1. Personal data regulation

Policy on the protection of personal data

On 25 May 2018, a new personal data regulation got registered. The regulation applies throughout the EU and the EEA and aims to regulate when and how personal data about employees, customers, business partners and other data subjects may be processed. 

The Personal Data Regulation requires, among other things, greater transparency about who processes personal data about registered users, to give registered users the opportunity to gain insight into the personal data that is processed, and to give registered users the opportunity to demand that incorrect information be corrected or deleted if so, etc. As a result of the new personal data regulation, WHOHOW has drawn up a policy on the protection of WHOHOW users’ protection of personal data.

WHOHOW prioritizes the fact that WHOHOW-users should feel comfortable using the service. WHOHOW’s policy about protection of personal data contains information about how and why WHOHOW collects, uses, stores, shares and protects information in relation to WHOHOW’s application, collectively referred to as the “service”, as well as the terms and rights of WHOHOW users in connection with the collection and use of information including how WHOHOW users can update, manage, export and delete personal data.

Reference is made to WHOHOW’s terms of use in relation to the general definitions, including, but not limited to, WHOHOW, the service, users, etc. which is used in WHOHOW’s terms and conditions.

When you access or use the service, you agree that WHOHOW, regardless of your access method and user type, processes personal data about you as stated in this policy. However, this data will not appear to be of a personally sensitive nature, and therefore this information and data is used exclusively to optimize the user experience of WHOHOW’s application.

 

Who is the data controller?

The person responsible for the processing of your personal data is:

 

WHOHOW ApS

Strandvejen 120, 1 2900 Hellerup

Denmark

CVR: 43215531

 

Contact Information:

Mail: support@who-how.com

 

The legal basis for the processing of your information

The legal basis for our processing of your personal data follows from the personal data regulation (EU) 2016/679 of 27 April 2016, article 6, subsection 1, letter a and Article 9, subsection 2, letters e and f. You can find the personal data regulation here: https://eur-lex.europa.eu/legal-content/DA/TXT/?uri=celex%3A32016R0679.

When you register as a user of the service, you thus agree that WHOHOW may process and store your personal data in accordance with this policy.

 

What information does WHOHOW collect and process?

WHOHOW processes several different categories of personal data, including, but not limited to, general information and sensitive information, including e.g. email and payment information. This will be information that you provide yourself to the service. When you use the service, you agree that you have understood and accepted that WHOHOW uses social sign-ons, so that the individual user can have his own independent profile on WHOHOW’s application. Beside that,  Ai data is used in relation to logins that are with third-party systems; Facebook, Apple and Google. This data is not shared with other WHOHOW users. This means that other users cannot search, use or otherwise share the data that you have disclosed to us, subject to the terms and conditions of this privacy policy and our terms of use.

WHOHOW collects content and information that you provide when you sign up to the platform and create your own independent profiles. This includes email address, payment information and other information that you provide via your user profile.

WHOHOW also collects information about how you use the service, e.g. the way you interact with the platform, including the frequency, duration and use of the service.

WHOHOW also collects communications between you and WHOHOW. When you use the service, you agree that you have understood and accepted that WHOHOW sends you e-mails about the service, including e.g. confirmation of your user account, changes/updates to features on the Service, technical notices, security information and new styling tips. Therefore, WHOHOW must point out that you cannot opt out of e-mails from WHOHOW regarding changes and updates. If you do not wish to receive WHOHOW’s e-mails and notifications then please send an e-mail to: support@who-how.com.

If you purchase one of WHOHOW’s subscription packages, information about the purchase or transaction will be collected. This information includes your payment information, such as your credit or debit card number, as well as other information about your card, other account and authorization information, and billing and contact information.

 

Information for analysis purposes

WHOHOW uses third-party analytics tools to measure traffic and usage trends for the Service. The tools collect information sent by your device or the Service, including web pages you visit, addons, and other information that helps WHOHOW improve the Service. WHOHOW collects and uses the analysis information together with analysis information from other users, so that it is not possible to identify the individual user.

 

Analyseværktøjer

When you visit the Service, WHOHOW may use a number of technologies, including but not limited to, for example, pixels and local storage, to collect information about how you use WHOHOW and to provide features to you.

