Privacy policy

Last updated: 13 November 2023

Effective: 13 November 2023

Thank you for using Whenn. Here we describe how we collect, use and handle your personal data when you use our websites, software and services (‘Services’). 

What & Why

We collect and use the following information to provide, improve, protect and promote our Services.

Account information. We collect, and associate with your account, the information you provide to us when you do things such as sign up for your account, upgrade to a paid plan and set up two-factor authentication (such as your name, email address, phone number, payment info and physical address).

What is yours. Our Services are designed as a simple, personalised way for you to store your data, information, text and so on (‘What is yours’), and share this with others. To make that possible, we store, process and transmit what is yours as well as information related to it. This related information includes your account information, which makes it easier to share what is yours with others when you request, as well as things like the size of content, the time it was uploaded, sharing and usage activity.

Contacts. You may choose to give us access to your contacts to make it easy for you, and your shared contacts, to do things like share what is yours, send requests and invite others to use the Services. If you do, we’ll store those contacts on our servers.

Usage information. We collect information related to how you use the Services, including actions you take in your account (like sharing, editing, viewing, creating and moving files or folders, and sending and receiving and other transactions). We use this information to provide, improve and promote our Services, and protect Whenn users. 

Device information. We also collect information from and about the devices you use to access the Services. This includes things like IP addresses, the type of device you use and identifiers associated with your devices. Your devices (depending on their settings) may also transmit location information to the Services. For example, we use device information to detect abuse and identify and troubleshoot issues.

Cookies and other technologies. We may use technologies like cookies and pixel tags to provide, improve, protect and promote our Services. For example, cookies help us with things like remembering your username for your next visit, understanding how you are interacting with our Services and improving them based on that information. You can set your browser to not accept cookies, but this may limit your ability to use the Services. We may also use third-party service providers that set cookies and similar technologies to promote Whenn services. 

Sharing analytics. In the case that Sharing is activated as part of our Services, we collect information including your identifying and device information, such as email addresses, IP addresses and device identifiers of devices to confirm Sharing has been activated. We also collect information on how you interact with the viewed content, such as the date and time you view the content, the number of times and length of time you view the content and which portions of the content you view.

Marketing. We give users the option to use some of our Services free of charge. These free Services are made possible by the fact that some users use our paid Services. If you register for our Services, we will, from time to time, send you information about upgrades when permissible. Users who receive these marketing materials can opt out at any time. If you do not want to receive a particular type of marketing material from us, click the ‘unsubscribe’ link in the corresponding emails, or update your preferences in the Notifications section of your personal account.

We may also collect information from you if you interact with Whenn representatives through customer support, at an event, download marketing or educational materials from our website or contact a Whenn representative. We may use the information you provide to send you additional marketing materials.

We sometimes contact people who do not have a Whenn account. For recipients in the EU, we or a third party will obtain consent before getting in touch. If you receive an email and no longer wish to be contacted by Whenn, you can unsubscribe and remove yourself from our contact list via the message itself.

Children’s privacy. Whenn does not provide services that children are likely to be attracted to by the nature and content of the service. Whenn does not intentionally or knowingly collect personal information from children under the age of 16. If we learn that we have personal information on a child under the age of 16, we will delete that information from our servers. 

Bases for processing your data. We collect and use the personal data described above in order to provide you with the Services in a reliable and secure manner. We also collect and use personal data for our legitimate business needs. To the extent that we process your personal data for other purposes, we ask for your consent in advance or require our partners to obtain such consent. 

What are Whenn’s lawful bases for processing data?

Whenn processes your data (1) to provide the Whenn Services to you pursuant to our contract with you; (2) in furtherance of its legitimate interests in operating our Services and business; and (3) with your consent. In some cases, Whenn may process your data to comply with applicable law, legal process, or regulation; protect any person from death or serious bodily injury; or to carry out a task in the public interest.

Examples of Whenn processing your data to provide you with the Whenn Services include:

  • Providing, updating, maintaining, and protecting our Services and business. For example, we host your data, back it up, and share it when you ask us to. We may also analyse how you use the Services to help prioritise your content.

  • Troubleshooting issues you may encounter with the Whenn Services. If you contact us with questions or concerns about the Services, we may use your personal information to respond.

  • Billing, account management, and administrative purposes. If you sign up for a trial or purchase a paid Whenn plan, we may collect and process payment information, including your name, credit or debit card information, billing address, and details of your transaction history.

  • Sending you emails and other communications. We may contact you about important changes to our Services and Service-related notices. These communications are considered part of the Whenn Services and you may not opt out of them.

Examples of Whenn processing your data in furtherance of its legitimate interests in operating our Services and business include:

  • Understanding how you use our Services and improving them.

  • Promoting Whenn Services that are most relevant to you.

  • Investigating and preventing security issues and abuse of the Whenn Services or Whenn users.

  • Conducting analytics and reporting on industry trends on usage and performance. 

Examples of Whenn processing your data with your consent include:

  • Sending you marketing materials about our Services. If you do not wish to receive these materials, simply click the Unsubscribe link in any email, or update your preferences in the account settings section of your Whenn account.

  • Connecting your Whenn account with other third-party services via Whenn APIs.

