Privacy Policy

Effective Date: November 23, 2024​

​

1. Introduction

The Good App FZCO ("we", "us", or "our"), registered at Dubai Silicon Oasis, DDP, Building A1, Dubai, United Arab Emirates, operates the mobile application Wispl ("Service"), which allows users to create and fulfill their wishes, interact with other users, and share moments. This Privacy Policy informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service.

 

2. Information Collection

2.1. Personal Data

When using the Wispl application, you must be over 17 years old. We collect and process the following personal data:

• Email Address: Obtained during registration via Apple ID or Google Account.

• Username: A unique display name within the application.
  Please note that your username cannot be changed through the application interface after registration. If you need to change it, please contact us as described below.

• Your First and Last Name: Your real name.
  These cannot be changed through the application interface. To update this information, please contact us.

• Date of Birth: Used to verify your age and ensure you meet the minimum age requirement to use our Service.
  This cannot be changed through the application interface. If you need to correct it, please contact us.

• Gender: For personalizing your experience.

• City: To display relevant wishes and events in your area.

• Profile Photo: One mandatory photo for your profile.

• Video Introduction: An "about yourself" video that you record using the camera. You can change it at any time by recording a new video, and the previous video will be deleted.

  • Purpose of Collection: The video introduction is used to personalize your profile and enhance interactions with other users.

  • Modification and Deletion: You can change the video introduction at any time by recording a new video. The previous video will be permanently deleted.

  • Access: The video introduction is displayed to other users within the functionality of the application.

2.2. Additional Data (Optional)

• Additional Photos: You may upload additional photos to provide a more complete representation of yourself.

• Biography ("About Me"): Textual information about you, which you can fill out and enhance using artificial intelligence.

2.3. User-Generated Data

• Wishes: Text descriptions of your wishes, photos, selected wish type (paired, group, personal), event city, wish category.

• Moments: Photos, videos, or text content showing how you fulfill your wishes.

• Chat Messages: Content of messages (text, photos, videos) exchanged in chats.

• Applications and Responses: Information about applications you submit to participate in other users' wishes and applications received for your wishes.

• Blocks and Complaints: Information about users or content you have blocked or reported.

2.4. Usage Data

• Log Files: Information about interactions with the application, including access times and dates, features used, and app sections visited.

• Technical Data: Information about your device, including device model, operating system version, unique device identifiers.

2.5. Geolocation Data

We may collect precise location data with your explicit consent. This data is used for:

• Providing location-based services, such as displaying wishes and events near you.

• Personalizing content and enhancing your user experience.

Permission Management: You can manage or revoke access to geolocation data at any time through your device settings or within the app (if available).

2.6. Data from Third-Party Sources

• Apple ID and Google Account: When registering through these services, we receive your email address and may access your name and profile photo if you grant such permission.

2.7. Data Collection Technologies and Third-Party Services

Our application uses certain technologies and third-party services to collect and analyze data to improve our Service, ensure its functionality, and enhance security.

2.7.1. Google Firebase

We use Google Firebase, a set of services provided by Google LLC, which is an integral part of our application and necessary for its operation.

Firebase services we use include:

• Firebase Authentication: For managing user registration and authentication.

• Firebase Realtime Database / Firestore: For real-time data storage and synchronization.

• Firebase Analytics: For collecting app usage data to improve its performance and user experience.

• Firebase Crashlytics: For tracking and fixing app crashes and errors.

• Firebase Cloud Messaging: For sending push notifications.

• Firebase Storage: For storing user content such as photos and videos.

Collected data may include:

• Personal Data: Email address, username, name, date of birth, gender, city, profile photo, and additional information you provide.

• Usage Data: Information about how you interact with our application.

• Technical Data: Device information, including device model, operating system version, unique device identifiers.

• Diagnostic Data: Crash reports, errors, and other diagnostic information.

How Firebase Uses Data:

Data collected through Firebase is used by us to:

• Provide core app functions: Registration, authentication, content storage, and sharing.

• Improve app performance: By analyzing usage data, we can enhance the app's functionality and performance.

• Ensure security: Monitoring and preventing fraudulent activity.

• Send notifications: Informing you about important events and updates.

