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PRIVACY POLICY

Effective date: 01 Jan 2021

WHO is firmly committed to the security and protection of personal information of our Users and their contacts. This Privacy Policy describes how WHO will collect, use, share and process personal information. Capitalized terms not defined in this Privacy Policy are defined in the WHO Terms of Service.

By accepting the WHO Privacy Policy and/or using the Services You consent to the collection, use, sharing and processing of personal information as described herein.

If You provide us with personal information about someone else, You confirm that they are aware that You have provided their information and that they consent to our use of their information according to our Privacy Policy. You may opt-out at any time to prevent further use of the information shared via Email.

1. PERSONAL INFORMATION COLLECTED
1.1 USER PROFILE

When You create a user profile in the Services and confirm being the holder of a certain number, WHO will collect the information provided by You. In order to create a user profile, You must register Your first name, last name and phone number.

Additional information that may be provided at Your option include, but is not limited to, photo, gender, street address and zip code, country of residence, email address, professional website, Facebook page, Twitter address and a short status message. WHO may supplement the information provided by You with information from third parties and add it to the information provided by You e.g. demographic information and additional contact information that is publicly available.

1.2 INSTALLATION AND USE

When You install and use the Services, WHO will collect personal information from You and any devices You may use in Your interaction with our Services.

This information may include e.g.: geo-location; Your IP address; device ID or unique identifier; device manufacturer and type; device and hardware settings; SIM card usage; applications installed on your device; ID for advertising; ad data, operating system; web browser; operator; IMSI; connection information; screen resolution; usage statistics; default communication applications; access to device address book; device log and event information; logs, keywords and meta data of incoming and outgoing calls and messages; version of the Services You use and other information based on Your interaction with our Services such as how the Services are being accessed (via another service, web site or a search engine); the pages You visit and features you use on the Services; the services and websites You engage with from the Services; content viewed by You, content You have commented on or sent to us and information about the ads You see and/or engage with; the search terms You use; order information and other usage activity and data logged by WHO’s servers from time to time. WHO may collect some of this information automatically through use of cookies.

Some information, including, but not limited to, usage information and other information that may arise from Your interaction with the Services, cannot be used to identify You, whether in combination with other information or otherwise and will not constitute personal information for the purposes of this Policy.

1.3 THIRD PARTY SERVICES

Third parties may collect information by using cookies, web beacons, or GPS information. A cookie is a small file that contains a unique ID tag and stores information (e.g., pages visited, information voluntarily provided). A web beacon is a small graphic file used to identify if a page has been viewed. GPS information may include city, state, and other information when you use our products or services on a GPS-enabled mobile device.

Third parties may collect information in order to;

  • deliver relevant online and mobile advertising to you both on and off our sites
  • help us provide or analyze usage and effectiveness of our products and services
  • for their own business purposes (e.g., such as to report aggregate, non-personally identifiable information about the use of their services and technologies
1.4 CONTACT INFORMATION

Where the WHO mobile applications (“WHO Apps”) are obtained from other sources than Apple App Store or Google Play, You may share the names, numbers, Google ID’s, email addresses, and other info contained in Your address book (“Contact Information”) with WHO by enabling the WHO Enhanced Search Functionality. Where the WHO Apps are obtained from Apple App Store or Google Play, we do not share any user Contact Information with third parties or for any commercial uses.

Please also note that You can always choose not to share Contact Information with WHO and if You have shared such information and changed Your mind, You can delist Your number or opt-out to render Your entire Contact Information unavailable for search in the WHO database.

1.5 OTHER INFORMATION YOU MAY PROVIDE

You may provide us with various information in connection with Your interaction with our Services. For example, You may through tagging functionality associate a phone number that is not registered in the WHO database or belongs to a User, with a business or name and You may report a phone number as spam or some other attribute to be included in spam blocking directories.

WHO may also from time to time offer You the opportunity to provide information on Your experience from using the Services or to participate in contests, surveys or other promotions. WHO will collect the information You provide in connection therewith, as well as any other information You provide through the Services or when You communicate or interact with us.

