1. PRESENTATION AND DEFINITIONS
Whosup takes all necessary measures to protect the privacy of the Member of its community (our user), in compliance with the legislation in force. This document details the ways of collecting, storing, using, sharing and disseminating personal data, as well as the measures taken to ensure the protection of the data collected.
The Member gives the free, express, informed and unequivocal consent for Whosup to use the information obtained, in addition to the services offered by its Platform (Web and App), the customization of Member service, as well as the identification of those responsible for undue and / or illegal conduct performed using the Whosup Platform.
2. COLLECTION, USE AND STORAGE OF DATA
- Register. The data to be provided by the Member when the profile is created in the Platform will depend on how the Whosup services will be used. In addition to general information such as email, phone, date of birth, gender and full name, the Member may complete a detailed questionnaire on different topics. This information will only be used to customize the Whosup services, and display events and people/groups compatible to the Member’s interests, personality and profile.
- CoachBot Pep. The conversations generated with Pep, Whosup’s lifestyle and relationship coach (artificial intelligence), will be collected and stored for the customization of the service offered in terms of improving assertiveness in offering options of activities or people/groups to meet, as well as general conversations between Member and Pep. All data provided in this context will be confidential and used anonymously, that is, they will not be able to identify a particular person.
- Access records. Whosup will maintain in its database all information regarding Member access to the Platform, including but not limited to the IP address, the pages accessed, the times and dates of access, and the access device used, in accordance with the current legislation. Such records may be used in internal or public audits to investigate practices that could generate any harm to Whosup or third parties on the Platform, including the practice of crimes in virtual environments.
- Purchases made on the Platform. When the Member contracts a paid service or makes a purchase directly on Whosup Platform, the Member provides information such as debit or credit card number, validity and/or other financial information.
- Conversations with other Members. When a Member exchanges messages with another Member (or group of Members) through Whosup Platform, the messages will be stored in our servers and we can collect the information transmitted there. This information will be confidential and used anonymously, that is, they will not be able to identify a particular person.
- Geolocation, photos and videos. If Member authorizes, Whosup Platform may collect the respective exact geolocation, according to the means of service and how the Member uses the Platform, including GPS, Bluetooth or Wi-Fi wireless connections. The geolocation collection may also occur in background when the Member is not using the Platform directly. In the same way, if the Member also grants permission to do so, Whosup may collect photos and videos posted on the Platform as well as the list of telephone and email contacts on the mobile devices. Also, as per Member authorization, pushes (alerts) of event, people and groups, and/or Pep conversations could be sent to Member devices.
Use of data. The Members’ data will be used for the following purposes: sending information on purchases made on the Platform, advertising, statistics’ development and/or improvement of interactivity tools, depending on the service plan contracted by the Members. The Members’ data will also be used to comply with legal/court orders. The data stored in the Whosup Platform will not be used in a different way without the prior consent of the Member.
Whosup has a specific regulation to Members regarding the characteristics and conditions of use of its services: Terms and Conditions of Use.
3. HOW WHOSUP USES MEMBER’S INFORMATION
We will use the information and personal data of Members to provide the best possible service. In addition, we will use the information collected and transmitted to:
- Enable connection, communication, entertainment, support and enrichment for the creation and development of relationships with other Platform Members;
- Recommend Members who have common interests and/or temperament (personality) complementarity, via the compatibility index among Members;
- Ensure a solid and consistent experience in all devices for use;
- Provide new services or third party offerings that might be of Members’ interests;
- Enhance Whosup’s services and develop new ones according to the Members’ interests;
- Provide ads according to Members’ preferences and interests;
- Prevent, detect and combat violations and fraud or other unauthorized activities that could harm the Platform Members and/or the Whosup community.
Whosup will use Member’s information through:
- Free, express, informed and unequivocal consent of the Member. Whosup may, from time to time, request consent to use Members’ information for specific reasons. Thes Members may revoke their consent at any time by contacting the email email@example.com.
