Privacy Policy

 

This Privacy Policy describes what personal information we collect, how we use this information, how this information may be shared, and what choices and rights you have with respect to this information. Access and use of our Platform is subject to this Privacy Policy.

Our Platform is made up of the “What I Wore” mobile application, whittleapps.com, and other sites and apps on which this Privacy Policy is posted and that are operated by us, and all of the related websites, mobile apps, products, services, and communications offered by us, including our plug-ins and embedded content made available on other sites (“the “Platform”).

The terms “we,” “us,” or “our” refer to Whittle, LLC. By “you,” we are referring to visitors and users of any part of our Platform.

This Privacy Policy is effective as of February 7, 2020.

1. Collection of Information
We may collect information that you provide us, from third parties, and automatically when you use our Platform. We collect information associated with your device using cookies and similar technologies. We may also receive information about your location.

Information You Provide Us
We may collect information that you provide us, including your account and profile information, content you submit or post to our Platform, your purchase information, your communications, and information you provide to us as part of surveys and contests.

Account and Profile Information
When you create an account on our Platform, we collect information you provide us, like your name, email address, interests, gender, age, and profile information. If you are a professional, you may also choose to provide us information related to your business.

Content you Submit
We may collect information and content that you submit or post to our Platform, including your photos, comments, reviews, searches, photo notes, and discussions.

Purchases
If you purchase or sell products or services within our Platform, we may collect certain information in order to process your purchases and sales, such as your phone number, address, and payment method (for example, credit card or bank account information).

Communications
When you communicate with us (via email, phone, through our Platform, or otherwise) and when you use our Platform to communicate with others, we may store a copy of your communications (including call recordings, subject to providing you notice or obtaining your consent in accordance with applicable law). Certain professionals and sellers on our Platform may choose to use our call tracking feature in order to better manage their business. You are using our Platform when you make calls to these professionals and sellers using their phone number displayed on our Platform. We will provide you notice or obtain your consent in accordance with applicable law before recording these calls. Otherwise, to the extent you communicate with professionals, sellers, and other users outside our Platform, those communications are not subject to this Privacy Policy.

Surveys and Contests
If you participate in our surveys, contests, or promotions, we will collect the information you provide to us.

Information from Others
We collect information that others provide us, including information from other platforms, publicly available information, information from other users of our Platform, information from our partners and corporate affiliates, and information from third-party sites.

Other Platforms
We may receive information about you from third-party platforms that obtain your permission to share this information with us. If you choose to sign-up for our Platform through Facebook or Google or upload your contacts from your third-party email service, you will be asked to share certain information with us as identified by those third-party platforms.  We may use Google Analytics’ services, including to track website traffic and to better understand our users. You can learn how Google Analytics collects and processes data by visiting the following site: www.google.com/policies/privacy/partners/.

Publicly Available Information
Others may post content on our Platform that includes information about you (for example, as part of photos or stories). If you are a professional or seller, we may also collect information about you from publicly available sources and make it available as part of our Platform. For example, we may receive your name and contact information from industry associations and dealer networks in which you participate and display your affiliation with these organizations.

Other Users
In order to enhance the quality of our Platform, professionals and sellers on our Platform may provide us information about your engagement with them, including whether you have contacted them or responded to them, whether your project has been completed, and whether you have received a product you have ordered. If you are a professional or seller, Platform users and visitors may provide us with feedback and public reviews about you.

Our Partners
We may receive information about you from our partners. For example, our payment processors may update your payment information, advertising partners may help us send communications to your address, and third parties may help us prevent fraud by verifying your contact information.  Subject to the privacy policies of our corporate affiliates and in accordance with applicable laws, we may receive information about you from them.

Third-Party Sites
Certain third-party sites may embed a plug-in, widget, or content, including through branded buttons, badges, and slideshows and co-branded content partnerships. You may also choose to use our browser extensions. These plug-ins, widgets, and embedded content provide information to us pursuant to this Privacy Policy. We may collect the information described in this Privacy Policy on those sites.

Automatically Collected Information
We may collect information about your use of our Platform, including your search activity, the pages you view, the date and time of your visit, and if you use our browser extensions, content you interact with on third-party sites. We also collect information that your device provides to us in connection with your use of our Platform, such as your browser type, type of device, browser language, IP address, mobile carrier, unique device identifier, location, and requested and referring URLs.

Cookies and Similar Technologies
We use cookies in connection with your use of our Platform to collect information related to what you see and interact with on our Platform and other Platform access and use. Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop. Options you select are browser and device specific.

Location Information
We will receive your device's location if you enable this through your browser or mobile device. We may infer your general location from your IP address. You may also choose to provide us your location information by inputting this information in our Platform, including in your settings, or when you checkout as a shipping or billing address.

