsing our websites and using our apps.

By using our websites, apps and services, you acknowledge that we process your personal data in accordance with this privacy policy.

Types of user's personal data we collect and process

Personal data is generally processed in order to provide the service contracted via WiseClean Platform. WiseClean collects data about Users which may include:

biographical and contact information including name, telephone number, e-mail address, as collected during installation of the app;
information related to Order(s) made via WiseClean Platform and information related to each Order made
geographic location from where you access and use the WiseClean Platform from and to what location you order the cleaning service;
where you register for an account, your user ID and password and associated account information such as your preferences and any applicable promo codes;
feedback ratings (including information provided to resolve disputes);
payment information and payment history; information regarding your requests to order cleaning services when you are the User/ your acceptance to provide cleaning services when you are the Cleaner, including geographical location, the time of provision of service; price paid and other order history;
text, images and other user content you provide;
If we ban or suspend you from use of the WiseClean Platform, a record of that ban or suspension;
identification data of the device on that you have installed WiseClean app;
website and communication information such as details collected by cookies and other similar tracking technologies when you use our sites or apps needed to properly view our website and apps;
details of support queries you make (e.g. through the WiseClean Platform or via other communication channels)
where we reasonably suspect fraud, details of offences or alleged offences from fraud detection and prevention agencies.

Client personal data retention

Your personal data will be stored as long as you have an active account. If your account is closed, personal data will be deleted, securely destroyed or anonymised (according to the policies set out in this section) from the databases, unless such data is required to be retained for legal or regulatory purposes or certain legitimate business purposes, including for accounting, dispute resolution or fraud prevention. This follows that:

Data related to each Order will be stored for a maximum of 2 years as of the performance of each Order.
Data required for accounting purposes will be stored for 7 years after the performance of each Order.
If you has not used the WiseClean Platform for 2 years, we will close your account and your personal data will be deleted, securely destroyed or anonymized unless such data is required to be stored for certain legitimate business purposes including for accounting, dispute resolution or fraud prevention purposes.
In the event that there are suspicions of an administrative or criminal offence, fraud or false information having been provided, the data will be stored for 10 years.
In the event of disputes or investigations, data will be retained until the claim or investigation is satisfied/resolved or the expiry date of such claims.

Please note that the uninstallation of WiseClean app from your device does not cause the automatic deletion, destruction or anonymization of your personal data.

Types of personal data of private individual cleaners we collect and process

Personal data is generally processed for the performance of the contract concluded with the Cleaner.

We collect the following types of personal data private individual Cleaners (both directly and indirectly, such as from third-party sources and publicly available information):

biographical and contact information including name, telephone number, e-mail address;
banking or financial information and payment information;
geographical locations when Cleaners are logged into the app (this is required for the service);
demographical data;
account information including user ID;
details of performed Orders and feedback ratings;
fees estimates, actual fees and other payment data;
earnings history and fiscal data;
text, images, and other user content you provide;
if we withdraw your right to use the WiseClean Platform, issue a warning, a record of that withdrawal or warning;
identification data of the device on which the relevant WiseClean app has been installed;
website and communication information such as details collected by cookies and other similar tracking technologies when you use our sites or apps needed to properly view our website and apps. Details of support queries you make (e.g. through WiseClean Platform or via other communication channels);
Client complaints related to the deliveries performed by the Cleaner;
background checks information in accordance with local requirements, which may include medical certificates and/or language test certificates;
data regarding criminal convictions and offences if allowed or necessary under applicable law;
information collected from third parties about you in order to verify any information you supplied to WiseClean during registration;
record of any requests for your information made by law enforcement, regulatory, governmental or judicial bodies.

We collect and process personal data of Cleaners to ensure regulatory compliance, for verifying the Cleaner's qualifications for pursuing this professional activity of providing cleaning service and safeguarding the contractual relations associated with the WiseClean app service, including resolving any cleaning service quality issues and monitoring your compliance on an ongoing basis.

WiseClean's team can see the geographic location of a Cleaner, information on any orders and the times of using the service.

Cleaner personal data retention

Your personal data will be stored as long as you have an active Cleaner account, unless your personal data is required to be retained for certain legal or regulatory purposes, or legitimate business purposes including accounting, dispute resolution or fraud prevention purposes. This follows that:

If your account will be closed the personal data will be stored for an additional 2-year period.
Data necessary for accounting purposes shall be stored for 7 years.
In the event of suspicions of an administrative or criminal offence, fraud or false information, the data shall be stored for 10 years.
In the event of disputes or investigations, the data shall be retained until the claim or investigation is satisfied/resolved or the expiry date of such claims.

After we no longer need your personal data, it will be deleted, securely destroyed or anonymized (according to the policies set out in this section) from the databases,

Please note that the uninstallation of the WiseClean app from your device does not cause the automatic deletion, destruction or anonymization of your personal data.