Third-Party Data Collection:

While we do not transfer or sell your personal data to third parties without your consent, third-party services (such as Google Firebase) used in our application may collect data in accordance with their own privacy policies. These services collect data necessary for their operation and are responsible for processing this data under their policies.

Mandatory Data Collection:

Data collection and processing through Firebase are necessary for us to provide our services. If you disagree with this, we will be unable to grant you access to the app's functionality.

Links to Google's Privacy Policy:

• Google Privacy Policy: https://policies.google.com/privacy?hl=en 

• Firebase Privacy and Security: https://firebase.google.com/support/privacy?hl=en

2.8. Access to Device Features

Our application may request access to the following features of your device:

2.8.1. Camera and Photos

• Purpose of Access: We request access to your camera and photo library so that you can:

  • Upload profile and additional photos.

  • Create and share moments.

  • Send photos and videos in chats.

• Consent and Management: Access is granted only with your explicit consent. You can manage this permission at any time through your device settings.

• Revoking Access:

  • iOS: Settings > Privacy > Camera/Photos > Wispl.

  • Android: Settings > Apps > Wispl > Permissions > Camera and Storage.

2.8.2. Microphone

• Purpose of Access: We request access to your microphone so that you can:

  • Record and send voice messages in chats.

  • Create audio content for video moments.

• User Consent: Access is granted only with your explicit consent when prompted.

• Revoking Access:

  • iOS: Settings > Privacy > Microphone > Wispl.

  • Android: Settings > Apps > Wispl > Permissions > Microphone.

2.8.3. Push Notifications

• Purpose of Use: We use push notifications to:

  • Inform you about new messages, applications, and updates.

• User Consent: You may agree to receive push notifications or change settings at any time via the app or device settings.

• Managing Notifications:

  • Within the App: Configure notification preferences in the app's settings section.

  • iOS: Settings > Notifications > Wispl.

  • Android: Settings > Apps > Wispl > Notifications.

2.8.4. Geolocation

• Purpose of Access: We request access to your location to:

  • Provide location-based services (e.g., displaying wishes and events near you).

• Consent and Management: Access is granted only with your explicit consent. You can manage this permission at any time through your device settings or within the app (if available).

• Revoking Access:

  • iOS: Settings > Privacy > Location Services > Wispl.

  • Android: Settings > Apps > Wispl > Permissions > Location.

2.9. Managing Permissions

You can manage or revoke access to the following features through your device settings or within the app (if available):

• Camera and Photos

• Microphone

• Geolocation

• Push Notifications

• On iOS Devices:

  • Go to Settings > Privacy, select the desired feature, and find Wispl to change permissions.

• On Android Devices:

  • Go to Settings > Apps (or Application Manager), find Wispl, select Permissions, then enable or disable access to the relevant features.

Please Note: Revoking access to certain features may limit the app's functionality and your user experience.

 

3. Use of Collected Information

3.1. Providing and Improving the Service

We use the collected data to:

• Create and Manage Your Account: Process registration data to provide access to the app.

• Provide Core Features: Allow you to create wishes, share moments, and interact with other users through chats and applications.

• Personalize Your Experience: Use your data to display relevant content and recommendations.

• Process Your Requests: Respond to your questions, complaints, comments, and provide user support.

• Age Verification: Use your date of birth to verify compliance with the minimum age of 17 and ensure adherence to our policy regarding minors.

3.2. Communicating with You

• Notifications: Send push notifications and in-app messages about new applications, messages, updates, and other events.

• Marketing Messages: With your consent, send information about new features, offers, and events.

3.3. Ensuring Security and Enforcement

• Preventing Fraud and Unauthorized Access: We may use your data to authenticate users and prevent unauthorized access to accounts and services. This includes monitoring and analyzing activity to detect suspicious or illegal actions.

• Compliance with Terms of Use: Process data to ensure adherence to our rules and policies.

• Legal Requirements: Use data as necessary to comply with laws, regulations, and legal processes.

3.4. Analytics and Research

• Usage Analysis: Use aggregated and anonymized data to understand usage trends and user preferences.

• Product Improvement: Develop new features and enhance existing ones based on data analysis.

