The Privacy Policy

Providing our Service requires collecting and using your personal information. The Data Policy below explains how we collect, use, and share personal information across the Whosthere Products. It also explains the many ways you can control your information, including in the Whosthere Privacy Settings.

Data policy

This policy describes the information we process to support Whosthere Products.

I. What kinds of information do we collect?

To provide the Whosthere Products, we must process personal information about you. The types of information we collect depend on how you use our Products.

Things you and others do and provide.

• Information and content you provide. We collect the content, communications, and other information you provide when you use our Products, including when you sign up for an account, create or share content, and message or communicate with others. This can include information in or about the content you provide (like metadata), such as the location of a photo or the date a file was created. Our systems automatically process content and communications you and others provide to analyse context and what's in them for the purposes described below.

• Data with special protections: You can choose to provide information in your Whosthere profile fields or Life Events about your religious views, political views, who you are "interested in," or your health. This and other information (such as racial or ethnic origin, philosophical beliefs or trade union membership) is subject to special protections under EU law.

• Networks and connections. We collect information about the people, Pages, accounts, hashtags and groups you are connected to and how you interact with them across our Products, such as people you communicate with the most or groups you are part of.
• Your usage. We collect information about how you use our Products, such as the types of content you view or engage with; the features you use; the actions you take; the people or accounts you interact with; and the time, frequency and duration of your activities. We also collect information about how you use features.
• Things others do and information they provide about you. We also receive and analyse content, communications and information that other people provide when they use our Products. This can include information about you, such as when others share or comment on a photo of you, send a message to you, or upload, sync or import your contact information.

Device Information

As described below, we collect information from and about the computers, phones, connected TVs and other web-connected devices you use that integrate with our Products, and we combine this information across different devices you use.

Information we obtain from these devices includes:

• Device attributes: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.
• Device operations: information about operations and behaviours performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).
• Identifiers: unique identifiers, device IDs, and other identifiers, such as from games, apps or accounts you use, and Family Device IDs (or other identifiers unique to Whosthere Products associated with the same device or account).
• Device signals: Bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers.
• Data from device settings: information you allow us to receive through device settings you turn on, such as access to your GPS location, camera or photos.
• Cookie data: data from cookies stored on your device, including cookie IDs and settings.

Cultural Information

Within the user profile page one can activate the RelatorBot on a volunteer basis. The software will give some questionnaires to measure the culture of an individual on 4 different cultural dimensions. This information is accessible only to the users who have activated the RelatorBot.

II. How do we use this information?

We use the information we have (subject to choices you make) as described below and to provide and support the Whosthere Products and related services described in the Whosthere Terms of Use. Here's how:

Provide, personalize and improve our Products.

We use the information we have to deliver our Products, including to personalize features and content (including your News Feed, Whosthere Feed, and ads) and make suggestions for you on and off our Products. To create personalized Products that are unique and relevant to you, we use your connections, preferences, interests and activities based on the data we collect and learn from you and others (including any data with special protections you choose to provide where you have given your explicit consent); how you use and interact with our Products; and the people, places, or things you're connected to and interested in on and off our Products. Information across Whosthere Products and devices: We connect information about your activities on different Whosthere Products and devices to provide a more tailored and consistent experience on all Whosthere Products you use, wherever you use them.

• Location-related information: We use location-related information-such as your current location, the location you have moved to virtually, where you live, the places you like to go, and the businesses and people you're near-to provide, personalize and improve our Products, including ads, for you and others. Location-related information can be based on things like precise device location, IP addresses, and information from your and others' use of Whosthere Products
• Product research and development: We use the information we have to develop, test and improve our Products, including by conducting surveys and research, and testing and troubleshooting new products and features.
• Ads and other sponsored content: We use the information we have about you-including information about your interests, actions and connections-to select and personalize ads, offers and other sponsored content that we show you.

Provide measurement, analytics, and other business services.

We use the information we have (including your activity off our Products, such as the websites you visit and ads you see) to help advertisers and other partners measure the effectiveness and distribution of their ads and services, and understand the types of people who use their services and how people interact with their websites, apps, and services. 

Promote safety, integrity and security.

At best of our capabilities, we use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Products, and promote safety and security on and off of Whosthere Products. However, such service cannot be considered a surrogate or a substitute of law enforcement and Whosthere declines any liabilities and responsibilities from failing in detecting malicious activities

Communicate with you.

We use the information we have to send you marketing communications, communicate with you about our Products, and let you know about our policies and Terms. We also use your information to respond to you when you contact us.

Research and innovate for social good.

We use the information we have (including from research partners we collaborate with) to conduct and support research and innovation on topics of general social welfare, technological advancement, public interest, health and well-being.

III. How is this information shared?

Your information is shared with others in the following ways:

Sharing on Whosthere Products

People and accounts you share and communicate with

All content shared on Whosthere Platform is public is accessible by all other users. When you share and communicate using our Products, all people within the surrounding of the post will be your audience and all those who follow you or follow the particular post. Similarly, when you use Whosthere to communicate with people or businesses, only those people and businesses can see the content you send. Your network can also see actions you have taken on our Products, including engagement with ads and sponsored content.

Public information can be seen by anyone, on or off our Products. This includes your Whosthere username; any information you share on the Whosthere platform; information in your public profile on Whosthere; and content you share on a Whosthere Page. You, other people using Whosthere, and we can provide access to or send public information to anyone on or off our Products, including in other Whosthere Products, in search results, or through tools and APIs. Public information can also be seen, accessed, reshared or downloaded through third-party services such as search engines, APIs, and offline media such as TV, and by apps, websites and other services that integrate with our Products.