How and why we use this personal data

WiseClean collects and uses personal data for purposes of providing the WiseClean Platform and for WiseClean's legitimate business purposes. These include the purposes set out below.

Under EU data protection laws, WiseClean's use of personal data must be justified by one of a number of legal bases. These are also set out below.

To deliver our services to you

(lawful basis: to perform and fulfil our contracts with you); and for our legitimate interests (to provide our services to you).

We may use personal data you provide our WiseClean apps to create and manage your accounts and to allow you to provide feedback.

Where you are a User, to forward your Order to respective Cleaner, accept your cleaning Order request and for enabling you to conclude an Agreement of services the Cleaner;

to find and allocate the Cleaner to fulfill the cleaning services of your cleaning Order request. This information (including geographical information) is provided to the Cleaner.

Once you have made an Order via WiseClean app, additional information is provided to the Cleaner to facilitate communication (see section "Disclosure of personal data" for further information).

Where you are a Cleaner, we use your personal data to on-board you as a cleaning service provider and to facilitate interactions with Users including to enable you to decide whether to fulfil a Cleaner's requested cleaning services and once a delivery has been allocated, to facilitate communication with the User (see section "Disclosure of personal data" for further information).

We may use personal data to facilitate payments between Users and Cleaners.

We may use personal data to provide support, including to assist with resolving service quality issues and to respond to queries from Users and Cleaners.

We use contact details to notify you of updates to our websites and the WiseClean apps;

To undertake checks where permitted by applicable law

(lawful basis: legal obligations; legitimate interests (to comply with legal or regulatory requirements and provide a safe service); legal claims; and substantial public interest (processing to prevent or detect a crime)).

We use personal data in our efforts to prevent fraud, including fraudulent payments. If false or inaccurate information is provided and fraud is identified or suspected, your personal data may be passed to fraud prevention agencies and may be recorded by us or by them.

In certain jurisdictions we may send data about earnings to tax authorities or other relevant authorities.

For research and development purposes

(lawful basis: legitimate interests (to allow us to improve our services)).

We may use personal data to improve our websites and apps (including their security features) by analysing it to better understand our business and services.

In order to assist with this, we may apply profiles to you based on your personal data and behavioral information (such as the pages on the website or apps you have visited or interacted with, including by reference to personal data legitimately obtained and shared with us by third parties or publicly available data). Such profiles may be used as part of our advertising, analytics and provision of support.

We may use personal data provided from surveys or feedback to assist with this.

To provide you with marketing materials

(lawful basis: consent, legitimate interest (where we are not required to rely on consent, to keep you updated with news in relation to our products and services and to enable us to analyse how you interact with our communications).

Where permitted by law (you will always be provided with an opportunity to opt-out of future messages), we may contact you with promotional messages regarding the WiseClean app and our and selected business partners' products and services. For further information about marketing and how to manage your preferences, see the section "Direct Marketing to Users" below.

To comply with our legal obligations and in relation to legal claims

We may use your personal data to enforce our terms and to meet our legal and regulatory requirements which may include disclosing your personal data to third parties, the court service and/or regulators, governmental agencies or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world.

We may record any requests for your information made by law enforcement, regulatory, governmental or judicial bodies.

To reorganise or make changes to our business

(lawful basis: legitimate interests (in order to allow us to change our business)).

In the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your personal data to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation.

We may also need to transfer your personal data to that re-organised entity or third party after the sale or reorganisation for them to use for the same purposes as set out in this policy.

Direct marketing to users

We may contact you with promotional messages regarding the WiseClean platform app and our selected business partners' products and services by email, SMS, phone, social media and where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing on our website or in the WiseClean app.

If you no longer wish to receive direct marketing messages, please click the "Unsubscribe from direct marketing messages" link in the footer of our marketing message. You can also opt-out by contacting us at the contact details specified below in the section "Questions and Updates".

Disclosure of personal data to third parties

General disclosure of personal data

WiseClean shares and discloses your personal data to third parties for the purposes and lawful bases set out in the section above titled "How and why we use this personal data". These third parties may include Cleaners who provide cleaning services, other service providers and our advisors and government and administrative agencies and bodies, where required under applicable law.

WiseClean may also transfer the personal data of the User to WiseClean's insurance broker(s) and insurer(s) in connection with the provision of services ordered through the WiseClean Platform.

WiseClean can transmit the data of the Cleaner (name, contact information) and the data of the service work performed by them regarding the start and end time of the work, the losses incurred during the execution of the work and the submitted claims to the Insurance Broker, who may use this data for calculating the insurance premium and broker's fee, processing the insurance indemnity, and forward it to the insurer for the aforementioned purposes. The Insurance Broker may collect and process this data on the Cachet.me platform, and in this case Cachet OÜ is a sub processor of this data. WiseClean can transmit data about the work and services performed by the Cleaner in response to a request to Cachet OÜ, which acts as a technical platform provider for insurance and financial service providers and with which Insurance Broker mediates insurance contracts

The Insurance Broker may use the Cleaner's data to submit insurance offers to the Cleaner.