  • Collecting feedback from you to improve our Services and develop new features.

With whom

We may share information as discussed below, but we won’t sell it to advertisers or other third parties.

Others working for and with Whenn. Whenn uses certain trusted third parties (for example, providers of customer support and IT services) for the business purposes of helping us provide, improve, protect and promote our Services. These third parties will access your information to perform tasks on our behalf, and we will remain responsible for their handling of your information per our instructions. 

Other users. Our Services are designed to help you share with others. If you register your Whenn account with an email address, and another user invites you to share on Whenn, the Sharing requestor may see some of your basic information, like your name and email address. This helps users begin the sharing process with you and others.

Other applications. You may choose to connect your Whenn account with third-party services. By doing so, you’re enabling Whenn and those third parties to exchange information about you and data in your account so that Whenn and those third parties can provide, improve, protect and promote their services. Please remember that third parties’ use of your information will be governed by their own privacy policies and terms of service.

Law and order and the public interest. We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to: (a) comply with any applicable law, regulation, legal process or appropriate government request; (b) protect any person from death or serious bodily harm; (c) prevent fraud or abuse of Whenn or our users; (d) protect Whenn’s rights, property, safety or interest; or (e) perform a task carried out in the public interest.

Looking after your data is critical to us and a responsibility that we embrace. We believe that your data should receive the same legal protections regardless of whether it is stored on our Services or on your home computer’s hard drive. We will use our judgment case by case when receiving, scrutinising and responding to government requests (including national security requests) for your data:

  • Be transparent

  • Question blanket requests

  • Protect users and

  • Provide trusted services.

Security. We continue to work on features to keep your information safe in addition to things like two-factor authentication and encryption of data in flight and database encryption. We review and act upon abusive behaviour and content that may harm our Services, you or other users.

User controls. You can access, amend and delete your personal information by logging in to your Whenn account.

Retention. When you sign up for an account with us, we’ll retain information you store on our Services for as long as your account exists or for as long as we need it to provide you the Services.

If you request to delete your account, will initiate deletion of this information after 30 days. Please note: (1) there might be some latency in deleting this information from our servers and backup storage, and (2) we may retain this information if necessary to comply with our legal obligations, resolve disputes or enforce our agreements.

Where

Around the world. To provide you with the Services, we may store, process and transmit data in the United Kingdom and locations around the world – including those outside your country. Data may also be stored locally on the devices that you use to access the Services.

Data transfers. When transferring data from the European Union, the European Economic Area, the United Kingdom and Switzerland, Whenn relies upon a variety of legal mechanisms, such as contracts with our customers and affiliates, as applicable.

Your control of and access to Your Data

You have control over your personal data and how it’s collected, used and shared. For example, you can:

  • Delete what is yours in your Whenn account. You can find out more about how to delete files saved on Whenn here.

  • Change or correct personal data. You can manage your account and the content contained in it, as well as edit some of your personal data, through your account settings tab in the app.

  • Access your data. You can access your personal data from your Whenn account.

  • Object to the processing of your personal data. Depending on the processing activity, you can request that we stop or limit processing of your personal data.

Whenn as controller or processor. Whenn is a Personal Data Controller and processor according to the Data Protection Act 2018 (DPA 2018) which sits alongside and supplements the UK GDPR.

Changes. If we’re involved in a reorganisation, merger, acquisition or sale of our assets, your data may be transferred as part of that deal. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event.

Governing law. This Privacy Policy and the use of the Website are governed by the laws of England and Wales. The parties undertake to first try to resolve the dispute by mediation and negotiation. If the parties fail to reach an amicable resolution through negotiation, Whenn agrees to submit the dispute to the competent Court of England and Wales.

Copyright and intellectual property.  The copyright, trademarks and content of our Website are the property of Whenn. All rights reserved.

Texts, graphics, photographs, animations, videos and clips, visible on the Website are the object of copyright and are part of the intellectual property of Whenn. Those may not be reproduced, used, presented or represented without an explicit written permission by Whenn. Any distribution of files, obtained by the Users under the Terms and Conditions of the Website, or of parts of such files, constitutes a violation of the relevant intellectual property protection laws and is prosecuted by the law.

Nothing contained on this Website may be interpreted as granting a licence or right of use as a trademark without the prior explicit written consent of Whenn.

Miscellaneous. Whenn is controlled, operated and administered entirely within United Kingdom. If you are accessing the Whenn Website from another jurisdiction, please be advised that you are transferring your personal information to Whenn in the United Kingdom and, by using the Website, you consent to that transfer and to abide by the applicable laws concerning your use of the Website and your agreements with us.

This statement and the policies outlined in this Privacy Policy are not intended to and do not create any contractual or other legal rights in or on behalf of any third party.

Whenn may display a translation of the English version of the Privacy Policy into other languages. You understand and agree that any translation of the Privacy Policy into other languages is only for your convenience and that the English version shall govern your rights and responsibilities. In case there are any inconsistencies between the English version of the Privacy Policy and its translated versions, the English version of the Terms shall prevail.

We may revise this Privacy Policy from time to time, and will post the most current version on our website. If a revision meaningfully reduces your rights, we will notify you.