THE INFORMATION WE COLLECT
In providing the Service, we collect, store and use the following Information relating to you:
“Information” is Personal Information and Non-Personal Information;
"Personal Information" is information that alone or when in combination with other information may be used to identify you. Personal Information may include the following:
“Location Data” is information that we collect regarding your location (when you use a location-enabled service), including:
If you have provided us with your Location Data previously and would like us to delete such Location Data, you may be able to do so via the Service. To the extent required by applicable law, we will not process Location Data unless you have consented to such processing via the App.
“Non-Personal Information” is any information that relates to you but from which it is not practicable to directly or indirectly identify you, including Personal Information in aggregated, anonymized or pseudonymized form.
“Shared Information” is information about you or relating to you that is voluntarily shared on the Service, including postings that you make on the Service (including your public profile, status updates, the lists you create and any or all content consisting of text, stickers, sounds, pictures, photos, video and/or any type of information or communications), any postings from others that you re-post and including Location Data and Log Data associated with these postings. Shared Information also includes information about you (including Location Data and Log Data) that others who are using the Service share about you.
If you choose not to provide any or parts of the Personal Information as described above, then we retain the right not to offer parts or the whole of the Service to you.
HOW WE USE YOUR INFORMATION
We may use your Information for any of the following purposes:
As highlighted in the “The Information We Collect” section above, we retain CDRs. It is standard practice in the phone companies industry to retain such records. Our purpose in maintaining a CDR is:
Particular CDRs may also be inspected by us where it is necessary to do so in relation to a customer support and/or law enforcement request. All CDR data is collated in an anonymous fashion. CDRs are kept by us for no longer than required by applicable law.
We shall use your phone number for identification purposes when you install and use the App. Verification of the number supplied by you shall be confirmed via an SMS or Interactive Voice Response sent to your iOS or Android device.
Your address book is stored by us on an active database, which has no backup function. As such, should you choose to delete the whole or any part of your address book, then it shall be entirely removed from our database and servers.
Wispi-to-Wispi voice calls are directly connected between the two or more (for conference calling) users of the Service. If, for any reason, a direct connection cannot be established, then our servers are utilized to connect the call. No part of your call is ever stored when our servers are utilized.
We use Information, including Personal Information, for internal and service-related purposes.
Please note that for the purposes of seeking to provide our users with a better experience, to improve the Service or otherwise where you have consented, Personal Information collected through the Service may, subject to user privacy controls (where available), be used by our other services (including in an aggregated or individualized manner).
For example, Personal Information collected during your use of one of our services may be used to suggest particular content that can be made available to you on another service or be used to try to present more relevant advertising to you in another service. You may also from time to time ask us to migrate or export your Personal Information contained in one of our services to another of our services on the Service, where such migration option is available.
COOKIES, CLEAR GIFS, AND YOUR INTERNET PROTOCOL ADDRESS
Cookies: these are pieces of information that a website transfers to an individual’s hard drive. We only use first party cookies which are reasonably necessary to ensure functionality of the Website and improved user experience. Your web browser should have an option to enable or disable cookies. If you choose to have cookies enabled, you may also choose to be informed and whether to accept when we send you a cookie. However, if you decide not to accept cookies from the Website, this may totally or partially impair the functionality of the whole or parts of the Website.
Clear GIFS: The Website and any communications sent to you by us may also make use of clear GIFs (known also as “Web beacons” and “tracking pixels”) or technology of a similar nature. Clear GIFS are visible (but more commonly, invisible) images that are embedded in websites, emails and other messages and are used by us to keep a record of the number of visits to the Website and to let us know when you have received and opened an email from us. This helps us to assess the performance of our communications to you and consider how successful our marketing strategies are.
Your Internet Protocol Address: or “IP address”, is the number that your Internet Service Provider allocates to you when you go online and/or surf the internet. Your IP address and domain name may be logged by our servers when you visit the Website, so that we are able to easily identify you. It also allows us to improve our management of the Service and identify any problems with the Service.
The operation of Cookies, GIFS and your IP address: We may use our trusted third parties to carry out the operation of the above technologies on our behalf. For the avoidance of doubt, no Personal Information shall be collected during such operation.
SHARING OF YOUR PERSONAL INFORMATION
You consent to the third party use, sharing and transfer of your Personal Information (both inside and outside of your jurisdiction) as described in this section.
We may also share your Personal Information and traffic data with trusted third parties in order to provide you with an optimal service. We ensure that our trusted third parties take all necessary measures to protect your Personal Information and traffic data and comply with the appropriate laws and regulations.
