Who we are

Wuja Ltd. (โ€œusโ€, โ€œweโ€, or โ€œourโ€) operates the www.leadingcomment.comย website (hereinafter referred to as the โ€œServiceโ€).

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.

Definitions

  • Service Service is the www.leadingcomment.com website operated by Wuja Ltd.
  • Personal Dataย 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 Dataย 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).
  • Cookiesย Cookies are small files stored on your device (computer or mobile device).

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 (โ€œPersonal Dataโ€). Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Cookies and Usage Data

Usage Data

We may also collect information how the Service is accessed and used (โ€œUsage Dataโ€). This Usage Data may include information such as your computerโ€™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

When you use our websites and apps we may collect information using cookies or similar technologies.

What are cookies and how do they work?

Cookies are small files that are downloaded to your computer or mobile device when you visit a website. Your browser sends these cookies back to the website every time you visit the site again, so it can recognise you. This allows websites to tailor what you see on the screen.

Do you use other technologies which are similar to cookies?

Yes, we use the following:

  • Web beacons: Our websites, apps and emails often contain small invisible images known as โ€˜web beaconsโ€™ or โ€˜tracking pixelsโ€™. These are used in a way similar to cookies to:

โ€“ understand when a particular part of a webpage, email or app is viewed,

โ€“ understand how successful an article or an email marketing campaign has been

โ€“ verify any clicks through to links or advertisements contained in emails

  • Flash cookies: In certain situations we use Adobe Flash Player to deliver video clips. Local Shared Objects (Flash cookies) are used to provide functions such as remembering your settings and preferences.
  • Tracking URLs: These are web links that allows us to measure when a link is clicked on. They help us measure the effectiveness of campaigns and advertising and the popularity of articles that are read.
  • Device identifiers: We use device identifiers on mobile devices in the same way as cookies are used on web browsers. A device identifier is a unique number on your device which allow us to remember your device.

We use these similar technologies on websites, emails and apps, for the same purposes and in much the same way as we use cookies on websites. We will use โ€˜cookiesโ€™ and โ€˜websitesโ€™ below as shorthand for โ€˜cookies and similar technologiesโ€™ on โ€˜websites, emails and in appsโ€™.

What do you use cookies for?

Cookies and other online tracking technologies are an important part of the internet. They make using websites much smoother and affect lots of the useful features of websites.

There are many different uses for cookies, but for within our sites, they fall into the following groups:

(i) Cookies that are needed to provide the service you have asked for (Essential)

Some cookies are essential so you can move around our websites and use their features. Without the use of these cookies parts of our websites would not function.

(ii) Cookies that collect information about your choices and preferences (Functional / Preference)

These cookies collect information about your choices and preferences, and allow us to remember things like:

(iii) Cookies used to understand how people use our products and services (Analytics)

We use analytics cookies to gather information about what pages, links and sections of our apps are popular and which ones donโ€™t get used so much to help us keep our sites relevant and up to date. They are also useful to be able to identify trends of how people navigate our sites so we can identify improvements to make to the customer journey

We may combine information collected by analytics cookies with other information that you provide to us. For instance, if you have registered for an account with us, we may combine your contact details other information you provide us with the browsing history from your device collected by analytics cookies (including data collected from before you registered and when you are signed-out).

We may also use this combined information to improve our products and services. For instance, we may analyse this information in aggregate to improve our advertising systems.

(iv) Cookies used to show advertising that is relevant to you (Tracking and Advertising)

Some advertising, known as โ€˜online behavioural advertisingโ€™ is tailored to you and uses information collected by first party and third party cookies based your web browsing activity. Cookies are placed on your browser to remember the websites you have visited. Advertising based on what you have been looking at is then displayed to you when you visit websites who use the same advertising networks.

To help us deliver relevant advertising using cookies, we use Google Double Click. Click here to find out more about Google Double Click.

We also use these cookies in order to:

  • know how many advertisements we serve, how many times these are clicked or hovered over with a mouse cursor, how many advertisements we show to a given user and how many customer actions these generate.
  • understand which customers reach a sale or other action page on an advertiserโ€™s site. This allows us to monitor how many sales or actions we achieve for an advertising client, and therefore, how effective our advertising is.
  • protect our advertisersโ€™ brands, we often use a technology that scans the page to ascertain that it is safe from profane, sensitive & potentially brand-negative topics, before serving an ad there. This process is called โ€˜ad verificationโ€™.

Ad-blockers: We and our advertisers may use information from within our webpages to determine whether you have an ad-blocker enabled. This information may be stored or associated with your device (including through the use of cookies) to re-insert advertisements on our websites and to understand how our customers use ad-blockers. The advertisements that are re-inserted may include those from ad-blockersโ€™ โ€˜white listsโ€™ or that promote our own products and services. We reserve the right to restrict your access to some or all of our website while you have an ad blocker turned on.

Do Not Track: Our websites do not respond to โ€˜Do Not Trackโ€™ (DNT) browser settings.

Cookies can also be controlled using the following instructions:

  • Mobile Devices: When using a mobile device, you can opt-out of receiving online behavioural advertising by selecting โ€˜Limit Ad Trackingโ€™ in the Settings of your Apple iPhone or iPad, or the โ€˜Opt out of interest-based adsโ€™ in the Settings on your Android device. You may also be able to reset your unique identifier used for online behavioural advertising (referred to as an โ€˜Advertising IDโ€™) in the Settings on your Apple or Android device.
  • OBA Cookies: If you are primarily concerned about third party cookies generated by advertisers, you can turn these off by going to Your Online Choices.
  • Web-Beacons: You can usually prevent the operation of web-beacons by changing your web-browser cookie settings and your ad choices, or for those in emails, by switching off images in your email client or viewing emails using only the โ€˜textโ€™ display (rather than โ€˜HTMLโ€™ displayโ€™). See the โ€˜Helpโ€™ section of your email client for instructions. Please see the All About Cookies website for further information about managing your options.
  • Flash Cookies: You can manage the use of Flash technologies with the Flash management tools available at Adobeโ€™s website.
  • You can also visit the trade body representing these advertising platforms where you can control your third-party online advertising preferences by going to the Network Advertising Initiative.

