If this Policy changes in the future, we will post an updated version on our website at https://app.whirple.com/home/Privacy (the “Website”). We recommend that you check this Website periodically in order to review our current Policy. You can tell if this Policy has changed by checking the effective date that appears at the bottom of this Policy. Depending on the circumstances, we may also decide to send you a notice in other ways in our discretion, such as via email or other contact information you have provided that the Policy was changed. If you continue to use our Products after the Policy changed or notice of the change has been given, you will be deemed to have accepted such changes.
By using, registering to or otherwise accessing our Products, Website and/or other services (collectively, the “Services”), you agree to this Policy and give your explicit, informed consent to the collection, use and processing of your personal data in accordance with this Policy. If you do not agree to this Policy please do not visit, use, register to, or otherwise access any Services.
You may withdraw your consent at any time, unless such consent would frustrate the performance of a legal obligation. Your withdrawal or refusal to grant consent may restrict our ability to provide the Services.
There are limited circumstances in which we may collect, use or disclose personal information without your consent.
- When the collection, use or disclosure of personal information is permitted or required by law.
- In an emergency that threatens an individual’s life, health or personal security.
- When the personal information is available from a public source.
- When we require legal advice from a lawyer.
- For the purposes of collecting debt.
- To protect ourselves from fraud.
- To investigate an anticipated breach of an agreement or a contravention of law.
1. How We Collect Personal Information
Like most website operators, we collect personal information about you from a variety of sources. We only collect information by lawful means, with your knowledge and consent. We also let you know why we’re collecting it and how it will be used. We collect information from you in the following ways:
- Directly from you (when you sign up for or use our Services).
- From any third-party sources.
- Automatically from devices that you use to connect to our Product.
2. Information We Collect
When you use our Products or Services, we may collect the following types of information:
- Account Information: When you use our Products, you will need to create an account with us through a third-party platform, such as Facebook. In order to create an account, you will need to provide us with a complete profile: login credentials (which include your username and password), your name, location, age range, email address, gender, and cities to which you may want to travel.
- General Usage Data: When you use our Products, we may collect technical properties of hardware and software utilized in conjunction with our Products, including information about Web browser, IP address, operating system, referring or exit web pages, operating system version, and hardware model of device or personal computer platform.
- Purchase and Payment Information: While payments made through our Products are processed through a third party such as PayPal, we may collect information to administer, manage, and fulfill the purchases you make. For example, we may collect your name, email address, account information, what is ordered, the date and time of the order, the quantity and price of the order, whether payment was made, method of payment, purchase history and related tax information, and if you re-ordered.
- Location Information: When you use our Products, we collect your Internet Protocol (“IP”) address.
- Third Party Information: If necessary to fulfill our identified purposes, we may combine the information you submit to us with information obtained from other sources such as Facebook or third-party offerings. For example, we may receive personal information about you from third parties involved in providing you with the products, services, software, and websites you are utilizing, such as from your email, calendar, and online file storage provider to facilitate the integration of those products, services, software, and websites with our Products. We treat all such personal information in accordance with this Policy and the terms and conditions between us and such third parties, if any, may also apply. However, the third party’s own use of your personal information in such cases will be determined by your agreement(s) with the third party, unless that third party is one of our service providers.
- Communications with Us, Quality Assurance, and Customer Service: Your customer service telephone calls, emails, and chat messages with us and our service providers, if any, may be recorded, logged, and/or monitored for quality assurance and customer service purposes such as to assist in addressing your inquiries, troubleshooting, training and analytics to identify trends and make improvements to our Services and customer service. As part of the recording and logging of the calls and emails, we will collect information like the identity of the caller or sender of email, his/her location, the date and time of the call or email, and the subject and resolution of the issue.
- Health Information: We may log information volunteered by users regarding illness and disability as it relates to event attendance and accessibility.
- Other Sources: to the extent permitted by applicable law we may receive additional information about you, such as demographic data or fraud detection information and warnings, or other information about you from partner networks.
Some of this information would not by itself identify you to us or be personally identifiable and is therefore considered non-personal information. If we combine any such non-personal information with other personal information available to us, the combined information will be treated as personal information in accordance with this Policy.
3. Our Use of Information We Collect
We use the personal information we collect about you for the following purposes:
- Verifying identity and authenticating information.
- To provide the Services and operate our business.