2. Use of Information
We use the information we collect to provide, support, and personalize our Platform and to communicate with you about our Platform (on and off our Platform). The ways we do this include the following:

  • to provide and improve our Platform's functionality, including to display content you post publicly; to fulfill your purchases through our Platform; to process, store, and deliver your communications; to provide customer service and support; to respond to your inquiries or requests; to back-up our systems; and to improve the security of our Platform;

  • to evaluate use of our Platform for our business purposes and to improve and develop our products and services, including new products and services and our Platform's functionality;

  • to personalize your experience, such as to tailor the content and information made available to you and our support services;

  • to display relevant advertising (on our Platform and third-party sites) and to evaluate the success of our advertising;

  • to provide feedback to professionals and sellers on our Platform;

  • to communicate with you as described in our agreements with you (for example, the Terms of Use) and this Privacy Policy;

  • to prevent fraud and to maintain a quality experience for our business purposes or legal reasons, including to filter for spam and communications that violate our agreements with you (for example, the Terms of Use);

  • to enforce compliance with our agreements with you (for example, the Terms of Use) and applicable law; to comply with our legal obligations; to prosecute or defend a lawsuit, arbitration, or similar legal proceeding; to respond to lawful requests by public authorities (including national security or law enforcement requirements);

  • to perform research and analysis for our business purposes; and

  • if you decide to participate, to administer surveys, contests, and promotions.

If you provide us information about your contacts (for example, when you sign up for our Platform through Facebook), in order to facilitate a more connected experience, we may inform your contacts who have accounts on our Platform that you also have joined our Platform and follow them on your behalf so that you may view their public activities on our Platform.

We may use your communications generally for quality assurance purposes and training and to improve our products and services. We may use your communications to understand and help manage the quality of requests received and responses sent by professionals and sellers on our Platform and to provide them feedback. We may use automated technology to review your communications and improve user experience. Learn more.

We may use your log-in information, cookie information, device information and IP addresses to identify you and log your use across devices and our Platform. We may use your addresses to personalize your experience on our Platform.

For your convenience, we may store information about the payment method you use in connection with the Platform. You may remove or change your payment method through your settings.

If you make purchases on the Platform as a visitor and subsequently create an account, for your reference, we will make information available to you about any prior purchases completed using the email address for your account.

Any use of your information that is incompatible with these uses will be disclosed to you in advance so that you may opt out of such uses at your discretion.

3. Sharing Your Information
We do not rent or sell your personal contact information (such as your email address associated with your account registration) to third parties to use for their own marketing purposes. We may share information in the following ways:

Platform Visitors and Users
Through the Platform, others may find, contact, view, and follow your profile and public activity on the Platform (for example, if you "like" content on our Platform), including through your username. You can customize your profile and whether users may follow you through your settings. Unless you make them private using the settings and other tools, your content (for example, photos, notes on others' photos, projects, discussions, and social media profiles), followers, and others you follow are viewable and open to comments by others. Learn how to make these private. We cannot control Platform visitors' and users' use of any information or content you choose to make available publicly.

Service Providers and Platform Partners
We may share your information with others as reasonably needed for our uses described in this Privacy Policy, and we ask them to limit their use of that information. You can find more information about our service providers and platform partners here. In addition, if you specifically agree to share your information with a third-party partner, for example, as part of a contest or promotion we sponsor with such third party, we will share your contact information with that third-party partner.

Advertisers and Ad Networks
We use advertising networks and similar companies to serve advertisements on third-party sites and to assist us in evaluating the effectiveness of our advertising. We may work with advertising partners to serve ads on our Platform. We may use advertising partners to communicate with you at the addresses they have for you. These types of companies use cookies and similar technologies. We may provide advertising networks, advertising partners, and businesses advertising on our platform with aggregate information but other than hashed information or device identifiers, we do not disclose your name, contact information, or other personal information. For more information, please see our Cookie Policy.

Businesses advertising on our Platform may also use cookies or similar technologies to track your activities on our Platform. You can access any settings offered by your mobile operating system to limit ad tracking.

Corporate Affiliates and Business Transfers
We may share information from or about you with (a) joint ventures or other affiliate companies, or (b) a potential or actual acquirer, successor, or assignee as part of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in bankruptcy or similar proceedings). In these cases, their use will be subject to this Privacy Policy.

Investigations
We may investigate and disclose information from or about you, as permitted by applicable law, if we believe that such investigation or disclosure is (a) reasonably necessary to comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process served on us; (b) helpful to prevent, investigate, or identify possible wrongdoing in connection with our Platform; (c) helpful to protect our rights, reputation, property, or that of our visitors, users, corporate affiliates, or the public; or (d) to enforce compliance with our agreements with you (for example, the Terms of Use).

4. Third Party Plug-ins, Widgets, and Links
Our Platform may include third-party social media features and other third-party plug-ins and widgets. When these features are displayed on our Platform, they are operated or hosted by third parties and are subject to their own privacy policies instead of this Privacy Policy. Our Platform also contains links to third-party sites that are not controlled or operated by us. Please be aware that we are not responsible for the privacy practices of such other sites.

