1. Information We Collect

The information we collect depends on how you use Whisprice.

1.1 Account and Profile Information

When you create or use a Whisprice account, we may process information such as:

• your name;

• email address;

• account identifier;

• login provider;

• profile picture;

• account creation and login information; and

• account settings and preferences.

Whisprice currently uses supported third-party authentication providers, such as Apple and Google, for account registration and authentication.

We do not receive or store your Apple or Google password.

The information made available to us by your authentication provider depends on the provider, your settings and the permissions you grant.

1.2 Product and Tracking Information

When you use Whisprice’s product features, we may process:

• product URLs you submit;

• products you track;

• wishlist products;

• product-tracking relationships;

• tracking dates and status;

• product notes;

• product ratings;

• collections and custom collection names;

• notification settings associated with products; and

• other information necessary to provide product-tracking functionality.

Whisprice also collects and generates product-related information independently of your account, including product details, detected prices and historical price observations.

1.3 Saved Purchase Information

If you use Whisprice’s saved-purchase or savings features, we may process information you provide about purchases, such as:

• product information;

• purchase date;

• purchase price; and

• information needed to calculate or display savings and related insights.

1.4 Subscription Information

If you purchase a Whisprice subscription through the Apple App Store or Google Play, payments are processed by the relevant app store.

Whisprice does not directly receive or store your full payment-card details.

We may receive and process information necessary to administer your subscription, such as:

• subscription plan or entitlement;

• subscription status;

• app-store platform;

• purchase or transaction identifiers;

• renewal or expiry information; and

• information necessary to verify access to paid features.

We use subscription-management service providers where necessary to administer these entitlements.

1.5 Device, App and Technical Information

When you use Whisprice, we may process technical information such as:

• device and operating-system information;

• browser information;

• app version;

• language or locale information;

• diagnostic information;

• crash and error information;

• technical identifiers;

• notification tokens;

• Service usage events; and

• other information reasonably necessary to operate, secure and diagnose the Service.

Where we use your IP address to determine your country, the IP address is processed for that purpose and we store the derived country rather than retaining the IP address as part of your Whisprice account information.

Technical infrastructure and third-party service providers may nevertheless process network information, including IP addresses, as reasonably necessary to provide, secure or diagnose their services.

1.6 Analytics Information

We use analytics and internal event information to understand how Whisprice is used and to improve the Service.

Depending on the platform and feature, this may include information about interactions with features, app or web performance, product additions, subscription events, retailer-link interactions and similar usage events.

We seek to limit analytics information to what is reasonably necessary for the relevant analytics purpose.

1.7 Notifications and Communications

If you enable notifications, we may process device or browser notification tokens, notification preferences and information necessary to determine which notifications to send.

Whisprice may send:

• price and product notifications;

• account or subscription communications;

• Service and security communications; and

• marketing or promotional communications where permitted.

Where consent or another opt-in is required for marketing communications, we will use the applicable consent or preference controls.

You can change notification permissions through your device, browser or Whisprice settings where available.

2. How We Use Your Information

We may use personal information to:

• create, authenticate and administer your account;

• provide product tracking, wishlists, collections, notes, ratings and saved-purchase features;

• check products and maintain your tracking relationships;

• provide price histories and product-related insights;

• send notifications you have enabled;

• administer free and paid plans;

• verify subscription entitlements;

• provide customer support;

• communicate with you about your account and the Service;

• provide marketing communications where permitted;

• understand how the Service is used;

• measure and improve features and performance;

• diagnose crashes, errors and technical problems;

• protect Whisprice, our users and our systems against fraud, abuse and security threats;

• enforce our Terms of Service;

• comply with legal obligations;

• establish, exercise or defend legal claims; and

• develop and improve Whisprice.

We do not use your personal information for purposes that are incompatible with the purposes for which it was collected unless permitted by applicable law.

3. Lawful Bases for Processing

Where the UK GDPR, EU GDPR or similar laws require us to identify a lawful basis, the basis depends on the purpose of the processing.

Contract

We may process information where it is necessary to provide the Service you request, including to:

• create and administer your account;

• maintain your tracked products and preferences;

• provide core Whisprice functionality;

• provide paid-plan functionality; and

• provide requested account and support services.

Legitimate Interests

We may process information where necessary for legitimate interests pursued by Whisprice or, where appropriate, another party, provided those interests are not overridden by your rights and interests.