- To understand and meet your needs and preferences, and/or to provide you with our Products, for example:
- For purposes related to the billing, payment, activation, provision, maintenance, support, trouble shooting, resolving of disputes, deactivation, upgrade, or update of Products.
- To process and fulfill your order, send you emails to confirm your order status and shipment, send you Products or goods you order, and allow you to pay for Products and goods you order
- To ensure Products are technically functioning as intended and to help identify and troubleshoot issues.
- To fulfill or enforce any agreements or notices we provide and are associated with a particular Product (“Notices”);
- To manage or respond to your inquiries or complaints.
- To maintain relationships.
- To develop new and enhance existing Products including to communicate with you about them using various means, for example to make available or send to you upgrades or updates, or to send notices of upgrades or updates of Products to make available or promotions and upcoming events.
- To send newsletters or other marketing information (which you may opt out of).
- To manage and develop our business and operations, for example:
- To detect, monitor, investigate, mitigate or attempt to prevent fraud and technical or security issues or to protect our property;
- To allow for business continuity and disaster recovery operations.
- To enforce our legal rights.
- For statistical purposes.
- To optimize experiences by performing analytics and conducting research.
- To conduct investigations.
- For resolving disputes and enforcing agreements and our policies.
- To meet and comply with legal and regulatory requirements and to respond to emergency situations, for example:
- To respond to court orders, warrants or other lawful requests or legal processes.
- To provide emergency assistance in situations that may threaten the life or physical safety of you or others.
- For any other purposes for which you have consented, such as those that may be set out in Notices, and other purposes as permitted or required by any applicable law.
4. Disclosure of your Personal Information
In accordance with this Policy, we may share your personal information. We may disclose personal information to fulfil the purposes identified in this Policy, and for purposes related thereto, and to provide the Services, including as follows:
- Within Company and/or with our service providers such as a cloud service provider in Canada, the United States, and the European Economic Area for data storage.
- With our financial, insurance, legal, accounting or other advisors that provide professional services to us (third party providers have their own rules and privacy policies and we encourage you to review these rules and policies).
- If we have your consent.
- With third parties involved in providing funding to the Company (third party providers have their own rules and privacy policies and we encourage you to review these rules and policies).
- With third parties involved in sponsoring and/or providing our Products to you, or payment processors (third party providers have their own rules and privacy policies and we encourage you to review these rules and policies).
- With any other of our business partners who carry out tasks on our behalf (each provider has its own rules and privacy policies and we encourage you to review these rules and policies).
- With other third-party services providers such as Google Analytics (we share your information with them so they may carry out tasks on our behalf, third party providers have their own rules and privacy policies and we encourage you to review these rules and policies).
- Certain information may be shared with third parties or published when you follow links to third party websites, we do not own or control these third parties and when you interact with them you may be providing information to them directly – such parties will have their own rules and policies in respect of the collection, use and disclosure of personal information and we encourage you to review these rules and policies.
- Certain aggregated and anonymized information may be shared publicly – we do not disclose the specifics of personal information publicly.
- As necessary to complete any transactions while using our Products.
- To respond to a subpoena, order, legal process, or government request.
- To protect, establish or exercise our legal rights or defend against legal claims.
- To investigate, detect, suppress, prevent or act regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or physical safety of any person.
- As otherwise required by law, for example and without limitation, pursuant to an access to information request.
- If we are to be sold, merged, or amalgamated or substantially all of its assets are to be sold or disposed of, your personal information may be transferred to a potential purchaser if, and to the extent necessary, it is required for the purposes of deciding whether to proceed with the proposed transaction and completing it. If such a sale, merger, acquisition, or disposal is completed, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with this Policy. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.
5. Aggregated and Anonymized/De-Identified Information.
Notwithstanding anything to the contrary contained in this Policy, as provided for above, we may remove personal identifiers from your information and maintain and use it in a de-identified form that may be combined with other information to generate aggregated information. Such de-identified and/or aggregated information will be deemed to be owned by us and we shall have unrestricted title, rights, and interest to the de-identified and/or aggregated information which may include, without limitation, the right to use, distribute, transmit, transfer, license, trade, rent, share, assign, and sell the de-identified and/or aggregated information. We will retain your personal information as long as necessary for the fulfillment of the identified purposes or as otherwise necessary to comply with applicable laws.
You may update your communication preferences anytime by writing us at email@example.com.
