Wispi Global Privacy Policy

INTRODUCTION

SG Atlantic Limited (“we”, “us” “our” and other comparable pronouns) considers that your privacy is of prime importance. This Privacy Policy details how we use Information (as defined in the “The Information We Collect” section below) that we receive and collect from you in relation to our website located at [www.wispiapp.com] (the “Website”), the Wispi mobile application (the “App”) (collectively, the “Service”) and any updates or upgrades to the Service that are made available from time to time.
By using the Service, you agree that we may collect, use and share your Information in accordance with this Privacy Policy, as revised from time to time.
If you wish to contact us regarding this Privacy Policy or any privacy-related matters, please contact us via postal mail at AIA Central, 1 Connaught Rd Central, Central, Hong Kong or email us at .

SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies comprehensively across the Service.
This Privacy Policy is incorporated into and forms part of the Wispi End User License Agreement and Terms of Service (the “Terms of Service”) [http://wispiapp.com/terms.html] that you have agreed to in order to use the Service. Any terms used in this Privacy Policy will have the same meaning as the equivalent defined terms in the Terms of Service, unless otherwise defined in this Privacy Policy or the context requires otherwise.
Please also note that this Privacy Policy does not apply to Information collected: (i) through third party services (including any third party websites) that you may access through the Service; or (ii) by other companies and organizations that use the Service to advertise their services.

CHANGES TO THIS PRIVACY POLICY

We may from time to time revise or add specific instructions, policies and terms to this Privacy Policy. These instructions, policies and terms form part of this Privacy Policy.
Where we consider that any changes to this Privacy Policy are reasonably material, we will notify you (via the Website, direct communication to you, or other means) prior to the change becoming effective.

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.
"Log Data" is technical information that is automatically collected by us when you use the Service, whether through the use of cookies, web beacons and log files (as explained in more detail in the “Cookies, Clear GIFs, and your Internet Protocol Address” section below) or otherwise, including:

 “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

We and our affiliate companies may share your Personal Information within our group of companies and with joint venture partners and third party service providers, contractors and agents (such as communication service providers who send emails or push notifications on our behalf, and mapping services providers which assist us and you with Location Data), in each case, for the purposes of: (i) providing the Service to you; (ii) assisting us in carrying out the purposes set out under the “How We Use Your Information” section above; (iii) carrying out our obligations and enforcing our rights under the Terms of Service or this Privacy Policy; (iv) in order to preserve and protect our equipment used to provide the Service and our rights (whether intellectual property or rights under an agreement); (v) where the personal safety of our users or members of the public is at risk; and/or (vi) help understand and improve the Service. These third parties may be located, and use and store your Personal Information, outside of your jurisdiction for these purposes.
Where we or our affiliate companies do share your Personal Information with any third parties, we will use reasonable efforts to ensure that such third parties only use your Personal Information: (i) in compliance with this Privacy Policy; and (ii) subject to any other instructions we give them, including any appropriate confidentiality and security measures that we implement.
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.
As we continue to develop our business, we or our affiliate companies may be acquired by a third party or re-organize our group structure. In these circumstances, it may be the case that your Information is transferred within our group and/or transferred to a third party who will continue to operate the Service or similar services under either this Privacy Policy or a different privacy policy which will be notified to you. The party to which your Personal Information is transferred may be located, and use your Information, outside of your jurisdiction. We shall ensure that the security of your Personal Information is no less than as set out under the terms of this Privacy Policy after such a transaction. No such transactions shall take place if we are in any doubt as to the security of your Personal Information. Once such a transaction has been confirmed we shall alert you in respect of the same by posting a notice on the Website.
You agree that we or our affiliate companies may be required to retain, preserve or disclose your Personal Information: (i) in order to comply with applicable laws or regulations; (ii) in order to comply with a court order, subpoena or other legal process; (iii) in response to a request by a government authority, law enforcement agency or similar body (whether situated in your jurisdiction or elsewhere); or (iv) where we believe it is reasonably necessary to comply with applicable laws or regulations. You also agree that we or our affiliate companies may need to disclose your Personal Information in order to enforce the Terms of Service or this Privacy Policy, protect our rights, property or safety, or the rights, property or safety of our affiliate companies or other users of the Service.
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.

SHARED INFORMATION

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.
Service-related announcements
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.
You consent to all processing of sensitive Personal Information for the purposes and in the manner described in this Privacy Policy.
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:

These third party social media or other services may be hosted by the relevant third party or us. Your use of any such third party services (whether social media services or otherwise), including any Personal Information you provide to such third parties, are subject to the relevant third party’s own terms of services and privacy policies and not the Terms of Service or this Privacy Policy, so please review their terms carefully. This Privacy Policy only applies to any Information collected by us, does not apply to any services offered by or information practices of any third parties, and we bear no liability for any third party use of any Information provided by you to them.

AGE RESTRICTIONS

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 may transfer Personal Information to countries which may not have the same data protection laws as the country in which you initially provided the Personal Information. When transferring your Personal Information internationally, we will comply with applicable legal requirements and protect your Personal Information as provided in this Privacy Policy.
You consent to the transfer of your Personal Information (both inside and outside of your jurisdiction) for the purposes described in this Privacy Policy.
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.