These interests may include:

• operating and improving Whisprice;

• understanding how features are used;

• maintaining product and price information;

• measuring Service performance;

• measuring affiliate and product-feature effectiveness;

• preventing fraud and abuse;

• securing our systems;

• diagnosing technical problems;

• enforcing our Terms; and

• protecting our legal rights.

Where users may be children, we take into account the additional protection their interests and rights require.

Consent

We rely on consent where applicable law requires it, including for certain marketing communications, optional storage/access technologies or other optional processing.

Where processing is based on consent, you can withdraw that consent at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn.

Legal Obligations

We may process information where necessary to comply with applicable legal, regulatory, accounting or other legal obligations.

Other lawful bases may apply where permitted or required by applicable law.

4. Product Data and Price History

An important distinction exists between your personal relationship with a product and Whisprice’s independently maintained product information.

For example, your account may contain information showing that you track a particular product, have placed it in a collection, have written a note about it or have rated it.

Separately, Whisprice may maintain information about the product itself, such as:

• its product URL;

• product characteristics;

• retailer information;

• detected prices;

• price observations; and

• historical price information.

If you remove a product or delete your account, we remove or disassociate your personal relationship with that product in accordance with this Privacy Policy.

This does not necessarily require deletion of independently maintained product information or historical price observations from Whisprice’s product database where that information is not personal information relating to you or may otherwise lawfully be retained.

If no Whisprice user continues tracking a product, active price checking for that product may stop while existing product and historical price information remains.

5. Affiliate Links and Affiliate Analytics

Whisprice may participate in affiliate programmes.

When you submit or follow a retailer URL, Whisprice may convert or redirect the URL into an affiliate-enabled link containing an identifier associated with Whisprice as the publisher.

If you follow such a link and make a qualifying purchase or take another qualifying action, Whisprice may receive a commission or other compensation.

Whisprice does not intentionally add your email address, profile name or similar Whisprice profile information to the retailer link.

However, retailers, affiliate networks and other third parties may process information when you follow their links, including through cookies or similar technologies, in accordance with their own privacy policies.

Affiliate measurement

Whisprice may receive information about affiliate interactions or conversions, such as:

• referral or click information;

• merchant information;

• conversion status;

• transaction or attribution identifiers;

• transaction value or similar commercial information;

• commission information; and

• timing information.

Where reasonably necessary for attribution, fraud prevention or internal analytics, we may temporarily associate affiliate interaction or conversion information with a Whisprice account or interaction.

Our aim is not to maintain a permanent identifiable history of users’ off-platform purchases. Where user-level association is no longer reasonably necessary for the relevant purpose, we may aggregate or de-identify the information so that it is no longer maintained as a user-level purchase history.

Affiliate partners and retailers may act as independent controllers for information they collect through their own websites, cookies or systems.

6. Automated and AI-Assisted Product Processing

Whisprice may use automated systems, machine learning or artificial intelligence to assist with product-related functions such as:

• extracting product information from webpages;

• structuring product information;

• identifying product characteristics;

• categorising or matching products;

• processing product images or descriptions;

• quality checking; and

• supporting product recommendations or related functionality.

The information submitted to these systems is product or webpage information needed for these purposes, such as product URLs, webpage content, product titles, descriptions, images and pricing information.

Whisprice does not use this process to send your email address, profile information, private product notes, product ratings or private collection names to AI providers for these product-processing purposes.

These systems are used to process product information rather than to make decisions about your legal rights, subscription eligibility or account status solely on the basis of automated profiling.

7. Cookies, Local Storage and Similar Technologies

Whisprice’s website and web application may use browser storage and similar technologies.

For example, the web application uses local storage where necessary to support authentication and maintain the functionality of your logged-in session.

We may also use cookies, local storage, software development kits or similar technologies for purposes such as:

• authentication and security;

• remembering settings;

• analytics;

• performance monitoring;

• error diagnosis; and

• other functionality described in this Privacy Policy.

Technologies that are strictly necessary to provide a feature you request may operate as necessary for that feature.

Where applicable law requires consent for non-essential analytics or similar technologies, we will seek the required consent or provide applicable controls.

Third-party websites that you visit through Whisprice, including retailers and affiliate partners, may use their own cookies and similar technologies. Their practices are governed by their own privacy information.