Content others share or reshare about you

You should consider who you choose to share with, because people who can see your activity on our Products can choose to share it with others on and off our Products, including people and businesses outside the audience you shared with. For example, when you share a post or send a message to specific friends or accounts, they can download, screenshot, or reshare that content to others across or off our Products, in person or in virtual reality. Also, when you comment on someone else's post or react to their content, your comment or reaction is visible to anyone who can see the other person's content.

People can also use our Products to create and share content about you with the audience they choose. If you are uncomfortable with what others have shared about you on our Products, you can report the content via the specific function built-in within the Whosthere platform.

Apps, websites, and third-party integrations on or using our Products.

When you choose to use third-party apps, websites, or other services that use, or are integrated with, our Products, they can receive information about what you post or share. Also, when you download or use such third-party services, they can access your public profile on Whosthere, and any information that you share with them. Apps and websites you use may receive your list of Whosthere followers if you choose to share it with them.

New owner.

If the ownership or control of all or part of our Products or their assets changes, we may transfer your information to the new owner.

Sharing with Third-Party Partners

We work with third-party partners who help us provide and improve our Products to grow their businesses, which makes it possible to operate our companies and provide free services to people around the world. We don't sell any of your information to anyone, and we never will. We also impose strict restrictions on how our partners can use and disclose the data we provide. Here are the types of third parties we share information with:

Partners who use our analytics services.

We provide aggregated statistics and insights that help people and businesses understand how people are engaging with their posts, listings, Pages, videos and other content on and off the Whosthere Products.

Advertisers.

We provide advertisers with reports about the kinds of people seeing their ads and how their ads are performing, but we don't share information that personally identifies you (information such as your name or email address that by itself can be used to contact you or identifies who you are.

Measurement partners.

We share information about you with companies that aggregate it to provide analytics and measurement reports to our partners.

Vendors and service providers.

We provide information and content to vendors and service providers who support our business, such as by providing technical infrastructure services, analysing how our Products are used, providing customer service, facilitating payments or conducting surveys.

Researchers and academics.

We also provide information and content to research partners and academics to conduct research that advances scholarship and innovation that support our business or mission, and enhances discovery and innovation on topics of general social welfare, technological advancement, public interest, health and well-being.

Law enforcement or legal requests.

We share information with law enforcement or in response to legal requests in the circumstances outlined below.

IV. What is our legal basis for processing data?

We collect, use and share the data that we have in the ways described above:

• as necessary to fulfil our Whosthere Terms of Use;
• consistent with your consent, which you may revoke at any time by deactivating your account;
• as necessary to comply with our legal obligations;
• to protect your vital interests, or those of others;
• as necessary in the public interest; and
• as necessary for our (or others') legitimate interests, including our interests in providing an innovative, personalized, safe, and profitable service to our users and partners, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.
• As necessary to fulfil our mission

V. How can you exercise your rights provided under the GDPR?

Under the General Data Protection Regulation, you have the right to access, rectify, port and erase your data (by erasing your account). You also have the right to object to and restrict certain processing of your data. This includes:

• the right to object to our processing of your data for direct marketing, which you can exercise by using the "unsubscribe" link in such marketing communications; and
• the right to object to our processing of your data where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. You can exercise this right on Whosthere.

VI. Data retention, account deactivation and deletion

We store data until it is no longer necessary to provide our Service and Whosthere Products, or until your account is deleted - whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. If you submit a copy of your government-issued ID for account verification purposes, we delete that copy 30 days after review, unless otherwise stated.

When you delete your account, we delete things you have posted, such as your photos and status updates, and you won't be able to recover that information later. Information that others have shared about you isn't part of your account and won't be deleted. Cultural Information will be retained 100% anonymised and used for academic research purposes (to support the advancement of our mission). If you don't want to delete your account but want to temporarily stop using the Products, you can deactivate your account instead. To delete or deactivate your account at any time, please visit the Whosthere Settings.

Profiles undergoing law enforcement scrutiny or connected to any police investigation will not be deleted until the appropriate Authorities have given permission as well.  

VII. How do we respond to legal requests or prevent harm?

We access, preserve and share your information with regulators, law enforcement or others:

• In response to a legal request, if we have a good-faith belief that the law requires us to do so. We can also respond to legal requests when we have a good-faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.
• When we have a good-faith belief it is necessary to: detect, prevent and address fraud, unauthorized use of the Products, violations of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, properties or Products), you or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse and other harmful activity on and off our Products.

Information we receive about you can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations of possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from accounts disabled for terms violations for at least a year to prevent repeat abuse or other term violations.

VIII. How do we operate and transfer data as part of our global services?

We share information globally, both internally and externally with our partners and with those you connect and share with around the world in accordance with this policy. Information controlled by Whosthere will be transferred or transmitted to, or stored and processed inside or outside the country where you live for the purposes as described in this policy. These data transfers are necessary to provide the services set forth in the Whosthere Terms of Use and to globally operate and provide our Products to you. We utilize standard contractual clauses approved by the European Commission and rely on the European Commission's adequacy decisions about certain countries, as applicable, for data transfers from the EEA to other countries.

IX. How will we notify you of changes to this policy?

We'll notify you before we make changes to this policy and give you the opportunity to review the revised policy before you choose to continue using our Products.

X. How to contact Whosthere with questions

You can learn more about how privacy works on Whosthere Data Policy. If you have questions about this policy, you can contact us as described below.

The data controller responsible for your information is Whosthere APP VOF which you can contact online, or by mail at:        

Whosthere App VOF
Industrieweg 26F

2254AE
Voorschoten
The Netherlands