Use of Data

Wuja Solutions uses the collected data for various purposes:

  • To provide and maintain the 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 care and support
  • To provide analysis or valuable information so that we can improve the Service
  • To monitor the usage of the Service
  • To detect, prevent and address technical issues
  • To analyse web traffic and provide relevant advertising

Transactions

If you purchase anything or make any other financial transactions on any of our websites/apps, we collect information about your purchase and ask for information including your name, e-mail address and delivery address to be forwarded on to the vendors who are responsible for delivering your order. This does not include payment information such as your credit/debit card number.

Advertisers

We may provide third party advertisers with reports containing aggregate statistical data about our customersโ€™ use of our websites and apps to determine the kinds of people viewing their ads and how they are performing. This aggregated information may include demographic data such as age range and/or geographic location of groups of our customers.

This aggregated data does not include contact details (such as names, addresses or email addresses) that can be used to personally identify you or contact you.

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

Tailored advertising

We use advertising to fund some of our websites and apps. Some advertising is โ€˜contextualโ€™ meaning it is shown due to the particular webpage you are presently viewing. Other advertising, known as โ€˜online behavioural advertisingโ€™ is shown to you based upon your likely interests, which are inferred from your deviceโ€™s browsing history. This information is collected through the use of cookies and similar technologies.

Sometimes we allow advertisers to show advertisements directly on our website and apps, which are tailored to you based upon information they have obtained, such as your browsing history on their own websites.

Other times we will arrange for our customers to be shown advertisements on other websites or apps. These advertisements are tailored to you with information we have obtained from your browsing on our websites and apps via cookies.

Where we arrange for our customers to be shown advertisements, we use technological and contractual mechanisms to protect your cookie data and to ensure that your browsing data used for advertising is not used by advertisers or other website owners for other purposes, such as linking online behavioural advertising data with your contact details, unless you have provided the advertiser or other website with your express permission to do this.

When you are shown an advertisement, our advertising systems do not know who you are or your contact details (such as your name, email address or postal address).

Demographic information from your registration on our websites and apps (such as your age, gender and city) may also be used to tailor the advertising we arrange to be shown. Your demographic information is not shared with advertisers.

 We collect information about the devices you use when you visit our websites or use our apps, and we combine this information in order to better personalise the advertisements you see when you visit our properties on another device.

We may also target advertising on social media sites to specifically include customers who have registered for our products and services.

Legal basis for this processing activity: Consent

Location based services and advertising

Where we provide services that utilise your deviceโ€™s location, such as local weather or news, your location will be determined either from a lookup of your IP address in a โ€˜GeoIPโ€™ database which lists information provided by your ISP (usually your closest town or borough) or your precise location directly from the device (such as through GPS or Wifi on mobile devices) where you have granted permission for us to access this location information via your device settings. We use such information to provide you with a more tailored, relevant experiences when using our websites/apps.

Where you have granted permission to access your deviceโ€™s location and consented to us to use your data for advertising purposes, this location information may be used to tailor the advertising you receive, including showing you certain advertisements when you are in the vicinity of a particular location.

Legal basis for this processing activity: Consent

Measurement and analytics

We may use certain information (such as the websites that you visit and advertisements you see or click on) to help advertisers and other promotional partners measure the effectiveness and distributions of their advertisements and promotions.

Transfer Of Data

Your information, including Personal Data, may be transferred to โ€“ and maintained on โ€“ 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 Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there.

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

Wuja Solutions 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

Legal Requirements

Wuja Solutions 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 Wuja Solutions
  • 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

As an European citizen, under GDPR, you have certain individual rights. You can learn more about these guides in the GDPR Guide.

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.

Service Providers

We may employ third party companies and individuals to facilitate our Service (โ€œService Providersโ€), 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.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third partyโ€™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.

How can you exercise your rights under the GDPR

ยท Access: If you wish to exercise your right to access a free copy of your data, please contact us.

ยท Deletion: To ask us to delete your personal data, please contact us.

ยท Rectification: If you wish to update or rectify your data, you can do this directly by accessing your account settings.

ยท Revoke consent: If you wish to object to the processing of your data for direct marketing or online behavioural advertising purposes, you can opt-out by updating your settings or, for direct marketing, clicking on the โ€˜unsubscribeโ€™ link in any marketing email or newsletter you receive from us.

ยท Objection to automated profiling: If you wish to opt-out of having your personal information profiled for personalisation purposes you can not use this service.

ยท Objection to legitimate interests: If you wish to object to our processing of your data where we are pursuing our legitimate interests or those of a third party please contacting us stating the nature of and reasons for such objection.

ยท Complain: You also have the right to lodge a complaint about us with our supervisory authority, the Information Commissionerโ€™s Office.

If you are contacting us to exercise any of your rights under the GDPR, you will have to provide valid proof of identification. We are required to respond to your request within 1 month.

Data retention and account deletion

We store your data for no longer than necessary in relation to the purpose under which such data was collected. This is determined on a cases by case basis and depends on things such as the nature of the data provided, why it was collected, the legal basis we rely upon to process the data, and our relevant legal or operation retention requirements. For example, if you request to delete your account we still have to retain some data for fraud prevention purposes and financial auditing. 

Childrenโ€™s Privacy

Our Service does not address anyone under the age of 18 (โ€œChildrenโ€).

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 โ€œeffective dateโ€ 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.