3.5. Use of Data by Third-Party Services

Data transmitted to third-party services is limited to what is necessary for them to provide their services. We ensure that only essential data is transmitted to ensure functionality such as analytics, notifications, and infrastructure technical support.

3.6. Data Storage

• Retention Periods: We retain your data as long as your account is active or as necessary to provide services.

• Criteria for Determining Retention Periods:

  • Service Provision Necessity: Data is retained as long as needed to fulfill the purposes described in this policy.

  • Legal Obligations: Some data may be retained longer if required by law.

  • User Requests: Upon your request, we may delete or anonymize your personal data unless its retention is required by law.

 

4. Disclosure to Third Parties

4.1. Service Providers

We may employ third-party companies and individuals ("Service Providers") to facilitate our Service, provide the Service on our behalf, perform Service-related tasks, or assist us in analyzing how our Service is used.

We enter into appropriate Data Processing Agreements with Service Providers, if applicable, to ensure they process your personal data in accordance with applicable data protection laws.

Our Service Providers are obligated to:

• Maintain the confidentiality of your personal data.

• Use your data only to provide services to us.

• Protect your data in accordance with applicable laws and our Privacy Policy.

Our Service Providers may include, but are not limited to:

• Google Firebase: We use Firebase to provide technical infrastructure, data storage, analytics, notifications, and app security. Firebase acts as a data processor on our behalf and is committed to protecting your data in accordance with the Google Privacy Policy.

Updating the List of Service Providers

Please note that our list of Service Providers may periodically update as we engage new providers or discontinue relationships with existing ones. We commit to notifying you of any significant changes in the list of Service Providers that may affect the processing of your personal data.

Notification of Changes

• Privacy Policy Updates: Any changes to our list of Service Providers will be reflected in the updated version of this Privacy Policy in accordance with Section 11. Changes to the Privacy Policy.

• Additional Notice: In case of significant changes that may substantially affect the processing of your personal data, we will provide you with additional notice as specified in Section 11.2. Notification of Changes.

• Your Choice: If you disagree with changes regarding new Service Providers, you have the right to discontinue using our Service or contact us to discuss your concerns.

4.2. Legal Requirements and Prevention of Violations

We may disclose your personal data in the following cases:

• Compliance with Law: If required by law, court order, or at the request of government authorities.

• Prevention of Illegal Activities: If you violate our Terms of Use or engage in illegal activities, we may provide your data to relevant authorities for investigation.

• Protection of Rights and Safety: To protect the rights, property, or safety of Wispl, our users, or the public.

4.3. Business Transactions

In the event we are involved in a merger, acquisition, or asset sale, your personal data may be transferred to the new owner or transaction partner. We will notify you before your personal data is transferred and becomes subject to a different Privacy Policy.

4.4. User Consent

We may disclose your personal data to third parties if you have given your explicit consent. You have the right to withdraw your consent at any time by contacting us via the contact information provided in Section 12. Contact Information of this Privacy Policy.

4.5. Aggregated and Anonymous Data

We may share aggregated or anonymized data that cannot be used to identify you with our partners, advertisers, or for analytics and research purposes. This data helps us improve our Service and provide more relevant content.

4.6. International Data Transfer

Your data, including personal data, may be transferred to and stored on servers located outside your state or national jurisdiction, where data protection laws may differ from those in your jurisdiction.

We store and process data on servers worldwide to ensure high availability and performance of our Service. When transferring data outside the European Economic Area (EEA), we take appropriate measures to ensure adequate protection of your personal data in accordance with applicable data protection laws.

Mechanisms to Ensure Adequate Data Protection:

• Standard Contractual Clauses (SCC): We use SCCs approved by the European Commission as a legal mechanism for transferring data to countries that do not provide an adequate level of data protection.

• Adequacy Decisions: For countries recognized by the European Commission as providing an adequate level of data protection, we rely on such decisions.

• Additional Safeguards: We implement additional technical and organizational measures to protect your data, such as encryption and strict access controls.

By using our Service, you agree to the transfer of your personal data in accordance with this Privacy Policy.

4.7. No Sale of Data

We never sell, trade, or transfer your personal data to third parties for their marketing or commercial purposes.

