PRIVACY POLICY

 

BACKGROUND TO THIS PRIVACY POLICY

RouteWhisperer PL (we/us) takes the issue of the privacy of your Personal Data seriously.

Personal data means any information relating to an identified or identifiable natural person (‘Data Subject’) and an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

This privacy policy applies to your permitted access to this website and/or the use of the RouteWhisperer App as regards to any Personal Data that may be collected from you or provided by you during such access or as a result of your access to our website or as a result of your using the RouteWhisperer App.

This privacy policy has been published to provide to you a clear and concise outline of how and when Personal Data is collected, stored and/or used by us.

IF YOU USE ANY SERVICE PROVIDED BY US OR YOU PROVIDE VOLUNTARILY ANY PERSONAL DATA TO US THEN YOU SPECIFICALLY REPRESENT TO US THAT YOU HAVE READ, UNDERSTOOD AND CONSENTED TO THE COLLECTION, USE AND STORAGE OF YOUR PERSONAL DATA.

From time to time, we may change the provisions of this Privacy Policy without specific notice to you.  We strongly recommend that you check this document on a regular basis to ensure that you understand the obligations detailed in this Privacy Policy.  This Privacy Policy will be accessible by you either through our website or through the RouteWhisperer App.

 

PERSONAL INFORMATION YOU PROVIDE US

We do not generally collect Personal Data about you except when you provide that information voluntarily and in accordance with our various application forms that are available on this web site or through the RouteWhisperer App.  Once you have provided Personal Data it will only be used for purposes of registration so that we can forward to you the information that you have requested via the RouteWhisperer App.  In other words, all collected Personal Data about you will be used solely for the purpose to which you have consented.  Such information will not be transferred to other parties unless you are fully informed prior to such transference and you have agreed to such transference, unless we are required by law to transfer the information to an authorised organisation.

The above only relates to your Personal Data and does not relate to any aggregated or other information that may be developed or created internally by us, provided this other information cannot later be used or combined with other information to identify you in any way whatsoever and therefore maintains our privacy commitment to you.

The information we may collect which we collectively call Personal data is:

 

  • Basic user information, such as your name, username, gender, birth date, email address, place user lives;
  • Messages and interactive post information from the RouteWhisperer App feed, such as messages to other users and information you provide in connection with those activities and events;
  • Other background, contact and demographic information, such other interests and self-descriptions you choose to provide;
  • RouteWhisperer has a legitimate reason to add your email address to RouteWhisperer’s email marketing database at the time of account creation in RouteWhisperer so that RouteWhisperer can send you the Welcome Email which has instructions & tips for using the app for the first time. However as a subscriber you have always had and always will have the opportunity to unsubscribe at any time from the unsubscribe link at the bottom of all our emails. You are also able to update your email marketing preferences from that same footer link of all our emails now too.

INFORMATION WE MAY COLLECT AUTOMATICALLY

When you access or use our Services, we may also automatically collect information about you, including:

 

  • Usage Information. We collect information about your activity through our services. For example, we may collect information about:
    • how you interact with our services, such as which posts you like, destination map that is downloaded.
  • Content Information. We collect content you create on our services, such as posts, etc. and information about the content you create or provide, such as if recipients have viewed the content. We also collect the metadata that is associated with the content.
  • Camera and Photos. Many of our services require us to collect images and other information from your device’s camera and photos. For example, you won’t be able to post on the feed or upload photos from your camera roll unless we can access your camera or photos.
  • Location Information: We may collect information about your location when you access our mobile application or website, or otherwise consent to the collection of this information. With your permission, we may also collect information about your precise location.
  • Device Information: We may collect device-specific information when you access our Services, including your hardware model, operating system and version, unique device identifiers, mobile network information and information about the device’s interaction with our Services, browser type, language and time zone.
  • Log Information: We may collect log information about how you access or use our Services, including your access times, browser type and language, Internet Service Provider and Internet Protocol (“IP”) address.

 

USE & DISCLOSURE OF PERSONAL DATA

Unless you have advised us not to do so, your Personal Data may be shared:

 

WITH OTHER ROUTEWHISPERER USERS.

We may share the following information with other RouteWhisperer users:

 

  • information about you, such as your username or name, and place you live.
  • information about how you have interacted with our services, contents user saved
  • any additional information you have directed us to share.
  • content you post or send. How widely your content is shared

 

WITH ALL ROUTEWHISPERER USERS OUR BUSINESS PARTNERS, AND THE GENERAL PUBLIC.

We may share the following information with all users as well as with our business partners and the general public:

 

  • public information like your name, username and profile pictures.

 

WITH THIRD PARTIES. We may share your information with the following third parties:

 

  • With third parties for legal reasons. We may share information about you if we reasonably believe that disclosing the information is needed to:
    • comply with any valid legal process, governmental request, or applicable law, rule, or regulation.
    • investigate, remedy, or enforce potential Terms of Service violations.
    • protect the rights, property, and safety of us, our users, or others.
    • detect and resolve any fraud or security concerns.

