Date of last revision: 9 January 2020
For purposes of this Policy, Personal Data refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time, but excludes business contact information.
By interacting with us, submitting information (including Personal Data) to us, or engaging, accepting or using our services, you agree and consent to Whissh, the service providers and their respective directors, officers, employees, sub-contractors, agents, or other third parties appointed by us or on your behalf collecting, using, retaining and disclosing your Personal Data in the manner and for the purposes as set out below.
In your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use, retain or disclose your Personal Data.
What data do we collect?
When you interact with us, we collect Personal Data including your name, address, phone number, credit card details, and e-mail address, to process your orders. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.
Otherwise, you may choose to provide us with additional personal information to obtain a better user experience when using our Site and services. This additional information, which includes optional profile information and information during participation in promotions and experience sharing, will be processed based on our legitimate interest or when applicable, your consent.
In addition to this, when you visit our Site, we may collect other certain information, such as your geographic data and account password, search preferences related to specific searches, and information about your web browser, IP address, time zone, and some of the cookies that are installed on your device, and information about your computer’s operating system, application version, language settings and pages that have been shown to you. If you are using a mobile device, we might also collect data that identifies your mobile device, device-specific settings and characteristics and latitude/longitude details. This information is necessary for our legitimate interest in being able to provide and improve the functionalities of our Site and services.
When you make a purchase or attempt to make a purchase with us, we process your billing information via third-party payment processors who have their own privacy policies. They collect certain information from you, including your name, billing address, payment information including credit card numbers, email address, and phone number, and we do not take responsibility for their personal data handling practices. To manage booking requests, we may store the last 4 digits of your debit/credit card and bank account details securely. For security reasons, those details cannot be edited but they can be deleted.
How do we collect your data?
We will only be able to collect your Personal Data if you voluntarily submit the information to us. Generally, we may collect Personal Data in various ways such as:
• In the course of your engaging, accepting or using our services, or your providing documentation or information to us;
• When you communicate or interact with us via telephone, letters, fax, face-to-face meetings, our website, email or other modes of contact. Telephone calls may be recorded;
• CCTV recordings while you are within our premises;
• When you attend any event organised by us;
• Photographs or videos taken by us or our representatives when you attend events hosted by us; or
• From public information sources, search services and other third parties.
We may collect information including Personal Data that others provide about you when they use our Site and services (e.g. referrers and enterprise package providers) or obtain information from other sources and combine that with information we collect through our Site and services. If you are seeking internship, training positions, employment or any other appointment with us, we may collect, use and disclose your Personal Data for processing and assessing your application and performing background checks. We do not control, supervise or respond for how the third parties providing your information process your Personal Data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
If you provide any Personal Data relating to a third party (including your family members or (if you are a corporate entity) your directors, shareholders, members, beneficial owners and the like) to us, you represent to us and must ensure that you have notified such third party of the terms of this clause and obtained his or her consent to the same.
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser, due to lack of standardization regarding how that signal should be interpreted.
Our Site and services are not directed to children under 16 and we do not knowingly collect any Personal Data directly from children under 16. If you believe that we processing Personal Data pertaining to a child inappropriately, we take this very seriously and urge you to contact us using the information provided under the “Contact us” section below.
How will we use your data?
Generally, we may use and retain Personal Data for a variety of reasons, such as:
• Providing our services;
• Responding to, processing and handling your queries, feedback and suggestions;
• Verifying your identity, processing payments as well as managing our accounts, administrative and business operations;
• Managing the security of our premises, facilities, website, and IT and technology infrastructure;
• Maintaining our customer database, including for future marketing and promotional purposes;
• Complying with applicable laws and regulations, codes of practice or guidelines, policies, procedures, regulatory requirements (which may extend to know-your-client and related reviews) and directions issued by relevant authorities;
• The establishment, exercise or defence of any legal or equitable claim; and
• Any other purpose which is ancillary or incidental or relating to any of the above.
Further, we may disclose or transfer your Personal Data to third parties in the following manner:
• To our sub-contractors, agents, or third-party service providers who provide services to our customers;
• To our sub-contractors, agents, or third-party service providers who provide accounts, operational or administrative services;
• To our legal, tax, accounting and other professional advisers;
• To any relevant authorities, whether local or overseas; or
• To the extent necessary to comply with any laws, regulations, rules, directions, and guidelines.
Where you have engaged us to carry out any work in any jurisdictions outside the United Kingdom, the transfer of your personal data records to these jurisdictions may be necessary to give effect to your instructions and that you consent to such transmission of your Personal Data, which would be exported to, processed and accessed in countries whose laws provide a different level of protection and which may not be comparable to that provided in the United Kingdom.
How do we store your data?
To prevent unauthorized access, we maintain reasonable physical, electronic and organizational procedures to protect Personal Data against accidental or unlawful destruction or accidental loss, alteration, or unauthorized disclosure or access.
Where permissible according to applicable law we may use certain limited Personal Data about you for marketing activities. Based on the information you share with us, individualized offers may be shown to you on the Site, via email, in mobile apps or on third-party websites, including social media sites. These might be offers that you can book directly on the Site or third-party offers or products we think you might find interesting. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be in your interest.