- Legitimate interest. Whosup may use its Member’s information in cases where Whosup has the legitimate interest to do so, such as support and promotion of Whosup activities, the protection of the regular exercise of Member’s rights or the provision of services that benefit individual or collectively the Whosup community, respecting the Members’ legitimate expectations with respect to Whosup's services and fundamental rights and freedoms related to information privacy.
4. MEMBER RIGHTS
Members have the following rights regarding the use of their personal data:
- The right to deactivate and remove their data and to delete their account;
- The right to access, rectify and cancel, and opposes the processing of their data, including for marketing and advertising preferences of the account;
- The right to determine how data will be used and processed, and the use of personal data after death;
- The right to request the receipt of personal data by Members.
Members may exercise and practice such rights through the Whosup Platform itself or by a specific tool created in the future. They may also request such rights directly by email to firstname.lastname@example.org.
The privacy laws applicable to this document guarantee the Members’ right to review their personal information that Whosup has, as a right of access. Members may request a copy of their personal information by submitting a request at this link or by sending this request to email@example.com.
5. DATA SHARING AND DISCLOSURE
- Intracompany sharing. The data can be shared within Whosup’s subsidiaries, as well as among companies of the same economic group, both national or international.
- Transfer to trading partners. In the case of transfer of pertinent data to transactions with trading partners, they will be contractually obliged to protect the information provided.
- Transfer to third parties: In the event that statistics are compiled by a third party company, the shared data will not have any element of identification of the Member.
- Disclosure of Member’s data to other Members of the Platform: According to the services provided, Whosup will disclose the data of Member’s profile with other Members which have "compatible profiles". Information such as photos, name, age, posts published and affinity groups will be available to Members with whom your profile is aligned and compatible.
Whosup will not disclose your contact information to any Platform Member, unless you post such information openly on your profile, leaving yourself at your own risk.
6. RESIDENTS OF CALIFORNIA STATE
If you are a resident of the State of California, located in the United States of America, and under the California Consumer Privacy Act, you may request notice with disclosure of categories of your personal information that Whosup shares with business commercial partners for purposes of direct marketing during the previous year. To request such notification, send your request through this link.
In order for Whosup to review your request, Whosup may take about 30 days to return with a response and Whosup may also request proof of identity to grant its response.
7. EXTERNAL LINKS
Whosup can provide links to external sites, plug-ins, and business partner applications. If access to other sites occurs from the links made available in Whosup Platform, the operators of these other sites and the commercial partners may collect, store and share the personal information of the Members who have accessed.
Whosup does not control third-party sites and Whosup recommends that you review the privacy policies of these third parties, which may be different from Whosups, so that you can understand the procedures for collecting, using and storing personal data.
8. AGE FOR USE AND PRIVACY OF TEENAGERS AND CHILDREN
The services offered by Whosup Platform are limited only to those who are 18 years of age or over. Whosup will not permit the use of its Platform for persons under the age of 18 and will not, knowingly, collect personal information from such persons.
If there is any personal information about a person under the age of 18 in its Platform (Web or App), Whosup will delete or destroy this information as soon as reasonably possible.
9. SAFETY PRECAUTIONS
Technological resources. Whosup adopts advanced technological resources to ensure the security of all personal data collected and stored. Access to the Members database is limited only to those whose functions require the contact with personal data.
The Members declare that they are the legitimate holders of their personal data and may at any time use the Platform's tools to edit, update or remove them from the database.
Monitoring. Whosup monitors its systems to address possible vulnerabilities, in order to avoid inconsistencies and security events. Whosup also reviews, regularly, its data collection, storage, and processing practices to maintain its security standards.
Total or partial suspension of services. Whosup may suspend all or part of the services provided to a Platform Member without prior notice, if Whosup suspects or detects a security breach.
- Directly by Whosup Platform;
- Sending an email to contact firstname.lastname@example.org;
- By mail through the address: Whosup Inc., 44 Tehama Street, San Francisco, CA 94105, USA.