Disclosure of personal data for law enforcement and claims

WiseClean is committed to ensuring the safety of all clients and couriers using our service. We take all reports of misconduct seriously and we reserve the right, at our discretion, to volunteer information to third parties (including between drivers and passengers), law enforcement, regulatory, governmental or judicial bodies where required by applicable law or regulation or where we feel is necessary.

If we are made aware that third parties, law enforcement, regulatory, governmental or judicial bodies require information about your personal data for an administrative or criminal investigation or in relation to legal claims we will comply as required by applicable law or regulation or to the extent that their request is reasonable and we are able to supply such personal data.

Personal data that we may provide may include:

name(s);
date of birth (if available);
contact phone;
home address (if available);
details about the Orders; and
details of the complaint made by the Client, Cleaner, or applicable third party.

WiseClean may, at our discretion, provide you with notice that we have provided such third parties, law enforcement, regulatory, governmental or judicial bodies with your personal data.

We reserve the right to proactively initiate police reports if we become aware of action or behaviour that may constitute a threat to safety or is of a criminal concern.

Disclosure of personal data as between users and cleaners

The personal data of Cleaners is disclosed to Users once the Cleaner has accepted the request for cleaning service and agreement of cleaning services is concluded between the User and the Cleaner. The User will see the Cleaners's name, photo and rating of the Cleaner. At the same time, the personal data of User disclosed to the Cleaner with whom the User concludes the agreement of cleaning services. Via WiseClean Platform, the Cleaner will see the first name and first letter of the last name of the User, geographic location of the Users' flat and information of the Order for the cleaning services made by the User and contact phone number of the User.

Pursuant to data processing agreement concluded between the Cleaner and WiseClean, after providing the delivery service, the Cleaner is entitled to retain the User data related to the performance of the cleaning service for the maximum period of 1 month.

Please note that personal data of Users may be disclosed to Cleaners and vice versa in connection with legal claims as per the section "Disclosure of personal data for law enforcement and claims" above.

How we protect your personal data

No data transmission over the Internet or websites can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal data in accordance with applicable data protection legislative requirements.

All personal data you provide to us is stored on our or our subcontractors' secure servers and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or mobile apps, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.

International transfers of personal data

WiseClean may disclose personal data to our third party service providers, who may be located in countries outside of the European Economic Area (EEA), subject to contracts with those third parties.

These may include:

IT or payment services providers or person verification checks providers.
data centers

When we transfer personal data from inside EEA to outside EEA, we will transfer your personal data subject to approved safeguards unless we are permitted under EEA data protection law to make such transfers without such formalities. For further information about the safeguards employed, please contact us at contact details specified below in section "Questions and updates".

Only authorized employees of WiseClean and partners have access to the personal data and they may access the data only for the purpose of resolving issues associated with the use of the services (including disputes regarding transportation services).

Your rights in relation to your personal data

You have the right opt-out of marketing communications at any time. To do so, please click the "Unsubscribe from direct marketing messages" link in the header of our marketing e-mail. You can also opt-out by contacting us at contact details specified below in section "Questions and updates".

You have the right to:

be provided with details about what personal data we hold about you and to be provided with a copy of your personal data;
require us to update any inaccuracies in the personal data we hold. In order to assist us with this, please keep your user account/app Profile information in the WiseClean app up to date, or contact us at contact details specified below in section "Questions and updates".to inform us of any updates that should be made to your personal data;
withdraw your consent (where our processing activity is based on your consent);
be provided with a copy of the personal data you have provided to us in a machine-readable format so that you can transfer it to another provider or ask us to transfer this to another data controller (where our processing activity is based on contract performance or consent); require us to delete personal data (including where our processing activity is based on your consent or our legitimate interests). Please note that the uninstallation of the WiseClean app in your device does not itself cause the deletion of your personal data;
restrict how we use your personal data whilst a complaint is being investigated;
object to our processing of your personal data (where our processing is based on our legitimate interests);

Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).

If you would like to exercise a right, we encourage you to contact our customer support via contact details specified below in section "Questions and updates". If you exercise any of these rights we will check your entitlement and respond in most cases within a month.

Third party links

Our websites and apps may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or their processing of your personal data. Please check these policies before you submit any personal data to such third party websites

Questions and updates

If you have any disputes, questions or concerns about this privacy policy or your personal data, we encourage you to first contact us at:

WiseClean operations OÜ
E-mail: [email protected]
Address: Harju maakond, Rae vald, Peetri alevik, Vägeva põik 2, 75312, Republic of Estonia

This privacy policy was last updated on 21.08.2022. Any changes we may make to this privacy policy in the future will be posted on this page and, where appropriate, notified by email.

Privacy Policy