Last revised: 1 July, 2020
- What type of information we collect?
- Information concerning Minors
- How do we collect your information?
- For what purposes we collect the information?
- With whom we share the information and for what purpose?
- How can you access or change your information?
- For how long we retain your information?
- How we protect your personal information
- How to contact us
- Notice for California residents
What type of information we collect?
- Information provided by you
Information submitted via our Service
We collect information that identifies an individual or may with reasonable effort identify an individual, or may be of private or sensitive nature ("Personal Information") submitted by you, including your name, password, email address, status, relationship interest, ethnicity, religion, social habits or preferences, height, weight, birthday, precise geo-location information (collectively "Profile Information"), messages you sent to other users (including photos, location, audio or video files) or any other information you voluntarily submit to your profile or is generated by your use of Whiplr.
Information you make available to the public via our Service
We collect information you make available to other users via our Service including, but not limited to, your username and other Profile Information, and the content you post, or any other information you voluntarily submit or are generated by your use of Whiplr.
- Information transmitted by your device
When you visit the Service, we also automatically collect, inter alia, information transmitted by your device, including your IP address, device ID (which is unique to the device on which you install the Whiplr Application or use the Service), geo-location information (via your GPS, WiFi or cellular technology in your device), certain software and hardware information about your device, including the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Service.
Information concerning Minors
The Whiplr Service is intended for users of the age of 18 years (21 years in places where 18 years is not the age of majority), at least. We do not intentionally or knowingly collect, use or disclose Personal Information regarding user who are under the age of maturity. We reserve the right to request proof of age at any stage so that we can verify that minors are not using the Service.
How do we collect your information?
We collect information submitted directly by you, or information transmitted automatically from your device using various standard technologies, such as cookies, log files, web beacons or other similar technologies.
When you visit our Service we may assign your device with a log file or a cookie (session or persistent). A "cookie" is a small piece of information that a website assign to your computer’s hard drive while you are viewing a web site. You may remove our cookies by following the instructions of your operating platform or your browser preferences; however, if you choose to disable cookies, some features of the Whiplr Service may not operate properly.
For what purposes we collect the information?
The information we collect enable us to personalize your interactive user experience and facilitate your access to our Service, customize our features and services to your needs, track your content and your activities in order to deliver advertisements tailored to your interests (whether via our Service, website or application, or websites or applications of third parties, or your e-mail address) and monitor the effectiveness of our Service and activities.
We may also use the information to perform research, for technical diagnostics, analytics or statistical purposes, conducting surveys or for our customized mailing list with respect to products or services that may be of interest to you either from us or other third parties.
We may also use the information to communicate with you via e-mail, mobile device, etc.
With whom we share the information and for what purpose?
- Service Providers
We share Information, including Personal Information, with our affiliated companies and our service providers, who are certified to use the information only for the purposes of providing certain services for you, or for us and for our affiliated companies and business partners (e.g. customer service, technical support, marketing assistance, analytics, ad tracking, etc.). The information will be disclosed only to the extent required to perform the service. Service providers are not permitted to share or use Personal Information for any other purpose.
- Public Information
Information, including Personal Information, you provided in the course of registering as a user may be viewable to other users of the Service, as well as information you shared with other users (e.g. photos you uploaded, your username, personal description, etc.).
You acknowledge and agree that information you share with other users or provided in your profile is available to the public. You are responsible for protecting and enforcing your rights with respect to your Personal Information.
- Other Disclosures
- Affiliates and corporate transaction
We may share Information, including Personal Information, with our parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively "Affiliates").
We may share Information, including Personal Information, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale).
- Aggregated Information
Non-Personal Information, aggregated information or Personal Information in non-human readable form (de-identified) may be shared with third parties (including ad networks, advertising companies and service providers) in any of the above circumstances, as well as for the purpose of developing or delivering tailored or targeted advertising (whether via our Service, website or application, or websites or applications of third parties, or your e-mail address), or for the purpose of improving our Service, conducting business analysis or other business purposes. This information may be combined with information we collect from other sources, to the extent that the information remains non-Personal Information.
- Third party collection of information
Our policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via our Service (whether our website or application; e.g. by clicking on a link to any other website or location) or via other sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. E.g. when conducting a payment by credit card via our third party vendors (such as Apple Store or Google Play Store), the vendors may collect your credit card information and additional information necessary for processing or authorizing your credit card payments.
These payment companies may also provide certain of your details to us - but this shall not include your credit card number.
You acknowledge and agree that information you share with other users is available to the public. You are responsible for protecting and enforcing your rights with respect to your Personal Information.
How can you access or change your information?
If you have a Whiplr account, you may review or update certain field of your Profile Information (in your settings page), at any time. You may also remove or disable your account. You may also change your email address or password associated with your account with compliance to our Service's methods.
As stated above, you may remove our cookies by following the instructions of your operating platform or your browser preferences. You may also refrain from providing us with any information you do not feel comfortable sharing. However, please be advised that failure of providing us with certain information may result in our inability to provide you the full features of our Service.
For how long we retain your information?
We retain the information (including your Personal Information) for as long as needed to provide the Service and to comply with our legal obligations, resolve disputes and enforce our agreements.
How we protect your personal information
We take security measures to help safeguard your personal information from unauthorized access and disclosure. However, no system can be completely secure. we do not promise, and you should not expect, that your personal information, chats, or other communications will always remain secure. Users should also take care with how they handle and disclose their personal information and should avoid sending personal information through insecure email.
Promotional emails and SMS offers
We may email you periodically our Service's news, updates or information regarding our latest products or services, as well as third party offers that we believe may interest you.
