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):

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:

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:

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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