·  Log file information: WHOHOW’s browser automatically reports log file information each time you request to access the application. Log file information is also reported when you download the content of the Service to your browser or device. When you use the Service, WHOHOW’s servers automatically record certain log file information, including your Internet Protocol (IP) address, browser type, referring pages and number of clicks, how you interact with the Service, landing pages, pages viewed and other similar information. WHOHOW also collects similar information from emails that’s been sent to you, which is then used to track which emails you open and which links you click on. WHOHOW uses the information to achieve more accurate reporting and to improve the service.

 ·  Device IDs: When you use the service from a mobile device, e.g. a tablet or phone, WHOHOW opens, collects, monitors and stores one or more device IDs on your device or in external storage. Device IDs are small data files or similar data structures which are stored on or associated with your mobile device and which are used to uniquely identify the mobile device. A device ID can be data stored with the device’s hardware, data stored with the device’s operating system, or other software or data that WHOHOW sends to the device. A device ID provides information to WHOHOW about how you browse or use the Service and enables it to display reports or customized content to you. Some features of the Service may not function properly if the use of Device IDs is prevented or disabled.

·  Metadata: Metadata is typically technical data associated with user content. Metadata can e.g. describe how and when certain user content has been collected and by whom, as well as how the content is formatted. WHOHOW collects and uses as a starting point, but not limited to, metadata in an analytical context.

 

What does WHOHOW use your personal data for?

WHOHOW’s overall purpose for processing and processing your personal data is to use your data to improve, optimize and display optimal styles targeted at your own personal references and to improve and optimize the terms and purposes of the service itself.

WHOHOW uses e.g. the collected personal data for, but not limited to, conducting surveys, testing functions and analyzing data from the app to improve the service with new products, functions, perform troubleshooting activities and the like.

Therefore, WHOHOW collects and processes e.g. your personal data for the purposes of, but not limited to:

• Finding out what language you speak and match the app’s layout to this
• Fix crashes and bugs based on your use of the app
• Finding out what type of device you use and how often you access and use our service
• Protect all users against improper use of the services.
• Collect pixel tags to improve your user experience
• Prepare statistics/analyses and use tracking tools such as Google Analytics with a view to optimizing the technicalities of the service as well as profiling the service, e.g. according to marketing contexts.

 

WHOHOW’s purpose in processing data is also to be at the forefront of the latest general standards and trends for UI, UX and design. Thus, your user data is the basis for creating a general improvement of the user experience with the service itself.

In addition to the specific uses described in this Privacy Policy, WHOHOW may use the information received from you to, respectively, but not limited to, provide you with quick access to your own individual information when you are logged in, to verify login, your subscription association, to investigate suspicious activity, to investigate violation of WHOHOW’s terms and policies, to remember information so that you do not have to enter it again during your visit or the next time you visit the service, on the contrary, the intention is to provide, improve, test and monitor the effectiveness of the service, to develop and test new products and functions, to monitor various parameters, e.g. total number of visitors, traffic and demographic patterns in order to constantly update the service as best as possible, to diagnose and correct technological problems, to update the application automatically on your device etc.

 

How is your information stored and processed?

The information that WHOHOW collects about you via the service is saved, stored and processed by, among others, but not limited to, WHOHOW and WHOHOW’s suppliers of data processing, including among others, but not limited to, WHOHOW’s associated companies or service providers. WHOHOW’s affiliates, service providers and data processing suppliers are:

 

WHOHOW’s associated companies and service providers include:

• Stripe. Stripe is used for handling subscription payments. Stripe handles personal sensitive data that complies with GDPR. Their headquarter is located at 354 Oyster Point Blvd., South San Francisco, CA 94107, USA. Their privacy policy can be read here: https://stripe.com/en-dk/privacy.

• MeeW ApS. MeeW is a technology provider that contributes to the technical development, technology and resources needed to develop the WHOHOW app. MeeW tracks and remedies bugs, crashes, optimization opportunities, development opportunities and other relevant technological data points to optimize and improve UI, UX, design and general user experience. Their headquarter is located at Overgaden Neden Vandet 9A, 1414 Copenhagen, Denmark. Their privacy policy can be read here: https://www.meew.dk/privatlivspolitik/.

• Facebook. Facebook is a social media platform that assists WHOHOW with the necessary Ai data needed for users to use social sign-ons. Their headquarter is located at Ireland Ltd. 4 Grand Canal Square, Grand Canal Harbor D2 Dublin. Their privacy policy can be read here: https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0.

