Pri­va­cy policy 

Welcome to Whistle

This Pri­va­cy Pol­i­cy is here to help you under­stand how we col­lect, use, dis­close, and process your per­son­al data. We also describe your choic­es and rights with respect to how we process your per­son­al data. Please read this pol­i­cy carefully.

WHO WE ARE
This is the Pri­va­cy Pol­i­cy of Whis­tle Mes­sag­ing, Inc. (“Whis­tle”, “us”, “our”, or “we”), a Cal­i­for­nia com­pa­ny with offices at 31416 Agoura Road #105, West­lake Vil­lage, CA 91361. You can con­tact us.
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APPLICABILITY
This Pri­va­cy Pol­i­cy applies to our “Plat­form”, which include our mes­sag­ing appli­ca­tion and relat­ed ser­vices (the “Plat­form”) and our cor­po­rate web­site at trywhistle.com, and oth­er web­sites that link to/post this Pri­va­cy Pol­i­cy (includ­ing any sub­do­mains or mobile ver­sions the “Site(s)”).
AGREEMENT
This Pol­i­cy is incor­po­rat­ed into the Terms of Use gov­ern­ing your use of any of our Plat­form. Any cap­i­tal­ized terms not defined in this Pri­va­cy Pol­i­cy will have the def­i­n­i­tions pro­vid­ed in our Terms of Use. Fol­low­ing notice to you or your acknowl­edge­ment of this Pri­va­cy Pol­i­cy (includ­ing any updates), your con­tin­ued use of any of our Plat­form indi­cates your con­sent to the prac­tices described in this Policy.
Terms of use
THIRD PARTIES
Whis­tle is a ser­vice provider for hotels and oth­er hos­pi­tal­i­ty clients (our “Clients”). Our Plat­form helps our Clients to com­mu­ni­cate with, sup­port, and pro­vide var­i­ous ser­vices to their guests and staff mem­bers. This Pol­i­cy reflects only how we process per­son­al data through our Plat­form. This Pol­i­cy does not apply to Clients’ own uses of your data. This Pol­i­cy also does not apply to infor­ma­tion processed by oth­er third par­ties, for exam­ple, when you vis­it a third-par­ty web­site or inter­act with third-par­ty ser­vices, unless and until we receive your infor­ma­tion from those par­ties. Please review any third par­ties’ pri­va­cy poli­cies before dis­clos­ing infor­ma­tion to them. See our list of third par­ties for more infor­ma­tion regard­ing our sources and recip­i­ents of per­son­al data.
SECURITY
We fol­low and imple­ment rea­son­able secu­ri­ty mea­sures to safe­guard the Per­son­al Data you pro­vide us. How­ev­er, we some­times share Per­son­al Data with third par­ties as not­ed above, and we do not have con­trol over third par­ties’ secu­ri­ty process­es. Please note, we do not war­rant per­fect secu­ri­ty and we do not pro­vide any guar­an­tee that your Per­son­al Data or any oth­er infor­ma­tion you pro­vide us will remain secure.
DATA RETENTION
We retain infor­ma­tion for so long as it, in our dis­cre­tion, remains rel­e­vant to its pur­pose, and in any event, for so long as is required by law or as direct­ed by our Clients. We will review reten­tion peri­ods peri­od­i­cal­ly, and may some­times pseu­do­nymize or anonymize data held for longer peri­ods, if appropriate.
MINORS
Our Plat­form is nei­ther direct­ed at nor intend­ed for use by minors under the age of major­i­ty in the rel­e­vant juris­dic­tion. Fur­ther, we do not know­ing­ly col­lect Per­son­al Data from such indi­vid­u­als. If we learn that we have inad­ver­tent­ly done so, we will prompt­ly delete it. Do not access or use the Plat­form if you are not of the age of major­i­ty in your juris­dic­tion unless you have the con­sent of your par­ent or guardian.
INTERNATIONAL TRANSFERS
We oper­ate in and use ser­vice providers locat­ed in the Unit­ed States. If you are locat­ed out­side the U.S., your Per­son­al Data may be trans­ferred to the U.S. The U.S. does not pro­vide the same legal pro­tec­tions guar­an­teed to Per­son­al Data in the Euro­pean Union. Accord­ing­ly, your Per­son­al Data may be trans­ferred to the U.S. pur­suant to the Stan­dard Con­trac­tu­al Claus­es, or oth­er ade­qua­cy mech­a­nisms, or pur­suant to exemp­tions pro­vid­ed under EU law. Con­tact us for more infor­ma­tion regard­ing the mech­a­nisms to ensure ade­quate pro­tec­tion of data sub­ject to EU Law.
CHANGES TO OUR PRIVACY POLICY
We may change this Pri­va­cy Pol­i­cy from time to time. Changes will be post­ed on this page with the effec­tive date. Please vis­it this page reg­u­lar­ly so that you are aware of our lat­est updates. Your use of the Ser­vice fol­low­ing notice of any changes indi­cates accep­tance of any changes. 
Pre­vi­ous
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Collection and use of personal data