With your consent, we may also send you regular newsletters by email. You can opt out, or unsubscribe, from marketing communications at any time in each newsletter or communication by contacting us using the information provided under the “Contact us” section below.
On the payment of a small fee, you have the right (subject to certain exceptions) to be provided with a copy of the Personal Data we hold about you and an explanation of how we use it. In certain circumstances you may also require us to alter or remove any Personal Data we may hold about you. Otherwise, you have the right to request that we restrict or stop the processing of your Personal Data, or transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you would like to withdraw your consent to any use of your Personal Data as set out in this Policy or provided otherwise, obtain access or make corrections to your Personal Data records, or exercise any other of your rights relating to personal data privacy, please contact our Data Protection Officer, as follows:
Phone: +44 (0)20 8168 9818
Address: 9 Fishers Lane, London W4 1RX, United Kingdom
To protect your privacy and security, we will verify your identity before granting access or making changes to your Personal Data. Any request to access your Personal Data will be answered within a reasonable timeframe.
Please note that if you withdraw your consent to any or all use of your Personal Data, we may be limited in our ability to, or not be able to continue to, provide our services to you.
A cookie is a small data file that is transferred to your device (e.g. your phone or your computer) to uniquely identify your browser or to store information or settings in your browser. Session cookies disappear from your computer when you close the browser. Persistent cookies remain on your computer after the browser has been closed but can be deleted at any time through your browser settings.
Other technologies have similar functionality to cookies, such as web beacons, pixels, mobile identifiers, and tracking URLs, to obtain log data. For example, our email messages may contain web beacons and tracking URLs to determine whether you have opened a certain message or accessed a certain link.
When you use our Site, we may use a combination of cookies or similar technologies as described above to help provide, protect, and improve our Site and service for your user experience, such as:
• To keep you signed in;
• To enable, facilitate and streamline the functioning of and your access to our Site;
• To better understand how you navigate through and interact with our Site and to improve our Site;
• To serve you tailored advertising (such as on our Site, emails and on third-party websites);
• To show you content (e.g. advertisements) that is more relevant to you;
• To monitor and analyze the performance, operation, and effectiveness of our Site and advertisements;
• To enforce legal agreements that govern use of our Site;
• For fraud detection and prevention, trust and safety, and investigations; and
• For purposes of our own customer support, analytics, research, product development, and regulatory compliance.
By visiting our Site, you consent to our usage of cookies and/or similar technologies for the above purposes. These technologies may be from Whissh and/or third parties we work with.
Specifically, we may allow certain business partners to place these technologies on our Site, to help us analyse how you use our Site, such as by noting the third-party services from which you arrived; market and advertise our services to you on our Site, emails, and third-party websites; help us detect or prevent fraud or conduct risk assessments; or collect information about your activities on our Site, other sites, and/or the ads you have clicked on. For example, we work with a number of analytics partners including Google Analytics.
Otherwise, our Site may use social plugins provided and operated by third parties, such as Facebook’s Like Button. As a result of this, you may send to the third party the information that you are viewing on a certain part of our Site. If you are not logged into your account with the third party, then the third party may not know your identity. If you are logged in to your account with the third party, then the third party may be able to link information or actions about your interactions with our Site to your account with them. Please refer to the third party’s privacy policies to learn more about its data practices.
In addition, we may share one-way hashed (undecipherable) data with third parties using advertisement targeting products. Such third-party vendors typically use hashed device identifiers to link such identifiers to their own users and to serve custom ads based on users’ prior visits to the Site. Consequently, third parties may show our and/or our partners’ ads on other websites or mobile apps.
For more information about targeting and advertising cookies and how you can opt out, you can visit the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or http://youronlinechoices.eu.
In many cases you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different so visit the “help” section of your browser when to learn about cookie preferences and other privacy settings that may be available. Please note that if you choose to remove or reject cookies or clear local storage this could affect the features, availability, and functionality of our websites, and you will be required to re-enter your log-in details. Please note that if you clear all cookies on your browser, or use a different browser or computer, you will need to complete the opt-out procedure again.
Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.
Your mobile device may allow you to control cookies through its settings function. Refer to your device manufacturer’s instructions for more information.
In the case of cookies or similar technologies from third parties, Whissh takes reasonable efforts to not collect, and to prevent the use of, personally identifiable information in third-party advertising solutions, unless you have authorised this.
The social media platforms with which we may share your personal information are not controlled or supervised by us. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to such provider.
If you would like more information about the information collection practices of third-party advertising companies and your choices about not having this information used by these companies, or you would like to opt out of online preference marketing, you can use the following tools:
To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser by clicking here.
To the extent advertising technology is integrated into our Site and you opt-out of tailored advertising, you may still receive advertising content. In that case, the advertising content will just not be tailored to your interests. Also, we do not control any of the opt-out links of third parties and are not responsible for the availability or accuracy of these mechanisms.
Privacy policies of third parties
Our Site may contain links to other sites that are operated by third parties with different privacy policies, and we do not take any responsibility for these third-party websites and their personal data handling practices, should you choose to access such sites.