• Apple. Apple’s App Store is a distribution channel that stores and distributes the app itself. Furthermore, they validate the individual user as a third-party provider. Their headquarter is located at Apple Park Way Cupertino, California, 95014-0642 United States. Their privacy policy can be read here: https://developer.apple.com/app-store/app-privacy-details/.

• Google Play. Google Play is a distribution channel that stores and distributes the app itself. Their headquarters is located in Mountain View, CA, US (HQ), 1600 Amphitheater Pkwy. Their privacy policy can be read here: https://policies.google.com/privacy.

• Google. Google is a distribution channel that assists WHOHOW with the necessary Ai data needed for users to use social sign-ons. Their headquarter is located at Mountain View, CA, US (HQ), 1600 Amphitheater Pkwy. Their privacy policy can be read here: https://support.google.com/adspolicy/answer/54817?hl=en.

• Supabase. Supabase is an open-source firebase platform. The platform helps support WHOHOW’s features and setting up the app. Their headquarter is located at 970 Toa Payoh North #07-04, Singapore, Central Singapore, 318992, Singapore. Their privacy policy can be read here: https://supabase.com/docs/company/privacy.

• DigitalOcean. DigitalOcean is a cloud infrastructure provider that supports WHOHOW’s management portal and backend. Their headquarter is located at 101 Avenue of the Americas (Grand St.) New York, NY 10013. Their privacy policy can be read here: https://www.digitalocean.com/legal/privacy-policy.

 

WHOHOW, its affiliates, service providers or suppliers of data processing transfer the information that WHOHOW collects about you, including the information that you yourself disclose and provide when using/creating a user account across national borders and thus across your jurisdiction to others countries or jurisdictions around the world, as WHOHOW and its affiliates and service provider, pursuant to the above, are geographically located in different countries. If you are located in the USA, China, Russia, or other logistics areas that have laws on the collection and use of data that are different from the legislation in Denmark, you should be aware that we may transfer information, including personal data, to a country or jurisdiction that may not have the same data protection laws as your existing jurisdiction.

When you register and use the service, you consent to the exchange, use and disclosure of personal information about you as described in this privacy policy in the countries where WHOHOW, its affiliates or service providers operate.

Only trusted employees with a work-related need at WHOHOW and at WHOHOW’s associated companies, suppliers of data processing, have access to the collected personal data.

 

What does WHOHOW do to protect your information?

WHOHOW manages to ensure that personal data is encrypted during transit and storage, and that only a limited number of individuals whose work necessitates access to personal data have access to this data.

WHOHOW takes reasonable steps (for example, by requesting a unique password) to verify your identity before we grant you access to your account on the app and the webshop, respectively. This happens i.a. to ensure that your information is protected as best as possible. WHOHOW will therefore at any time anonymize the data that can indicate your association with the platform.

 

Who does WHOHOW share your information with?

WHOHOW does not rent or sell your information to third parties outside of WHOHOW, its affiliates or service providers without your consent, except in the specific situations set forth in this policy.

WHOHOW shares user content and your information including, but not limited to, information from cookies, logs, device IDs and usage data) with entities that legally belong to the same group of companies as WHOHOW, or that may become part of this group (“associates”). The associated companies may use the information to provide content and improve the Service (including through analytics data) and the associated companies’ own services (including by providing you with a better and more relevant user experience).

WHOHOW may also share your information including, but not limited to, information from tools such as cookies, logs and device IDs and location data with third party companies that help WHOHOW provide the Service to you (“Service Providers”). Our service providers access your information to the extent reasonably necessary to provide the service.

WHOHOW may also share certain information, including but not limited to data, with third-party advertisers with whom WHOHOW partners.

WHOHOW may share your personal data with public authorities, including e.g. the public prosecutor’s office, the police, municipalities and SKAT, as well as corresponding authorities in other jurisdictions who have a legitimate and special interest in the use of the information found on WHOHOW, and if WHOHOW believes in good faith that WHOHOW is obliged to provide this data in accordance with applicable law in the relevant jurisdiction.

If WHOHOW sells or otherwise transfers all of WHOHOW or parts of the company or the company’s assets to another company (e.g. in connection with a merger, acquisition, bankruptcy, dissolution or liquidation), your information, e.g. your email address any other information collected through the Service among the items included in the sale or transfer. Your User Content remains your property. At a possible transfer of all or parts of the company, the buyer or acquirer is basically obliged to comply with the provisions of this policy on the protection of personal data.