As a responsible member of the cyber community Whiplr Service maintains a strict policy forbidding any third party from sending any sort of promotional emails on behalf of the Whiplr Service – solicited or unsolicited.
This means we go beyond merely prohibiting spamming. To make things even clearer for everybody we don't let any third party to send any emails on our behalf. Moreover, the Service itself only sends emails to persons who have registered on with the Service. These policies demonstrate our strong "Anti-SPAM Policy".
How do we operate?
In every case we receive a complaint regarding one of our direct marketers/partners or any other third party sending emails on our behalf, our Abuse Team immediately initiates an investigation.
It is important that you understand that the Abuse Team investigates every single complaint we receive. Affiliates/direct marketers found by our Abuse Team to have been promoting this site by email face termination of its/his account and possible forfeiture of earnings.
In extreme cases, our Legal Department is also involved.
If you have been emailed by a third party in any matter that is connected to the Whiplr App, please report it to firstname.lastname@example.org and our Abuse Team will take immediate action. Please include the complained-of email itself in your complaint, so the Abuse Team can proceed with the investigation.
Retention of personal information
If you have registered with an account through our Services, the Company will retain your Personal Information during the period your account is active. In addition, the Company will retain your Personal Data for additional periods, to enable the Company to meet its legal obligations under applicable laws or regulations, Know-Your-Customer and Anti-Money Laundering regulations.
In addition, the Company may retain your Personal Information for longer periods, provided that retaining such information is necessary for the Company’s legitimate interests, such as fraud prevention and record keeping.
If for any reason you wish to delete your Personal Information, please send us an e-mail to: DPO@Whiplr.com, and we will make reasonable efforts to address your request.
If you reside in the EU or in other locations that provide you with the below rights, you may contact us at any time by email (at: DPO@Whiplr.com), and request:
1. To access or delete any Personal Information relating to you;
2. To change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted). Note that you may also request that we will correct errors with regard to your Personal Information (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);
3. That we will restrict or cease any further use of your Personal Information;
4. That we will provide the Personal Information you volunteered to us in a machine-readable format.
Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including any legal and ethical reporting or document retention obligations. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.
How we keep your information secured
We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.
We employ industry standard procedures and controls to ensure the safety of our users’ information, such as:
- Secure network topology, which includes intrusion prevention and Firewall systems;
- Encrypted communication;
- Authentication and Access Control;
- External and Internal audit tests; etc.
Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
How to contact us
If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us via email at DPO@Whiplr.com or by sending a letter to:
Attn: Data Protection Officer
Unit 3203-4, No. 69 Jervois Street, Sheung Wan, Hong Kong.
You may contact our representative in the EU by the following contact details:
We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can reach out to the applicable data protection supervisory authority.
This part of the Policy addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (Cal. Civ. §§ 1798.100–1798.199) and the California Consumer Privacy Act Regulations by the Attorney General (collectively, 'CCPA').
1. Categories of Personal Information We Process?
In the 12 preceding months, we have collected and disclosed the categories of Personal Information as listed in the above sections 'What Information We Collect?' and 'With Whom We Share Information?'
We do not sell (as this term is defined under the CCPA) any Personal Information.
We may share or transfer Personal Information to third parties as assets that are part of a merger, acquisition, bankruptcy or other transaction in which the third party assumes control of all or part of the Company. Such transfer will be handled according to the requirement of the CCPA and shall not be regarded as a sale of Personal Information under the CCPA.
2. Sources of Personal Information
In the 12 preceding months, we have collected the above-mentioned categories of Personal Information from the following categories of sources:
- Consumer directly;
- Social Networks;
- Internet Service Providers;
- Data analytics providers;
- Operating Systems;
- 3rd party billers.
3. User Rights under the CCPA
The CCPA provides consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Personal Information
You may request, up to two times each year, that we disclose to you the categories and specific pieces of Personal Information that we have collected about you, the categories of sources from which your Personal Information is collected, the business or commercial purpose for collecting your Personal Information, the categories of Personal Information that we disclosed for a business purpose, any categories of Personal Information about you that we sold, the categories of third-parties with whom we have shared your Personal Information, and the business purpose for sharing your Personal Information, if applicable.
You have the right to request that we delete any Personal Information collected from you and retained, unless an exception applies.
Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, subcontractors, and consultants to delete) your Personal Information, unless an exception applies.
Exercising Your Rights
You can exercise your rights (such as access and deletion) by submitting a verifiable consumer request to our email address: DPO@whiplr.com or by sending a mail to our physical address specified in the HOW TO CONTACT US section.
Only you or a person authorized to act on your behalf may make a consumer request related to your Personal Information.
The request must:
· Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
· Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
· We cannot respond to your request or provide you with Personal Information if we 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. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
You may only request a copy of your data twice within a 12-month period.
If you have any general questions about the Personal Information that we collect about you how we use it, please contact us at DPO@whiplr.com.
Response Timing and Format
Our goal is to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing within the first 45 days period. We will deliver our written response, by mail or electronically, at your option. Any disclosures we provide will cover only the 12-month period preceding the request. If reasonably possible, we will provide your Personal Information in a format that is readily useable and should allow you to transmit the information without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
In case of rejection, the response we provide will explain the reasons for which we cannot comply with your request.
Please note that these CCPA rights are not absolute and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.
You can designate an authorized agent to make a request under the CCPA on your behalf if:
· The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
· You sign a written declaration that you authorize the authorized agent to act on your behalf.
If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
Unless permitted by the CCPA, we 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.