The circumstances under which we may share your Personal Information with trusted third parties are as follows:
Apple’s Push Notification Service may be utilized by us to alert you when you miss a phone call or instant message. Such alerts may contain the phone number and name of the person who called as part of the message that you receive. We send the message to Apple Inc., who delivers the message to your iPhone.
Google’s Push Notification Service may be utilized by us to alert you when you miss a phone call or instant message. Such alerts may contain the phone number and name of the person who called as part of the message that you receive. We send the message to Google Inc., who delivers the message to your Android device.
We reserve the right to send you messages in respect of faults, as well as any other service issues that may arise, and to use email, the App or SMS to alert you in respect of any claims that relate to your use of the App.
The Wispi App enables Shared Information to be shared publicly with all users of the App and not just your contacts. Our social media services in particular are primarily designed to help you share Shared Information with the world via features either provided by us or third parties, so Shared Information can be broadly and instantly transmitted and will remain public for as long as you do not delete it (and even after you delete Shared Information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us). We recommend that you do not share any Personal Information or other information that you prefer to keep private and confidential.
Please consider carefully what you post and communicate through the Service. In some instances, you may control what access the wider public has to your Shared Information via the privacy settings in some of the Service. If you would like to update or amend your Personal Information you may do so by logging into your account and making the appropriate changes. To request removal of your Personal Information from the Service, or to request the removal of an unauthorized account, please contact us at the address above.
COMMUNICATIONS FROM US
Newsletters and other types of communications
When you use the Service, we may use your Personal Information to send you emails, newsletters or push notifications to your device. If you no longer wish to receive these communications, you can do so by following the unsubscribe instructions in the emails we send to you, opting out of notifications at the device level (if available) or contacting us at the address above.
We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend the Service or portion thereof for maintenance). You may not opt-out of these service-related announcements, which are not promotional in nature.
SENSITIVE PERSONAL INFORMATION
In some jurisdictions, certain Personal Information, such as Location Data, or information about your race or ethnic origin, political opinions or religious or other beliefs, physical or mental health, sexual life, criminal convictions or the alleged commission of an offence, trade union membership, is characterized as “sensitive” and is subject to stricter regulation than other Personal Information. Please note that content and information that you input to the Service, such as photographs or information about your social, political, sexual or religious activities, may reveal your sensitive Personal Information to others.
We urge you to consider whether it is appropriate to communicate Personal Information of a sensitive nature in the manner you are proposing to communicate it using the Service.
Please note that we do not use your sensitive Personal Information for the purpose of serving advertising to you.
THIRD PARTY SERVICES
The Service may link you to, social media or other services (including websites) provided by a third party. For example:
Children under the age of 13 are not allowed to use the Service. We do not knowingly collect Personal Information from any children under the age of 13 and the Service are not directed at children under the age of 13. Please contact us at the address above if you believe we have any Personal Information from any children under the age of 13 and we will promptly investigate (and remove) such Personal Information.
TRANSFER, STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION
We operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which your Personal Information is used and stored may not be in your jurisdiction. Access to these servers is restricted to only a limited number of employees.
We use a variety of security technologies and procedures for the purpose of preventing loss, misuse, unauthorized access or disclosure of Information.
In the Service, we will use encryption technology (such as SSL) to protect certain Information (such as Location Data) provided by you to us. Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. Our systems and the communications networks through which you access the Service may be subject to security breaches and failures which are due to circumstances beyond our reasonable control. If you have any questions regarding the security of your Personal Information, please contact us at the address above.
RETENTION OF YOUR PERSONAL INFORMATION
Subject to applicable laws and regulations (including as set out under the “Sharing of your Personal Information” section above), we will only use your Personal Information for so long as is necessary to fulfil the purposes as set out under the “How We Use Your Information” section above.
Subject to applicable laws and regulations, you may have the right to request to receive a copy of and make any corrections to your Personal Information which we hold, and to request that we deactivate and not use any of your Personal Information that is stored by us. You may direct such request to us at the address above, or where we offer this option in the Service, you may also log into your account with us and make the appropriate changes. We will respond to all requests made to us at the address noted above under this “Retention of your Personal Information” section within 40 days.
Should your account be terminated by you or us for any reason, we will (subject to the above paragraph) take steps to ensure that your Personal Information is no longer available through the Service, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination. However, it is important to note that communications made by you using the Service may put your Personal Information in the hands of third parties that we cannot control.