Who App - Privacy Policy

PRIVACY POLICY

Effective date: 01 Jan 2021

Last Updated: 14 January 2024

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.

"Collected Information" means a user's private, personal or personally identifying or identifiable data or information, including Content, Contact information (such as name, email address, or social network identifier), information which may be considered as "personal information" under the California Consumer Privacy Act of 2018 ("CCPA"), and as further defined below.

"Public Resources" means information available through WHO app's partners' data resources, or over publicly available online databases and other public data resources.

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, age,  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 COLLECTED INFORMATION AND HOW WE USE IT

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.:  Your phone number; 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

You may provide us with Your user identifier information regarding, or to enable Your usage of, certain third party services (together with a mapped photo where applicable) e.g. social networking services and payment services, in order for the Services to interoperate with such third party services. You may use such third party services to create Your user profile or log in to our Services, share information with such third party services, or to connect Your user profile with the respective third party services. Such third party services may automatically provide us with access to certain personal information retained by them about You (e.g., your payment handle, unique identification information, content viewed by You, content liked by You and information about the advertisements You have been shown or may have clicked on) and You agree that we may collect, use and retain the information provided by these third party services in accordance with this Privacy Policy. You may be able to control the personal information You allow us to have access to through the privacy settings on the respective third party service. We will never store any passwords created for any third party services.

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. 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.  

 In addition to Contact Information, if You choose to activate use of a third party service, such as social networks services, within the Services, WHO may collect, store and use the list of identifiers associated with said services linked to the Contact Information in order to enhance the results shared with other Users. 

The following points cover the terms of Collected Information such as ("Contacts"):  

1.4.1 -When you register, download, install and access the Service, the following Collected Information will be collected and processed by WHO app :Information regarding Contacts contained in user device phone books (as detailed below) ("Contacts"), name, phone number, email, connection information, usage statistics, event information, version of the Software used (the "Essential Information").  

We collect and process the Essential Information because it is necessary in order for us to be able to perform our contract with you and provide you with the Service. 

1.4.2-Information regarding Contacts: When you register, download, install, access and use the Service, the following Collected Information regarding the Contacts will be collected and processed by WHO:  

names, phone number, emails and information from Public Resources, associated with the phone number of each Contact, such as, website address. Your Contacts are uploaded to our servers on https://api.whoapp.us to allow you to effortlessly access your saved Contacts, make calls with ease, and identify incoming calls.

You agree that you will exercise caution and common sense if you provide us with or let us collect or receive information, including Collected Information, about someone else e.g. someone who calls you. Please inform your Contacts and any such other person, that their information may be collected and shared with WHO and direct them to the terms of this Privacy Policy and our Terms of Service for more information.  

We collect and process the Collected Information about others (including Contacts) because it is necessary for our legitimate interests in conducting, developing and improving our business and meeting the needs of and improving the relationships with our current and prospective users. 

1.4.3- Information uploaded by you: You may upload and share information, including Collected Information, into the Service as content ("Content"). Content may take the form of your profile information or Contact information. All Content is available to us and to other users.  

We collect and process the Content because it is necessary for our legitimate interests in conducting, developing and improving our business and meeting the needs of and improving the relationships with our current and prospective users. 

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 or following a manual number search against the WHO database; display the number associated with a certain name following a manual name search against the WHO database, subject to that name searches will only produce a number linked to the name if the number is available for search in a public database or relates to a User who has made his or her name available for search.

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 as we may require you to verify your account by sending an SMS message to a designated phone number. 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; or

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.

Your phone number information is uploaded to our servers on https://api.whoapp.us to create and verify your profile.

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 at www.whoapp.us 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 whoapppeoplesearch@gmail.com

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

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. In addition, in case You are one of our users, we may also process the following personal data relating to You : *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 25 W Highland Dr Apt 23 Seattle, Washington 98119

You can also send Your enquiries via email to whoapppeoplesearch@gmail.com