4.8. Third-Party Sites and Services

Our Service may contain links to third-party websites or services not operated by us. We do not control and are not responsible for the content, privacy policies, or practices of third-party websites or services. We recommend that you review the privacy policies of every third-party site you visit.

4.9. Data Security

We strive to protect your personal data and use security measures provided by our Service Providers, such as Google Firebase. Firebase ensures:

• Data Encryption: Your data is encrypted during transmission between your device and Firebase servers and at rest on Firebase servers.

• Access Control: We use Firebase security rules to control data access, ensuring that only authorized users have access to relevant information.

• Compliance with Security Standards: Firebase complies with international security standards and is certified under ISO 27001 and SOC 2.

You can learn more about Firebase's security measures at the following links:

• Firebase Security: https://firebase.google.com/support/privacy?hl=en

• Firebase Security Documentation: https://firebase.google.com/docs/rules?hl=en

Despite our efforts to protect your personal data, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that your account security has been compromised), please immediately contact us at amir@wispl.app.

4.10. Policy Regarding Minors

Our Service is not intended for individuals under 17 years of age. We do not knowingly collect personal data from individuals under 17. If we become aware that we have collected personal data from a person under 17, we will take steps to delete that information from our servers.

 

5. Payment Information

5.1. In-App Purchases

5.1.1. Optional Paid Services

Our application offers optional in-app purchases, such as the subscription Wispl Member (1 month), which provides access to additional features and content.

5.1.2. Payment Processing

All payments for in-app purchases are processed through third-party platforms — App Store (for iOS devices) and Google Play (for Android devices). We do not collect or store your payment details, such as name, address, or payment card information.

5.2. Data Collection and Use

5.2.1. No Collection of Payment Information

Since payments are processed through App Store and Google Play, we do not receive your personal payment data.

5.2.2. Transaction Information

We may receive information from App Store or Google Play that a purchase has been made, including the type of purchase and date, but this information does not contain personal payment data.

5.3. Third-Party Payment Systems

5.3.1. App Store and Google Play Privacy Policies

Your interactions with App Store and Google Play are governed by their own privacy policies and terms of use. We recommend reviewing their policies to understand how they process your data:

• App Store (Apple Inc.):

  • Privacy Policy: https://www.apple.com/legal/privacy/

  • Terms of Use: https://www.apple.com/legal/internet-services/itunes/us/terms.html

• Google Play (Google LLC):

  • Privacy Policy: https://policies.google.com/privacy?hl=en 

  • Terms of Use: https://play.google.com/intl/en_us/about/play-terms/ 

5.4. Transaction Security

5.4.1. Security Measures of Third-Party Platforms

All payment transactions are securely processed by App Store and Google Play. We do not have access to your payment data and rely on these platforms to ensure the security of your transactions.

5.4.2. Limitation of Liability

We are not responsible for the processing of your payments and transactions through App Store or Google Play. Any issues related to payment transactions should be directed to the support service of the respective platform.

5.5. Changes to In-App Purchases

5.5.1. Updates and Changes

We may modify, suspend, or discontinue providing in-app purchases at any time. Prices and availability of in-app purchases may change without prior notice.

 

6. Account Blocking and Data Retention

6.1. Blocking for Policy Violations

6.1.1. Violation of Terms

We reserve the right to suspend or block your account immediately, without prior notice or liability, for any reason, including but not limited to your violation of our Terms of Use, Privacy Policy, or applicable laws.

6.2. Data Retention and Deletion

6.2.1. Data Deletion

In the event your account is blocked, we may delete or anonymize your personal data, considering our legal obligations and legitimate interests.

6.2.2. Compliance with Legal Obligations

We will retain and use your information as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.

6.3. User Rights

6.3.1. Access to Personal Data

Even if your account is blocked, you retain the rights outlined in Section 8. User Rights, including the right to access your personal data unless otherwise provided by law.

6.3.2. Exceptions

We may refuse to provide access to your data or fulfill your requests if required by law or necessary to protect the rights and freedoms of others.

 

7. Use of Tracking Technologies and Device Identifiers

7.1. In-App Tracking Technologies

We use certain technologies to collect information about how you interact with our application. This helps us improve our Service, provide you with a personalized experience, and ensure app security.