We may col­lect and process infor­ma­tion that relates to iden­ti­fied or iden­ti­fi­able indi­vid­u­als (“Per­son­al Data”). We col­lect and process the fol­low­ing cat­e­gories of Per­son­al Data (note, spe­cif­ic Per­son­al Data ele­ments list­ed in each cat­e­go­ry are only exam­ples and may change):

  • Per­son­al Data about you and your iden­ti­ty, such as your name, ID num­ber, photo/avatar, user­name, and oth­er Per­son­al Data you may pro­vide on reg­is­tra­tion or pur­chase forms or as part of an account pro­file (e.g. bio­graph­i­cal information).
  • Per­son­al Data used to con­tact an indi­vid­ual, e.g. email address(es), phys­i­cal address(es), phone number(s), or social media or com­mu­ni­ca­tions plat­form usernames/handles, as well as a name or oth­er salutation.
  • Per­son­al Data relat­ing to your device, brows­er, or appli­ca­tion e.g. IP address­es, MAC address­es, appli­ca­tion ID/AdID/IDFA, iden­ti­fiers from cook­ies, ses­sion nav­i­ga­tion his­to­ry and sim­i­lar brows­ing meta­da­ta, and oth­er data gen­er­at­ed through appli­ca­tions and browsers, includ­ing cook­ies and sim­i­lar technologies.
  • Per­son­al Data relat­ing to your loca­tion, such as infor­ma­tion col­lect­ed from your device’s GPS, or WiFi, or oth­er local­iza­tion service.
  • Per­son­al Data reveal­ing racial or eth­nic ori­gin, polit­i­cal opin­ions, reli­gious or philo­soph­i­cal beliefs, or trade union mem­ber­ship, genet­ic data, bio­met­ric data, health infor­ma­tion, or infor­ma­tion relat­ing to sex life or sex­u­al orientation.
  • Infor­ma­tion that a user pro­vides in a mes­sage, free text field, or oth­er unstruc­tured for­mat, includ­ing any Per­son­al Data or Spe­cial Cat­e­go­ry Data to the extent pro­vid­ed by the user.
  • On behalf of the Client, we process Iden­ti­ty Data, Con­tact Data, Device Data and if pro­vid­ed, User Con­tent when you use our Plat­form to com­mu­ni­cate with or send a mes­sage to a Client or oth­er Client users, or if you oth­er­wise sub­mit any User Con­tent (e.g. on a com­ment board or oth­er free form con­tent sub­mis­sion form).
  • On behalf of the Client, we use Iden­ti­ty Data, Device Data, Con­tact Data, and User Con­tent on behalf of the Clients as nec­es­sary to car­ry out the process­es and trans­ac­tions you request, includ­ing dis­clos­ing this infor­ma­tion to the Client. Sub­ject to Your Rights and Choic­es, we may also use this infor­ma­tion as part of our legit­i­mate inter­ests in improv­ing the design of our Plat­form, to cre­ate a per­son­al­ized user expe­ri­ence, and for ensur­ing the secu­ri­ty and sta­bil­i­ty of the Platform.
  • Client users may be able to reg­is­ter and cre­ate an account on our Plat­form. If you reg­is­ter, we will process Iden­ti­ty Data, Pref­er­ences Data and cer­tain Con­tact Data.
  • We use the Iden­ti­ty Data and Con­tact Data as nec­es­sary to cre­ate, main­tain, and pro­vide you with impor­tant infor­ma­tion about your account. Sub­ject to Your Rights and Choic­es, we may also use this infor­ma­tion as part of our legit­i­mate inter­ests in improv­ing the design of our Plat­form, to cre­ate a per­son­al­ized user expe­ri­ence, for ensur­ing the secu­ri­ty and sta­bil­i­ty of the Plat­form, and in con­nec­tion with mar­ket­ing communications.
  • We may process Iden­ti­ty Data and Con­tact Data in con­nec­tion with email mar­ket­ing com­mu­ni­ca­tions if you reg­is­ter for a Client account or choose to enroll to receive mar­ket­ing com­mu­ni­ca­tions or when you open or inter­act with our mar­ket­ing communications.
  • We use Iden­ti­ty Data and Con­tact Data as nec­es­sary to pro­vide mar­ket­ing com­mu­ni­ca­tions, and con­sis­tent with our legit­i­mate busi­ness inter­ests, we may send you mar­ket­ing and pro­mo­tion­al com­mu­ni­ca­tions if you sign up for those com­mu­ni­ca­tions reg­is­ter for our Ser­vice. See Your Rights and Choic­es for infor­ma­tion about how you can lim­it or opt out of this processing.
  • We, and cer­tain third par­ties, may process Iden­ti­ty Data, Con­tact Data and Device Data when you inter­act with cook­ies and sim­i­lar tech­nolo­gies on our Site. We may receive this data from third par­ties to the extent allowed by the applic­a­ble part­ner. Please note that the pri­va­cy poli­cies of third par­ties may apply to these tech­nolo­gies and infor­ma­tion collected.
  • Sub­ject to Your Rights and Choic­es, we use this infor­ma­tion as fol­lows: for “essen­tial” or “func­tion­al” pur­pos­es, such as to enable var­i­ous fea­tures of the Plat­form such as remem­ber­ing pass­words, or stay­ing logged in dur­ing your ses­sion; for “ana­lyt­ics” pur­pos­es, con­sis­tent with our legit­i­mate inter­ests in how the Plat­form is used or per­forms, how users engage with and nav­i­gate through the Plat­form, what sites users vis­it before vis­it­ing our Plat­form, how often they vis­it our Plat­form, and oth­er sim­i­lar infor­ma­tion; and sub­ject to any con­sent required by law, for the pur­pose of dis­play­ing adver­tise­ments via retar­get­ing to those users who have vis­it­ed our Site, or for behav­ioral advertising