2. USE OF PERSONAL INFORMATION
2.1 PROVIDE, IMPROVE AND PERSONALIZE OUR SERVICES

WHO may use the personal information collected to provide, maintain, improve, analyze and personalize the Services to its Users, partners and third party providers. More specifically, WHO may use such information to:

provide smart caller ID, dialer and messaging functionality that, among other features, allow for population of unidentified numbers and other data in call or message logs, display the name associated with a certain number for incoming or outgoing calls and messages

2.2 STATISTICAL DATA FROM THE SERVICES

We use aggregated or anonymized personal information for statistical and analytical purposes. We may come to share such data with third parties.

We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.

2.3 PERSONALIZE OUR ADVERTISING AND COMMUNICATIONS

We may use any of the information collected, as set out above, to provide You with location and interest based advertising, marketing messaging, information and services. We may also use the collected information to measure the performance of our advertising and marketing services.

We may contact You for verification purposes or with information pertaining to the Services or special offers, e.g. newsletter e-mails, SMS and similar notifications about WHO’s and our business partners’ products and services. We also use the collected information to respond to you when you contact us.

2.4 COMPLIANCE WITH LAWS AND PREVENTION OF FRAUDULENT OR ILLEGAL ACTIVITIES

We may use the collected information to comply with applicable laws and to enforce our agreements and protect and defend the rights or safety of WHO, its Users or any other person and verify provided User profile information with third party providers and ensure technical service functionality and data accuracy, perform trouble-shooting and prevent or detect fraud, security breaches or illegal activities.

3. SHARING AND DISCLOSURE OF PERSONAL INFORMATION

In addition to the sharing and disclosure of personal information that is included as part of the functionality of the Services as described in section 2 above, WHO may disclose personal information if we believe such action is necessary to:

  • comply with the law, or legal process served on us;
  • protect and defend our rights and the enforcement of our agreements
  • protect the security and safety of Users or members of the public or other aspects of public importance, provided, of course, that such disclosure is lawful.
  • We transfer information to trusted vendors, service providers, and other partners who support our business and Services, such as providing technical infrastructure services, bug testing, analyzing how our Services are used. WHO will always require these third parties to take appropriate organizational and technical measures to protect personal information and to observe applicable legislation. WHO may also share personal information with third party advertisers, agencies and networks. Such third parties may use this information for analytical and marketing purposes e.g. to provide measurement services and targeted ads and for improvement of products and services.
  • We may disclose and transfer Your Information to our associated or affiliated organizations or related entities and to any third party who acquires our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets.
4. DELISTING OF CONTACT INFORMATION AND OPT-OUT OF AD TARGETING

If a User chooses to disable the Enhanced Search Functionality, the Contact Information made available by that User is disabled and will thereafter not be available for search in the WHO database.

If any persons do not wish to have their names and phone numbers made available through the Enhanced Search or Name Search functionalities, they can exclude themselves from further queries by notifying WHO via its website or as set forth in the contact details below. You acknowledge and agree that WHO may keep and process personal information related to such requests in order to be able to honor the request.

You can limit or opt-out of the collection and use of Your information for ad targeting by sending email to Info@whoapp.ai

5. INFORMATION SECURITY AND TRANSFER OF PERSONAL INFORMATION TO OTHER COUNTRIES

In order to provide the Services, WHO will transfer, process and store personal information in a number of countries, including but not limited to India, and may also use cloud based services for this purpose.

WHO may also subcontract storage or processing of Your information to third parties located in countries other than Your home country. Information collected within one country may, for example, be transferred to and processed in another country, which may not provide the same level of protection for personal data as the country in which it was collected.

You acknowledge and agree that WHO may transfer Your personal information as described above for purposes consistent with this Privacy Policy. We take all reasonable precautions to protect personal information from misuse, loss and unauthorized access.