7.2. Types of Technologies Used

• Unique Device Identifiers: We may collect unique identifiers of your device, such as IDFA (Identifier for Advertisers) on iOS or Advertising ID on Android, for analytics and content personalization.

• Local Storage: Our application may store information locally on your device to ensure its functionality, such as saving your settings and preferences.

• Third-Party SDKs and Libraries: We use third-party SDKs, such as Google Firebase, which may collect information about app usage and your activity within it.

7.3. Purposes of Using Technologies

• Analytics: Understanding how users interact with our app to improve its functionality and performance.

• Personalization: Providing you with content and recommendations based on your interests and app behavior.

• Security: Detecting and preventing fraudulent or malicious activity, ensuring the security of your account.

7.4. Managing Technologies

You can manage certain technologies through your device settings:

• Managing Advertising Identifiers:

  • iOS: Go to Settings > Privacy > Advertising and enable Limit Ad Tracking.

  • Android: Go to Settings > Google > Ads and enable Opt out of Ads Personalization.

• Disabling Access to Device Features: Manage app permissions to access certain device features through your device settings.

7.5. Third-Party Technologies

Some of our partners may use their own technologies to collect and process data about your activity within the app. We recommend reviewing the privacy policies of these third-party services:

• Google Firebase: Google's Privacy Policy is available at: https://policies.google.com/privacy?hl=en

7.6. Disclaimer

Please note that disabling or limiting certain tracking technologies may affect the app's functionality and the quality of services provided.

 

8. User Rights

We respect your rights regarding your personal data and strive to ensure their implementation in accordance with applicable laws, including the General Data Protection Regulation (GDPR). Please note that some rights may be limited in accordance with the law and our legitimate interests.

8.1. Right of Access

You have the right to request confirmation as to whether we process your personal data and obtain a copy of this data.

8.1.1. Data Provision Limitations

When fulfilling your request, we are obliged to ensure that the provision of data does not infringe the rights and freedoms of others or contradict our legal obligations and legitimate interests. In some cases, we may refuse to provide certain information for the following reasons:

• Legal Restrictions: If disclosure is prohibited by law.

• Protection of Others' Rights: If providing data affects the rights and freedoms of third parties.

• Confidentiality and Trade Secrets: If the information contains confidential information or trade secrets.

8.2. Right to Rectification

If you believe that your personal data is inaccurate or incomplete, you have the right to ask us to correct or supplement it. We may request supporting documents to verify the accuracy of the provided information.

8.3. Right to Erasure ("Right to be Forgotten")

You may request the deletion of your personal data under the following conditions:

• Data is no longer needed for the purposes for which it was collected.

• You have withdrawn your consent, and there are no other legal grounds for processing.

• You object to the processing, and there are no overriding legitimate grounds for processing.

• Data was processed unlawfully.

• Deletion is required to comply with a legal obligation.

8.3.1. Exceptions

Your right to deletion may be limited if data processing is necessary for:

• Compliance with legal obligations.

• Establishment, exercise, or defense of legal claims.

• Public interests in the area of public health, archiving, scientific or historical research, or statistical purposes.

8.4. Right to Restrict Processing

You have the right to request the restriction of processing your data in certain cases. We will retain your data but limit its processing in the following situations:

• You contest the accuracy of the data.

• Processing is unlawful, but you prefer restriction over deletion.

• We no longer need the data, but you require it for legal purposes.

• You have objected to processing, and verification of legitimate grounds is pending.

8.5. Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and transmit it to another controller if technically feasible and does not affect the rights and freedoms of others.

8.6. Right to Object

You may object to the processing of your personal data on grounds relating to your particular situation if processing is based on our legitimate interests. We may continue processing if we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms or if processing is necessary for legal claims.

8.7. Right to Withdraw Consent

If processing is based on your consent, you have the right to withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing before its withdrawal. Some features or services may become unavailable after consent withdrawal.

8.8. Right to Lodge a Complaint

If you believe we have violated your data protection rights, you have the right to lodge a complaint with the relevant supervisory authority.