6. Your Decisions About Your Personal Information
At any time you can contact us to: stop receiving emails from us; review the personal information held by us in connection with your account; withdraw your consent for our use and disclosure of your information; request a list of third parties to which we may have provided your personal information; close your account; and amend your personal information, by writing to us at 37 Laver Road, Toronto, ON, Canada, M9C 3K4. You can always unsubscribe from receiving promotional emails from us by simply clicking the “unsubscribe” link provided at the bottom of every promotional email from us.
If you contact us to do any of the things listed above, we may require you to provide sufficient personal information to allow us to identify you and tell you about the existence, use and disclosure of your personal information and this personal information will only be used for this purpose. If you contact us about your personal information, we will respond to your request within a reasonable time and at minimal cost or no cost to you in accordance with applicable laws. If a request is refused, you will be notified of the refusal in writing and provided with reasons for the refusal.
Generally, you may withdraw at any time your consent for us to collect, use, and disclose your personal information in accordance with this Policy, subject to legal or contractual restrictions and reasonable notice. As such, we may continue to collect, use, and disclose your personal information as may be required to provide you with our Products, and to the extent that we are contractually obligated to do so or as necessary to enforce any contractual obligations you may have with us. If you refuse to provide us with the information we require or later contact us to withdraw your consent for us to use and disclose your personal information, we may no longer be able to provide you with our Products.
When you visit the Website, we collect certain information by automated means, such as through server log files, cookies (text files sent to and stored on your device when you access the Website), web beacons (also known as clear GIFs and pixel tags, which may be used to transmit information back to the Website), and embedded scripts (programming code that is designed to collect information about your interactions with the Website, such as the links you click on, and which is active only when you are accessing the Website).
The information we collect in this manner may include details about the computer, mobile phone, or other device used to access the Website (such as browser type, operating system, and IP address), referring URLs and information on actions taken or interaction with our digital assets.
We may use third-party web analytics services to help us analyze how visitors use the Website. We may permit these third parties to operate directly on the Website, use their own technology (such as cookies or web beacons), and collect information about you on our behalf.
The information we collect in this manner is collected to enhance your user experience. For example, this information allows us to pre-fill form fields as well as provide you with contextual recommendations while using the Website.
When you visit our Website, we may allow some third parties (such as advertising networks and data analytics companies) to collect information about your online activities over time and across different websites. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. However, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” visit http://www.allaboutdnt.com.
In some instances, we may also combine information we receive about you from third parties with information we collect through the Website.
We aim to provide you with a safe experience. We have in place certain physical, technical, and administrative safeguards designed to appropriately protect the security and privacy of your personal information against loss, theft, and unauthorized access, disclosure, copying, use, or modification. Please note, however, that we cannot guarantee that the measures we maintain will guarantee the security of the information.
We only retain personal information for as long as necessary to provide a service, or to improve our Services in future.
We limit access to your personal information within the Company to individuals with a need to know.
Your personal information may be collected, used, processed, transferred, and retained in multiple countries and jurisdictions including Canada, the United States, United Kingdom, Australia, South America, Asia, and the European Economic Area which may be outside the region in which you are situated and may have different privacy or data protection legislation, and may therefore be subject to the laws of these countries. If you are a resident of the European Economic Area or a country which restricts data transfers outside of that jurisdiction or region without your consent, by using our Products, you consent to your personal information being transferred outside of the European Economic Area or your country for processing or storage by or on behalf of us.
9. Links to Other Sites
10. Children’s Online Privacy Protection
The Website and Products are not intended for use by children under 13 years of age, and are not intended for use by children over the age of 13 but under the age of 18 unless verifiable parental or guardian consent has been provided to us. If you are a parent or guardian and you learn that your child is using the Website and/or Products and you don’t want them to, please contact us. We do not knowingly collect or use any personal information from any children under 13 years of age. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make commercially reasonably efforts to delete such personal information from our database.
11. Questions or Comments
If you have any questions or comments or wish to make a complaint about this Policy, please feel free to contact us by delivery in person, by courier or by the mail, to us at 37 Laver Road, Toronto, ON, Canada, M9C 3K4 or by calling us at 416-834-3870. If you contact us about your personal information, we will respond to your request within a reasonable time and at minimal cost or no cost to you in accordance with applicable laws. Depending on the circumstances and applicable laws, we may refuse to process certain access requests (for example, access requests that are unreasonably repetitive or systematic, would be extremely impractical or require disproportionate technical effort).
Effective Date: August 28, 2018