WHO has implemented physical, electronic, and procedural safeguards in order to protect the information, including that the information will be stored on secured servers and protected by secured networks to which access is limited to a few authorized employees and personnel. However, no method of transmission over the Internet or method of electronic storage is 100% secure.

6. ACCESSING AND UPDATING PERSONAL INFORMATION

WHO may on its own initiative, or at Your request, replenish, rectify or erase any incomplete, inaccurate or outdated personal information retained by WHO in connection with the operation of the Services.

When required by applicable law, You have the right to know what personal information is stored about You and to have any such information corrected or deleted on Your request. See contact details below.

7. MINORS

Services are not intended for or designed to attract anyone under the relevant age of consent to enter into binding legal contracts under the laws of their respective jurisdictions.

WHO does not intentionally or knowingly collect personal information through the Services from anyone under that age. We encourage parents and guardians to be involved in the online activities of their children to ensure that no personal information is collected from a child without their consent.

8. CHANGES TO THIS PRIVACY POLICY

WHO may at any time with or without a separate notice change this Privacy Policy, and You are encouraged to review this Policy from time to time. In case of substantial changes, WHO will notify the Users by push notice or via notice in the Services. Your continued use of the Services after a notice of changes has been communicated to You or published on our Services shall constitute consent to the changed policy.

9. COOKIES

As described in our Cookie Policy, we use cookies, web beacons, flash cookies, HTML 5 cookies, pixel tags and other web application software methods, including mobile application identifiers, to help us recognize you across the Services, learn about your interests both on and off the Services, improve your experience, increase security, measure use and effectiveness of the Services, and serve advertising.

You can control Cookies through your browser settings and other tools. By interacting with the Services, you consent to the use and placement of Cookies on your device in accordance with this Privacy Policy, which by reference incorporates our Cookie Policy.

10. WHAT PERSONAL DATA DO WE PROCESS?

We collect information given directly by you and automatically as you use the Service. The personal data relating to you that we process may include the information set out below.

A key component of the Service is to assist our users in discovering businesses near their physical location and enabling them to call such businesses or otherwise get in contact with those businesses. To do so, we may collect search, location and call log information automatically from our users’ devices.

  • Mobile device IDs , including a hashed version of your phone number
  • Mobile carrier
  • Language information
  • Your current country
  • Device name and model; operating system type, name, and version
  • Your activities within the Service

If you contact us, we will collect whatever information you choose to provide in your correspondence with us often this includes your phone number, email address or other contact details.

We may combine this information with other information that we have collected about you, including, where applicable, your user id, preferences, and other personal data. Please see the section “Our Use of Cookies and Other Tracking Mechanisms” for more information.

11. WHAT DO WE DO WITH YOUR PERSONAL DATA?

In case you are one of our users, we may process your personal data for the purposes listed below.

As necessary to perform our contract with you, for our or third parties’ legitimate interests, especially in order to provide the Service to you and other users, to assist our users in discovering and calling businesses, including:

  • To match the information in your phone logs with numbers from the calls you make or receive, as well as with information in our database. We also may store this information for subsequent data validation for both you and other users of the Service and other products;
  • To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Service;
  • To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising.
  • If you contact us we may process your personal data to communicate with you about your use of the Service, to respond to your inquiries, and for other user services purposes;
  • To better understand how users access and use the Service, both on an aggregated and individualized basis;
  • To improve the Service, and for research and analytics purposes;
  • To administer the Service, and other systems, including troubleshooting, and data analysis, testing, research, statistical and survey purposes;
  • To improve the Service to ensure that content is presented in the most effective manner for you and for your device;
  • To keep our website, Apps and other systems safe and secure;
  • The data we collected never uses for commercial purposes
12. CONTACT

If You have any additional questions about WHO’s Privacy Policy or want to make a request regarding certain personal information, You are encouraged to contact WHO. The contact information is:

RD Labs LLC, Seattle, WA 98101

You can also send Your enquiries via email to info@whoapp.us