Behavioral advertising

We, and cer­tain third par­ties oper­at­ing on or through our Site, may engage in online behav­ioral adver­tis­ing. This form of adver­tis­ing includes var­i­ous par­ties and ser­vices providers, includ­ing third par­ty data con­trollers, engaged in the pro­cess­ing of per­son­al data in con­nec­tion with adver­tis­ing. This form of adver­tis­ing uses Device Data, Iden­ti­ty Data, and at times, Con­tact Data in order to deliv­er more rel­e­vant adver­tis­ing to you. The par­ties that con­trol the pro­cess­ing of Per­son­al Data for behav­ioral adver­tis­ing pur­pos­es may build a pro­file of you con­tain­ing this infor­ma­tion, and may be able to iden­ti­fy you across sites, devices, and over time. These ser­vices may also track whether you view, inter­act with, or how often you have seen an ad, or whether you com­plete a pur­chase for a good or ser­vices you were shown in an adver­tise­ment. In some cas­es, these par­ties may also devel­op and assess aspects of a pro­file about you to deter­mine whether you are a type of per­son a com­pa­ny wants to adver­tise to, and deter­mine whether and how ads you see are effec­tive, and these third par­ties may aug­ment your pro­file with infor­ma­tion derived from these obser­va­tions. See Your Rights and Choic­es for infor­ma­tion about how you can lim­it or opt out of this processing.