8.9. How to Exercise Your Rights

To exercise your rights, please contact us:

• Email: amir@wispl.app

• Postal Address: Dubai Silicon Oasis, DDP, Building A1, Dubai, United Arab Emirates.

8.9.1. Request Requirements

In your request, please provide:

• Your full name and contact information.

• A detailed description of your request.

• Documents confirming your identity (if required).

8.9.2. Response Timeframes and Procedures

We will review your request and respond within 30 days of receipt. If necessary, this period may be extended by an additional 60 days considering the complexity and number of requests. In such cases, we will notify you of the extension and reasons for the delay.

8.9.3. Refusal to Fulfill Request

In some cases, we may refuse to fulfill your request, in whole or in part, if permitted by law. We will provide you with an explanation of the reasons for refusal and information about your possible actions, including the right to lodge a complaint with a supervisory authority.

8.10. Limitations and Conditions

Your rights may be limited in accordance with applicable law. We may retain and continue processing your data if necessary for:

• Compliance with legal obligations.

• Protection of our legitimate interests.

• Establishment, exercise, or defense of legal claims.

8.10.1. Protection of Others' Rights and Freedoms

We are obliged to ensure that the exercise of your rights does not affect the rights and freedoms of others. If necessary, we may limit or refuse to provide information to protect the rights of third parties.

8.10.2. Trade Secrets and Confidentiality

We may refuse to provide information if it may disclose trade secrets, intellectual property, or violate the confidentiality of information.

 

9. Legal Grounds for Processing Personal Data

We process your personal data on the following legal grounds:

9.1. Consent

We process your personal data if you have given your explicit consent. This includes:

• Marketing Messages: Sending you informational and promotional messages about our services, new features, and special offers if you have agreed to receive them.

• Access to Device Features: Using your camera, microphone, geolocation, and other device features after obtaining your permission.

• Content Personalization: Providing you with a personalized experience based on your preferences and settings if you have consented.

9.2. Performance of a Contract

Processing your personal data is necessary for the performance of a contract between you and us:

• Provision of the Service: Creating and managing your account, providing access to app features.

• Processing Your Actions: Allowing you to create wishes, share moments, interact with other users.

9.3. Legal Obligations

We process your personal data to comply with our legal obligations:

• Compliance with Laws: Fulfilling requirements of applicable laws, regulations, and court orders.

• Responding to Legal Requests: Providing information in response to legitimate requests from law enforcement and other government agencies.

9.4. Legitimate Interests

Processing your personal data is necessary for our legitimate interests if they are not overridden by your rights and freedoms. Our legitimate interests include:

• Improving and Developing the Service: Analyzing how users interact with our app to enhance its functionality, user experience, and overall performance.

• Ensuring Security and Fraud Prevention: Monitoring, detecting, and preventing fraudulent, unauthorized, or illegal activities to protect our users and Service.

• Communicating with Users: Sending you important information about changes to the Service, policy updates, or providing customer support and responding to your inquiries.

• Enforcing Our Terms and Policies: Ensuring compliance with our Terms of Use and other policies to maintain the integrity and security of our Service.

We conduct a thorough assessment to ensure that our legitimate interests do not override your privacy rights. You have the right to object to processing based on our legitimate interests, as described in Section 8.6. Right to Object of this Privacy Policy.

9.5. Protection of Vital Interests

In rare cases, we may process your personal data to protect your vital interests or those of another person, such as in emergency situations.

 

10. Data Retention and Deletion

10.1. Data Retention Periods

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

10.2. Criteria for Determining Retention Periods

When determining appropriate retention periods, we consider the following criteria:

• Purposes of Data Collection: How long we need the data to provide our services and fulfill our obligations to you.

• Legal Obligations: Requirements of applicable laws and regulations to retain certain types of data.

• User Consent: Whether you have consented to a longer retention period (if applicable).

• Our Legitimate Interests: Necessity of retaining data to protect our rights, resolve disputes, or comply with our contractual obligations.

10.3. Data Deletion and Anonymization

After the relevant retention periods have expired or upon your request, we will:

• Delete your personal data from our systems and records.

• Anonymize data so that it can no longer be associated with you.

