Legal

Privacy Policy

Privacy Notice — Updated 7th September 2022
Whisp Limited (CRN 13508220) (we, us or our), understands that protecting your personal data is important. This Privacy Notice sets out our commitment to protecting the privacy of personal data provided to us, or otherwise collected by us when providing our artificial intelligence services (Services) or when otherwise interacting with you.

It is important that you read this Privacy Notice together with any other detailed privacy notices we may provide when we are collecting or processing personal data about you so that you understand our privacy practices in relation to your data.

The information we collect

Personal information: is information that relates to an identified or identifiable individual. We may collect, use, store and disclose different kinds of personal data about you which we have listed below:

  • Identity Data including first name, last name and job title.
  • Contact Data including address (physical or billing), email address and telephone numbers.
  • Technical and Usage Data including internet protocol (IP) address, your login data, your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour, information about your access and use of our website, including through the use of Internet cookies, your communications with our website, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider.
  • Profile Data including your username and password for our Services, purchases or orders you have made with us, support requests you have made, your interests, preferences, feedback and survey responses.
  • Interaction Data including information you provide to us when you participate in any interactive features of our Services, including surveys, contests, promotions, activities or events.
  • Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Professional data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience.
  • Special Categories of Personal Data is a special category of personal data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not actively request special categories of data about you, nor do we collect any information about criminal convictions and offences. If at any time we need to collect special categories of data about you, we will only collect it and use it as required or authorised by law.
How we collect personal information

We collect personal data in a variety of ways, including:

  • Directly: We collect personal information which you directly provide to us, including through the ‘contact us’ form on our website or when you request our assistance via email, or over the telephone.
  • Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries.
  • From third parties: We collect personal information from third parties, such as from your employer where they invite you to access our Services and details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.
  • From publicly available sources: We collect personal data from publicly available resources such as Companies House and professional networking sites such as LinkedIn.
Purposes and legal bases for processing

We collect and process personal data about you only where we have legal bases for doing so under applicable laws. We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please access the table of purposes here.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please reach out to us if you need further details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using our services. Further information about your rights is available below.

Our disclosures of personal information to third parties

We may disclose personal information to:

  • our employees, contractors and/or related entities;
  • IT service providers, data storage, web-hosting and server providers, such as Amazon Web Services and others as may be engaged from time to time;
  • marketing or advertising providers, as may be engaged from time to time;
  • professional advisors, bankers, auditors, our insurers and insurance brokers;
  • payment systems operators such as Stripe and others as may be engaged from time to time;
  • our existing or potential agents or business partners;
  • sponsors or promoters of any promotions or competition we run;
  • anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
  • courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
  • courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and
  • any other third parties as required or permitted by law, such as where we receive a subpoena.
Overseas transfers

Where we disclose personal data to the third parties listed above, these third parties may store, transfer or access personal data outside of the United Kingdom, including Switzerland and the Netherlands. The level of data protection in countries outside of the United Kingdom may be less comprehensive that what is offered in the United Kingdom. Where we transfer your personal data outside of the United Kingdom, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred personal data in accordance with this Privacy Notice. This includes:

  • only transferring your personal data to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal data; or
  • including standard contractual clauses in our agreements with third parties that are overseas.
Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your rights and controlling your personal data

Your choice: Please read this Privacy Notice carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Notice. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Notice. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Access, correction, processing and portability: You may request details of the personal data that we hold about you and how we are process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal data rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to you or another organisation.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Withdraw consent: Where we are relying on consent to process your personal data, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.  

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

Cookies

We may use cookies on our website from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our online Services. They include, for example, cookies that enable you to log into secure areas of our online Services, use a shopping cart or make use of e-billing services.
  • Analytical/performance cookies. These are cookies that allow us to recognise and count the number of visitors to our online Services and to see how visitors move around our online Services when they are using them. This helps us to improve the way our online Services work, for example, by ensuring that users find what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our online Services. These cookies enable us to personalise our content for you and remember your preferences (for example, your choice of language or region).
Links to other websites

Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Notice.

Personal information from social network accounts

If you connect your account with us to a social network account, such as Google and Apple, we will collect your personal information from the social network. We will do this in accordance with the privacy settings you have chosen on that social network.

The personal information that we may receive includes your name, email and any other personal information you choose to share.

We use the personal information we receive from the social network to create an account or profile for you.

If you agree, we may also use your personal information to give you updates on the social network which might interest you. We will not post to your social network without your permission.

Where we have accessed your personal information through your Facebook account, you have the right to request the deletion of personal information that we have been provided by Facebook. To submit a request for the deletion of personal information we acquired from Facebook, please send us an email at the address at the end of this Privacy Notice and specify in your request which personal information you would like deleted. If we deny your request for the deletion of personal information, we will explain why.

Use of Google API Services (this section applies to personal information accessed through Google API Services)

We use Google’s Application Programming Interface (API) Service to assist with bot detection.

Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements (set out in the Google API Services User Data Policy).

We limit our use of the personal information that we collect to providing or improving our Services. We do not use the personal information for any other purposes.

We only transfer the personal information to others if it is necessary to provide or improve our Services or as necessary to comply with applicable law or as part of a merger, acquisition or sale of assets where we notify you of this.

We do not use or transfer the personal information for serving ads, including retargeting, personalised or interest based advertising.

We don’t allow humans to read the personal information unless:

  • we have first received your consent to view specific messages, files or other data;
  • it is necessary for security purposes (such as investigating a bug or abuse);
  • our use is limited to internal operations and the personal information (including derivations) have been aggregated and anonymised.

These restrictions apply to the raw data we obtain from the restricted scopes and data that is aggregated, anonymised or derived from them.

We have policies and procedures in place setting out appropriate safeguards for protecting your personal information obtained with the Google APIs. We will also ensure that our employees, agents, contractors and successors comply with the Google API Services Data Policy.

Amendments

We may change this Privacy Notice from time to time. We will notify you if we make a significant change to this Privacy Notice, by contacting you through the contact details you have provided to us and by publishing an updated version on our website. For any questions or notices, please contact us at: compliance@whisp.ai