 

Deletion of your personal data

When you as a user have downloaded the WHOHOW app and created your profile via social sign-ons, from either Facebook, Google or Apple, it is important to point out that your data will not disappear if you delete the app on your device. If you wish to delete all data and traces of your presence on the app, please contact: support@who-how.com.

Information that WHOHOW receives about you may be kept for a longer period than stated in this privacy policy, if a legal request or obligation has been made by one of the above authorities, if a public inquiry has otherwise been requested, investigating a possible violation of WHOHOW’s terms or policies or otherwise to prevent harm, fraud and other illegal activities.

 

How can you protect your personal data yourself?

To ensure the highest possible security, WHOHOW must make you aware that you are responsible at all times for keeping your own individual password a secret and your account information and for controlling access to e-mails between you and WHOHOW. 

Your rights

According to the data protection regulation, you have a number of rights in relation to WHOHOW’s processing of your personal data. You have, among other things, the right to access the information that is processed about you, to know the purpose of the processing, to whom the information is disclosed, how long the information is stored or the criteria used to determine the period of time, to object to the processing of information about you, to object against the use of your personal data for direct marketing/profiling, to demand correction, deletion or blocking of incorrect or misleading information and in certain cases, at your request, to receive your personal data in a structured, commonly used and machine-readable format and to have transferred this personal data from one data controller to another without hindrance. You can read more about your rights in the Data Protection Authority’s guidance on the rights of data subjects, which can be found at www.datatilsynet.dk.

The right to withdraw consent

You have the right to withdraw your consent to the processing of your personal data at any time. You can do this by contacting us at: support@who-how.com.

If you choose to withdraw your consent, it does not affect the legality of WHOHOW’s processing of your personal data based on your previously communicated consent and up to the time of withdrawal. If you withdraw your consent, it therefore only takes effect from this point.

WHOHOW must, in turn, make you aware that your use of the service requires your consent, as stated above.

 

What happens to your data when you delete your account?

After your account has been closed or deactivated, WHOHOW, its affiliates and WHOHOW’s service providers will store your personal information (including your profile information) and your user content for a period of up to 6 months for backup, archiving and/or control purposes, after which all data will be deleted or anonymised.

If you have purchased one of WHOHOW’s subscriptions, the information in connection with your purchases is stored for up to 10 financial years after the purchase, cf. the Accounting Act.

Your user information and personally sensitive data are also deleted or anonymised when there is no longer considered to be a legitimate need to store your personal data.

 

How to contact us about a deceased user

In the event of a WHOHOW’s users death, please contact us at support@who-how.com. WHOHOW typically handles inquiries of this type via e-mail. If WHOHOW needs additional information, WHOHOW will contact you at the email address you provided in your request.

 

Changes to WHOHOW’s privacy policy

WHOHOW reserves the right to make changes or updates to this privacy policy from time to time. WHOHOW therefore encourages you to review the policy periodically. WHOHOW will notify you of any changes or updates, in the circumstances where these are deemed to be material. With your continued use of WHOHOW’s application or service generally, following changes to the Privacy Policy, you accept those changes.

You accept that WHOHOW has the right to notify you of updated Terms by posting them on the Service, and that if you use the Service after the effective date of the updated Terms, you accept the updated Terms. The updated terms will be effective when they are posted, or on any specified date that may be specified in the updated terms, and will apply to your use of the service from that time.

The effective date for these terms is 25 May 2018. These terms were originally written in Danish. In the event of a conflict between the Danish version and a possibly translated version, the Danish version shall prevail.

  

Complaints

If you wish to complain about the processing of your personal data, you can contact WHOHOW. If you do not agree with WHOHOW’s response to your complaint, you can lodge a complaint with your national supervisory authority, cf. Article 77 of the Personal Data Regulation. In Denmark, the supervisory authority is the Danish Data Protection Authority. You will find the Data Protection Authority’s contact information at www.datatilsynet.dk. You also have the option of bringing the matter before the national courts. However, see WHOHOW’s terms of use regarding choice of law and venue.

The effective date for these terms of use is 25 May 2018. These terms of use were originally written in Danish. In the event of a conflict between the Danish version and any translated version, the Danish version shall prevail.