10.4. Requesting Data Deletion

You have the right to request the deletion of your personal data at any time in accordance with Section 8.3. Right to Erasure ("Right to be Forgotten") of this Privacy Policy.

To do so, please contact us:

• Email: amir@wispl.app

• Postal Address: Dubai Silicon Oasis, DDP, Building A1, Dubai, United Arab Emirates.

10.5. Exceptions to Deletion

We may retain certain personal data if necessary for:

• Compliance with Legal Obligations: For example, for tax or accounting purposes.

• Establishment, Exercise, or Defense of Legal Claims: If data is needed to resolve disputes or legal proceedings.

• Ensuring Security: To prevent fraud, abuse, or violation of our Terms of Use.

• Statistical or Research Purposes: We may retain data in an anonymized form that does not identify you for statistical analysis or research. This anonymized data helps us improve our Service and develop new features.

10.6. Backup Storage

Please note that even after deleting your data from our active systems, copies of your data may remain in backup archives for a certain period due to technical reasons or to fulfill our legal obligations. We ensure the secure storage of such data and restrict access to it.

10.7. Secure Data Destruction

We take commercially reasonable measures to securely delete or destroy your personal data to prevent unauthorized access, disclosure, or use after deletion.

 

11. Changes to the Privacy Policy

11.1. Policy Updates

We may periodically update this Privacy Policy to reflect changes in our data processing practices, technologies, legal requirements, or for other reasons. The updated policy version will be posted on this page with an updated "Last Updated" date at the top of the document.

11.2. Notification of Changes

• Significant Changes: If we make significant changes to the Privacy Policy, we will notify you in advance using reasonable means, such as an in-app notification or sending an email (if you have provided an email address).

• Regular Review: We encourage you to periodically review this Privacy Policy to stay informed about our practices and any changes.

11.3. Consent to Changes

By continuing to use our Service after the updated Privacy Policy takes effect, you agree to the changes and updated terms.

 

12. Contact Information

If you have any questions, comments, or concerns regarding this Privacy Policy or the processing of your personal data, please contact us:

• Email: amir@wispl.app

• Postal Address: Dubai Silicon Oasis, DDP, Building A1, Dubai, United Arab Emirates.

• Other Contact Details: Feedback form on the website wispl.app

 

13. Data Security

13.1. Our Security Measures

We take reasonable organizational, technical, and administrative measures to protect your personal data from unauthorized access, use, alteration, or destruction. This includes using encryption, securing servers, and limiting data access to authorized personnel only.

13.2. Limitation of Liability

Despite our efforts to protect your data, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security of your data and are not responsible for unauthorized access or use beyond our control.

 

14. International Users

14.1. Global Access to the Service

Our Service is available to users worldwide. If you use our Service from outside the country in which we are based, please note that your data may be transferred to, stored, and processed in other countries where data protection laws may differ from those in your jurisdiction.

14.2. Consent to International Data Transfer

By using our Service, you consent to the transfer of your personal data to countries other than your country of residence, including the United Arab Emirates and other countries where our servers are located or where we operate.

 

15. California Residents' Rights

Residents of California have certain rights regarding their personal data:

• Right to Know: You have the right to request information about what personal data we collect, use, and disclose.

• Right to Delete: You may request the deletion of your personal data that we collect or hold.

• Right to Opt-Out of Sale of Data: We do not sell your personal data to third parties.

• Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your privacy rights. We will not deny you services, charge different prices, or provide a different level of service quality for exercising your rights.

To exercise your rights, contact us using the information provided in Section 12. Contact Information.

 

16. Disclaimer

We are not responsible for the actions of users or third parties who may access your personal data due to unauthorized access, misuse, or other circumstances beyond our control. You are responsible for protecting your account credentials and not disclosing them to third parties.

You are responsible for maintaining the confidentiality of your account credentials and for all actions that occur under your account. Please immediately notify us of any unauthorized use of your account.

 

17. Links to Other Documents

Our Privacy Policy is part of our Terms of Use. Please also review:

• Terms of Use: https://wispl.app/terms 

 

18. Language of the Policy and Its Interpretation

This Privacy Policy may be translated into other languages for user convenience. In case of discrepancies between versions in different languages, the version in English takes precedence.