 

WITH THIRD PARTIES AS PART OF A MERGER OR ACQUISITION.

If RouteWhisperer gets involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your information with that company before and after the transaction closes.

We may also share with third parties—such as advertisers—aggregated, non-personally identifiable, or de-identified information, which cannot reasonably be identified as you.

It is our goal to only use the information you provide us in a manner that better provides our services to you such as:

 

  • develop, operate, improve, deliver, maintain, and protect our products and services.
  • send you communications, including by email. For example, we may use email to respond to support inquiries or to share information about our products, services, and promotional offers that we think may interest you.
  • monitor and analyse trends and usage.
  • personalize our services by, among other things, suggesting friends or profile information, or customizing the content we show you, including ads.
  • contextualize your experience by, among other things, tagging post content using your precise location information (if, of course, you’ve given us permission to collect that information) and applying other labels based on the content.
  • provide and improve ad targeting and measurement, including through the use of your precise location information (again, if you’ve given us permission to collect that information), both on and off our services. See the sections below for more information and your choices.
  • enhance the safety and security of our products and services.
  • verify your identity and reduce the risk of fraud or other unauthorized or illegal activity.
  • use information we’ve collected from cookies and other technology to enhance our services and your experience with them.
  • enforce our Terms of Service and other usage policies.

In addition we undertake not to sell, rent or trade your Personal Data.  We will not disclose information about you unless the disclosure is:

 

(A) REQUIRED BY LAW (THE ESTONIAN TAX OFFICE);

 

(B) IS AUTHORISED BY LAW (TO PROTECT OUR INTERESTS OR WHERE WE HAVE A DUTY TO MAKE SUCH DISCLOSURE); OR

 

(C) YOU HAVE CONSENTED FOR US TO DISCLOSE THE INFORMATION ABOUT YOU.

 

PERSONAL DATA QUALITY

It is our goal to ensure that your Personal Data is correct, accurate, relevant, timely and secure.  For us to meet this goal would you please ensure that if there is any change to any of the details you have provided to us, you will promptly advise us so that we can continue to provide the services that we have agreed.  Further, if it comes to your attention that we possess certain information about you that is not correct, accurate, complete or up-to-date, then contact us and we will use all reasonable efforts to correct the information we have about you.  Such corrections may take time as we will only correct such information once we have verified that the new information is correct.

 

PERSONAL DATA SECURITY

We undertake to use our best endeavours to keep secure your Personal Data and we further undertake to take all reasonable precautions to protect that information against any unauthorised loss, misuse or alteration.

Although we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we do not guarantee or warrant the security of the information you share with us and we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content. No system is 100% secure.

 

ACCESS TO PERSONAL INFORMATION

If you request us to provide you with access to personal information we hold about you, then we will provide such information to you in a timely manner in accordance with GDPR requirements. Please submit your request with the Subject: Access To My Personal RouteWhisperer Information to the following address [email protected]

RIGHT TO BE FORGOTTEN

If you are a resident of a jurisdiction that is a member of the European Union and the GDPR applies to your Personal Data, then:

 

  • you may by email to us advise us that your consent is withdrawn; and
  • we will subject to the requirements of the GDPR and subject to any binding laws upon us to the contrary and subject to validating your request use all reasonable efforts to remove any Personal Data about you within a reasonable time commencing on the date that you advise us that your consent concerning the collection, storage and usage of your Personal Data is withdrawn.

Nothing in this clause requires us to breach any law in Turkey that requires us to keep your Personal Data such as taxation laws.

COOKIES

We use “cookies” to collect information. A cookie is a small data file that most major web sites write to your hard drive for record keeping purposes when you visit them. Cookies allow us to measure activity on the web site and to improve your user experience, for example by remembering your passwords and viewing preferences, thus allowing you to visit various member-only parts of the web site without re-registering. Cookies are used by us to measure activity on the web site and make improvements and updates based on which areas are popular and which are not. We do not use cookies to retrieve information from your computer that was not originally sent in a cookie. Except for personal information voluntarily provided by you (i.e., during membership registration or a contest), we do not use information transferred through cookies for any promotional or marketing purposes, nor is that information shared with any third parties whatsoever.

You may occasionally get cookies from our advertisers, which is standard in the Internet industry. We do not control these cookies, and these cookies are not subject to our privacy policies.

Most browsers are initially set to accept cookies. If you’d prefer, you can set yours to refuse cookies or to alert you when cookies are being sent. However, it is possible that some parts of the web site and the services provided via this website, such as the member-only areas, will not function properly if you do so

You can find more about cookies on our Cookies Policy

 

CHANGES TO THIS POLICY

We reserve the right to make changes to this privacy policy from time to time for any reason.  We will accordingly make those changes and display those changes on this website.  This privacy statement was last amended on 25 May 2018.

 

CONTACT US ABOUT PRIVACY

If you would like to contact us as regards to anything concerning this privacy policy, or if you think that we have breached any aspect of this privacy policy, then please contact us by:

E-mail: [email protected]