Additional processing 

If we process Per­son­al Data in con­nec­tion with our Plat­form in a way not described in this Pol­i­cy, this Pol­i­cy will still apply gen­er­al­ly (e.g. with respect to Your Rights and Choic­es) unless oth­er­wise stat­ed when you pro­vide it.

Note that we may, with­out your con­sent, also process your Per­son­al Data on cer­tain pub­lic inter­est grounds. For exam­ple, we may process infor­ma­tion as nec­es­sary to ful­fil our legal oblig­a­tions, to pro­tect the vital inter­ests of any indi­vid­u­als, or oth­er­wise in the pub­lic inter­est. Please see the Data Shar­ing sec­tion for more infor­ma­tion about how we dis­close Per­son­al Data in extra­or­di­nary circumstances.

Data sharing

Infor­ma­tion we col­lect may be shared with a vari­ety of par­ties, depend­ing upon the pur­pose for and con­text in which that infor­ma­tion was pro­vid­ed. We gen­er­al­ly trans­fer data to the fol­low­ing cat­e­gories of recipients:

  • We process data on behalf of Clients, and may share your Per­son­al Data with Clients to the extent such infor­ma­tion was pro­vid­ed to us for pro­cess­ing on the Client’s behalf. For exam­ple, any com­mu­ni­ca­tions sent using our Plat­form and all oth­er Per­son­al Data processed on behalf of the Client may be avail­able to the Client and its users. These par­ties may engage in direct mar­ket­ing, or oth­er activ­i­ties that are out­side our control.
  • In con­nec­tion with our gen­er­al busi­ness oper­a­tions, product/service improve­ments, to enable cer­tain fea­tures, and in con­nec­tion with our oth­er legit­i­mate busi­ness inter­ests, we may share your Per­son­al Data with ser­vice providers or sub­proces­sors who pro­vide cer­tain ser­vices or process data on our behalf.
  • In order to stream­line cer­tain busi­ness oper­a­tions and devel­op prod­ucts and ser­vices that bet­ter meet the inter­ests and needs of our cus­tomers, and inform our cus­tomers about rel­e­vant prod­ucts and ser­vices, we may share your Per­son­al Data with any of our cur­rent or future affil­i­at­ed enti­ties, sub­sidiaries, and par­ent companies.
  • In order to deliv­er cer­tain adver­tise­ments, and devel­op bet­ter prod­ucts and ser­vices, we may share cer­tain Per­son­al Data col­lect­ed from our Site (as described in the Cook­ies and Sim­i­lar Tech­nol­o­gy sec­tion above) with trust­ed third par­ties for mar­ket­ing, adver­tis­ing, or sim­i­lar com­mer­cial purposes.
  • Your Per­son­al Data may be processed in the event that we go through a busi­ness tran­si­tion, such as a merg­er, acqui­si­tion, liq­ui­da­tion, or sale of all or a por­tion of our assets. For exam­ple, Per­son­al Data may be part of the assets trans­ferred, or may be dis­closed (sub­ject to con­fi­den­tial­i­ty restric­tions) dur­ing the due dili­gence process for a poten­tial transaction.
  • In lim­it­ed cir­cum­stances, we may, with­out notice or your con­sent, access and dis­close your Per­son­al Data, any com­mu­ni­ca­tions sent or received by you, and any oth­er infor­ma­tion that we may have about you to the extent we believe such dis­clo­sure is legal­ly required, to pre­vent or respond to a crime, to inves­ti­gate vio­la­tions of our Terms of Use, or in the vital inter­ests of us or any per­son. Note, these dis­clo­sures may be made to gov­ern­ments that do not ensure the same degree of pro­tec­tion of your Per­son­al Data as your home juris­dic­tion. We may, in our sole dis­cre­tion (but with­out any oblig­a­tion), object to the dis­clo­sure of your Per­son­al Data to such parties.