8. Analytics, Diagnostics and Service Providers

We use third-party service providers to operate, analyse, secure and maintain Whisprice.

These currently include providers supporting functions such as:

Amazon Web Services (AWS) — primary hosting and infrastructure. Whisprice’s primary server infrastructure is hosted in Frankfurt, Germany.

Firebase / Google services — functionality that may include authentication-related services, notifications, analytics, file or profile functionality, diagnostics and other supporting services used by Whisprice.

Google Analytics — Service analytics where enabled.

Elastic — monitoring, search, logging or related infrastructure functions.

Sentry — error, crash and performance monitoring.

RevenueCat — subscription entitlement and subscription-management functionality.

We may also use service providers for authentication, communications, affiliate functionality, infrastructure, customer support, security and product processing.

These providers process information on our behalf or, in some circumstances, as independent controllers for their own processing.

We do not authorise processors to use Whisprice personal information for unrelated purposes contrary to our instructions and applicable law.

Our service providers may change as Whisprice develops. We assess the information they need and the role they perform when determining how personal information is shared.

9. When We Share Information

We may disclose personal information:

• to service providers that process information to operate Whisprice;

• to Apple, Google and related platforms where necessary for authentication, subscriptions or platform functionality;

• to affiliate and retailer-related services as described in this Privacy Policy;

• where you direct or request us to disclose information;

• where reasonably necessary to protect Whisprice, our users or others against fraud, abuse or security threats;

• where necessary to establish, exercise or defend legal rights;

• where required by law, regulation, court order or a lawful request from a competent authority; or

• in connection with a merger, acquisition, financing, restructuring or sale of all or part of Whisprice’s business, subject to appropriate safeguards and applicable law.

We do not disclose private notes, ratings or collection names to retailers merely because you follow a retailer or affiliate link.

10. International Data Transfers

Whisprice LTD is based in the United Kingdom and uses service providers that may operate infrastructure or personnel in different countries.

Our primary server infrastructure is currently hosted in Frankfurt, Germany, but this does not mean that every service provider or every processing operation necessarily occurs only in Germany or the European Economic Area.

Where personal information is transferred internationally and applicable data-protection law requires safeguards for that transfer, we use an applicable lawful transfer mechanism.

Depending on the circumstances, these may include adequacy regulations or decisions, approved contractual safeguards or another mechanism permitted by applicable law.

You may contact us at support@whisprice.com if you would like further information about safeguards relevant to your personal information.

11. How Long We Keep Information

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected and for legitimate legal, security, accounting, fraud-prevention and dispute-resolution purposes.

Different information may therefore have different retention periods.

In determining how long to retain information, we consider factors including:

• whether your account remains active;

• whether the information is needed to provide the Service;

• the nature and sensitivity of the information;

• security and fraud-prevention needs;

• applicable limitation periods;

• accounting, tax or legal requirements;

• whether the information remains in backups or technical logs; and

• whether information can instead be aggregated or de-identified.

We do not automatically delete a Whisprice account merely because it has not been used for 12 months.

Whisprice may separately suspend or reduce active product tracking for inactive accounts without deleting the account.

Account deletion

When you delete your Whisprice account, we aim to remove the active account and disassociate its personal product relationships promptly, normally within approximately one day.

This does not mean that every copy of every item of information is guaranteed to disappear from every system within 24 hours.

Limited information may remain for longer where reasonably necessary in:

• backups;

• security and technical logs;

• subscription or transaction records;

• fraud or abuse-prevention records;

• records required by law; or

• information necessary to establish, exercise or defend legal claims.

Such information is retained only for as long as reasonably necessary for the applicable purpose.

Account deletion also does not require deletion of non-personal product catalogue information and historical price observations as explained in Section 4.

Deleting your Whisprice account does not necessarily cancel an Apple App Store or Google Play subscription. You should separately manage an active subscription through the relevant app store.

12. Security

We use technical and organisational measures designed to protect personal information against unauthorised access, disclosure, alteration, loss or misuse.

These measures may include access controls, authentication, infrastructure security and other safeguards appropriate to the nature of the information and processing.

No internet-based service can guarantee absolute security. You should also take reasonable steps to protect access to your device, authentication provider and Whisprice account.

13. Children

Whisprice is a general-audience Service and is not intended for children under 13.

You must be at least 13 years old to use Whisprice.