5. Communication
An essential part of our services that you sign up for when you create an account on our Platform is to receive communications from us through email and our Platform. If you use our mobile app or provide us with your cell phone number, these communications also include text messages and push notifications. We communicate with you about your account, privacy, and interactions with your content (for example, if others respond to your comment, or if you earn a badge on our Platform). We also ask for your feedback about your experience in connection with our Platform or about your home renovation and design plans. In accordance with applicable law, we communicate to you tips, offers, and similar services from us and may feature professionals, sellers, and other businesses on our Platform in these communications. You may change your communication preferences at any time through your settings, and you may also opt-out of similar types of marketing emails from us directly through the email. Please be aware that you cannot opt-out of receiving account and privacy-related messages from us.

Our Platform also allows you and others to send messages in our Platform, share content with others outside our Platform, and if you make your contact information available, for others to contact you outside our Platform.

6. Account Termination and Data Retention
You can deactivate your account at any time by going to your settings. When you deactivate your account, you will cease to provide ongoing or future data to us. Your profile will no longer be viewable but in accordance with applicable law and the Terms of Use, your photos, reviews, and other content may still be accessible and viewable. In order to request permanent deletion of your account, please contact us as described in the Contact Us section.

We will keep your personal information only for as long as necessary to fulfill the purposes for which we are processing your personal information unless the law permits or requires us to retain your personal information for a longer period. For example, we may need to keep your personal data for quality assurance for our Platform or to defend future legal claims. We also will retain de-identified information after your account has been deleted. Information you have shared with others will remain visible after your account has been deactivated or deleted and after the information has been deleted from your own profile or account. We do not control information or content that others have copied out of our Platform. Please note that copies of information that you have updated, modified, or deleted may continue to reside in our systems for a period of time, and we may maintain copies of this information as part of our business records.

7. Children
Our Platform is intended for general audiences and is not directed to children under 13. We do not knowingly collect personal information from children under 13. In the event that we learn that we have collected personal information from a child under age 13, we will take appropriate steps to delete that information. If you become aware or believe that a child has provided us with personal information, please contact us as provided in the Contact Us section.

8. Data Security
We use reasonable and appropriate measures to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information.

9. Updates to this Privacy Policy
We may revise this Privacy Policy from time to time. The most current version of our Privacy Policy will govern our use of information about you. If we make material changes to our Privacy Policy, we will notify you by email or by posting a notice on our Platform. By continuing to access or use our Platform after those changes become effective, you are subject to the revised Privacy Policy.

10. Contact Us
If you have questions or comments about this Privacy Policy, please email us at contact@whittleapps.com.

11. International Transfers of Personal Information
In order to provide you with the services you sign up for by creating an account or visiting our Platform, your personal information may be transferred to and processed in the United States (or any other country where we, our corporate affiliates, agents, and service providers operate). Data protection laws differ among jurisdictions, and the United States and these other jurisdictions may not provide the same level of protection for personal information as your jurisdiction of residence. If you are from the European Economic Area ("EEA") and we transfer your personal information to countries outside of the EEA, we will take appropriate steps to ensure your personal information is afforded the same level of protection as described in this Privacy Policy.

12. Legal Basis for Processing Personal Information (European Economic Area)
If you are from the EEA, our legal basis for collecting and using the personal information described in this Privacy Policy will depend on the personal information concerned and the specific context in which we collect it. We collect and use your information for a variety of business purposes that are in our legitimate interests, in order to enter into or perform a contract with you, with your consent, or to comply with our legal obligations.

If you wish to learn more about specific legal grounds we rely on to process your information for any particular purpose (including any legitimate interests we have to process this information), please contact us as provided under the Contact Us section. For example, we rely on our legitimate interests to process information for direct marketing purposes and for fraud prevention and detection, provided these interests are not overridden by your data protection interests or fundamental rights and freedoms.

13. Your Data Protection Rights (European Economic Area)
In some regions, such as the EEA, you may have certain rights in relation to your personal information, including the right to access, correct, update, or request deletion of your personal information. We take reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You also can manage your profile and settings within our Platform. However, if you are not a user of our Platform and you want to contact us directly about accessing, correcting, updating, or deleting your personal information, or altering your data or marketing preferences, you can do so at any time by contacting as provided in the Contact Us section. We will consider your request in accordance with applicable laws.

You can object to processing of your personal information, ask us to restrict processing of your personal information, or request portability of your personal information. Again, you can exercise these rights by contacting us as provided in the Contact Us section. You also can deactivate your profile through the settings in the “What I Wore” app and can obtain a copy of your information by emailing us at contact@whittleapps.com.

You can complain to a data protection authority about our collection and use of your personal information in relation to the General Data Protection Regulation (GDPR). For more information, and to submit a GDPR complaint, please contact your local data protection authority. Contact details for data protection authorities in the EEA and Switzerland are available here.

Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

This Privacy Policy was last updated on February 7, 2020.