Your rights and choices

Sub­ject to the rights grant­ed to oth­er indi­vid­u­als, and our rights to lim­it or deny access/disclosure under applic­a­ble law, you have the fol­low­ing rights in your Per­son­al Data. We may require that you pro­vide addi­tion­al Per­son­al Data to exer­cise these rights, e.g. infor­ma­tion nec­es­sary to prove your iden­ti­ty. Note: While we may noti­fy Clients of your request, we are unable to direct­ly ful­fill rights requests regard­ing Per­son­al Data we con­trol or for which we have the nec­es­sary rights of access, and we may not have access to or con­trol over all or some Per­son­al Data con­trolled by Clients. Please con­tact the Client direct­ly for data rights requests regard­ing Client-con­trolled infor­ma­tion, and we will assist the Client as appro­pri­ate in the ful­fill­ment of your request. You may exer­cise your rights by con­tact­ing us at the address below.

 

It is pos­si­ble for you to use some of our Plat­form with­out pro­vid­ing any Per­son­al Data, but you may not be able to access cer­tain fea­tures or view cer­tain con­tent. You have the fol­low­ing choic­es regard­ing the Per­son­al Data we process:

  • You may receive a list of your Per­son­al Data that we process to the extent required and per­mit­ted by law.
  • You may cor­rect any Per­son­al Data that we hold about you to the extent required and per­mit­ted by law. You may be able to make changes to much of the infor­ma­tion you pro­vid­ed direct­ly via the Ser­vice via your account set­tings menu.
  • To the extent required by applic­a­ble law, you may request that we delete your Per­son­al Data from our systems.
  • To the extent required by applic­a­ble law, we will send you a copy of your Per­son­al Data in a com­mon portable for­mat of our choice.
  • You have the right to con­tact or file a com­plaint with reg­u­la­tors or super­vi­so­ry author­i­ties about our pro­cess­ing of Per­son­al Data. To do so, please con­tact your local data pro­tec­tion or con­sumer pro­tec­tion authority.
  • Res­i­dents of Cal­i­for­nia (and oth­ers to the extent required by applic­a­ble law) may request a list of Per­son­al Data we have dis­closed about you to third par­ties for direct mar­ket­ing pur­pos­es dur­ing the pre­ced­ing cal­en­dar year. This request must be writ­ten, signed, and mailed to us.
  • If you con­sent to pro­cess­ing, you may with­draw your con­sent at any time, to the extent required by law.
  • You have the choice to opt-out of or with­draw your con­sent to direct mar­ket­ing com­mu­ni­ca­tions. You may have a legal right not to receive such mes­sages in cer­tain cir­cum­stances, in which case, you will only receive direct mar­ket­ing com­mu­ni­ca­tions if you con­sent. You may exer­cise your choice via the links in our com­mu­ni­ca­tions or by con­tact­ing us re: direct marketing.
  • You may con­trol or lim­it Loca­tion Data that we col­lect using our Mobile App by chang­ing your pref­er­ences in your device’s loca­tion ser­vices pref­er­ences menu, or through your choic­es regard­ing the use of Blue­tooth, WiFi, and oth­er net­work inter­faces you may use.
  • If you do not want infor­ma­tion col­lect­ed through the use of cook­ies, you can manage/deny cook­ies (and cer­tain tech­nolo­gies) using your browser’s set­tings menu. You must opt out of third par­ty ser­vices direct­ly via the third par­ty. For exam­ple, to opt-out of Google’s ana­lyt­ic and mar­ket­ing ser­vices, vis­it Google Ana­lyt­ics Terms of Use, the Google Pri­va­cy Pol­i­cy, or Google Ana­lyt­ics Opt-out. To learn more about how to opt out of Google’s use of cook­ies for adver­tis­ing or retar­get­ing, vis­it Google’s Ads Set­tings, here. Please note, at this time, our Ser­vice does not respond to your browser’s do-not-track request.
  • You may have the right under applic­a­ble law to object to our pro­cess­ing of your Per­son­al Data for cer­tain pur­pos­es. You may do so by con­tact­ing us re: data rights requests. Note that we may not be required to cease pro­cess­ing based sole­ly on an objection.

Contact us

If you have any ques­tions about these Terms, please feel free to please con­tact us at:

 

Gen­er­al inquires: info@trywhistle.com

Data rights requests: compliance@trywhistle.com

 

Whis­tle Mes­sag­ing, Inc.
31416 Agoura Road #105
West­lake Vil­lage, CA, 91361
Unit­ed States

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