Whisprice does not currently ask users to provide their date of birth as part of ordinary account registration and does not represent that it independently verifies the age of every user.

If you are under the age at which you may independently agree to the relevant processing or use the Service under applicable law, parental or guardian involvement may be required.

If we learn that an account belongs to a child under 13 or that personal information has been collected in circumstances where additional parental authorisation is legally required, we may restrict or delete the account or information and take other appropriate steps.

Parents or guardians who believe that a child has provided personal information to Whisprice inappropriately can contact us at support@whisprice.com.

14. Marketing

Where permitted by law, Whisprice may send marketing communications about features, shopping information, guides, deals, promotions or related Whisprice content.

Where consent is required, we will send such communications only after the required opt-in.

You can withdraw consent or change your marketing preferences using the unsubscribe mechanism or relevant settings provided with the communication or Service.

Withdrawing from marketing does not prevent us from sending necessary Service, account, security or subscription communications.

15. Your Privacy Rights

Depending on where you live and the law that applies to our processing, you may have rights concerning your personal information.

These may include rights to:

• request access to personal information we hold about you;

• request correction of inaccurate information;

• request deletion of information;

• restrict certain processing;

• object to certain processing;

• receive certain information in a portable format;

• withdraw consent where processing is based on consent; and

• complain to an applicable data-protection authority.

These rights are not absolute and may depend on the circumstances and applicable law.

You can also manage or delete certain information directly through Whisprice where the relevant controls are available.

To exercise a privacy right that cannot be handled through the Service, contact support@whisprice.com.

We may need to take reasonable steps to verify your identity before fulfilling a request.

Right to object

Where we rely on legitimate interests to process your personal information, you may have the right to object to that processing based on your particular situation.

You may also object to the use of your personal information for direct marketing at any time.

16. UK and EEA Users

If UK data-protection law applies to our processing, Whisprice LTD is the relevant controller described in this Privacy Policy.

You may have the rights described in Section 15 under the UK GDPR and Data Protection Act 2018.

If you believe we have not handled your personal information appropriately, you may have the right to complain to the UK Information Commissioner’s Office (ICO).

If EU/EEA data-protection law applies to you, you may also have the right to complain to the competent supervisory authority in your country.

We encourage you to contact us first at support@whisprice.com so that we have an opportunity to address your concern.

17. Users in Other Countries

Whisprice may be available in countries outside the United Kingdom and European Economic Area.

Depending on where you live, local privacy laws may provide additional rights concerning access, correction, deletion, consent, objection, portability, complaints or the use and disclosure of personal information.

Where those laws apply to Whisprice, we will honour mandatory privacy rights and obligations applicable to our processing.

Nothing in this Privacy Policy is intended to limit a privacy right that applicable law does not permit us to limit.

18. California and Other US Privacy Rights

Residents of certain US states may have additional privacy rights under applicable state law.

Depending on the law and whether its applicability thresholds are met, these rights may include requesting:

• information about categories or specific pieces of personal information collected;

• correction of inaccurate information;

• deletion of certain information;

• a portable copy of certain information;

• information about categories of recipients; or

• an opt-out from certain uses or disclosures where applicable.

Whisprice does not operate a conventional third-party advertising business based on selling Whisprice account profiles to advertisers.

However, privacy laws may use technical definitions of terms such as “sale,” “sharing” or “targeted advertising” that do not necessarily correspond to the ordinary meaning of those words. Affiliate links, analytics and similar technologies are therefore described in this Privacy Policy according to how Whisprice actually uses them rather than relying only on broad labels.

Where applicable law gives you an opt-out right in relation to a particular processing activity, Whisprice will provide the legally required method of exercising that right.

You may contact us at support@whisprice.com regarding applicable US privacy rights.

19. Changes to This Privacy Policy

We may update this Privacy Policy as Whisprice changes, our service providers change, or legal requirements develop.

When we make a material change, we will take reasonable steps to bring it to your attention where required or appropriate.

The “Last updated” date at the top of this Privacy Policy indicates when it was most recently revised.

We encourage you to review the Privacy Policy periodically.

20. Contact Us

For privacy questions, requests or complaints, contact:

Whisprice LTD
Company number: 17163470
71–75 Shelton Street
Covent Garden
London, WC2H 9JQ
United Kingdom

Email: support@whisprice.com