When we refer to “we” (or “our” or “us”), that means whochs, Inc., a Virginia corporation. When we refer to “you” (or “your” or “yours”), that means you as a user of our Services. When we say “Personal Data,” we mean identifiable information about you, like your name, email, address, other demographic information, telephone number, payment account details (including credit and debit card numbers), payment information, support queries or account history. If you can’t be identified (for example, when Personal Data has been aggregated and anonymized) then this Policy does not apply.
The Website is available solely in the US and we provide our Services solely to US residents. By accessing our Website, you affirm that you are a U.S. resident and over the age of 18.
1. Public Information Available Through Services
We may make available aggregated publicly available information that is already accessible and in circulation and which is obtained from our third-party data providers (“Public Information”) to users of our Services through the Website’s people search.
2. How to Opt Out
To request that Public Information about you be removed from the Website’s people search, please use our opt-out tool available at https://whochs.com/remove_from_directory. This tool is only intended to remove Public Information available through our Website and cannot be used to remove it from third-party sources (e.g. we are not able to remove your information from other sites or Google). Removal of your information from the Website is completely free. When you submit a request to opt out, we ask you to provide an email address. We use this email address solely to send you an email to verify your request to opt out. We will not sell the email address that you provide as part of the opt-out process, or use it for any other purpose, without your prior consent.
We take measures to avoid reappearing of information about you on the Website after you opted out. We use a proprietary algorithm aimed towards preventing reappearance of information about you after you opted out.
Please note that it takes search engines some time to update their indexes after you opted out. Google bot crawls our pages approximately once every two weeks, which means that a link to the removed page and a snippet will be visible in Google search results for a while. Although, if you click on that link, it will return a 410 (gone) error message, which means the page does not exist anymore. If you want to expedite the removal of such information from Google search results, you can use the following removal tool provided by Google: https://www.google.com/webmasters/tools/removals .
3. What Personal Data We Collect and How We Do That
When you visit our Website or use our Services we collect and process your Personal Data. The ways we collect it can be categorized into the following:
Information you provide to us directly
When you visit or use some parts of our Website and/or Services, we might ask you to provide Personal Data to us. For example, we ask for your email and first and last name upon registration or when you contact us with questions or request support.
Information we collect automatically
We collect some information about you automatically when you visit our Website or use our Services, like what pages you visit, your IP address, operating system, internet service provider, device type and settings, browser type and settings, crash reports, the content you view on our Website, and the date, time, and referrer URL of your request. This information is useful for us as it helps us get a better understanding of how you are using our Website and Services so that we can continue to provide the best experience possible. Some of this information is collected using cookies, similar tracking technologies and third-party tools like, for example, Google Analytics or Facebook Pixel. Our use of these tools and technologies will be covered in detail below. We also collect details of your account activity.
Information we get from third parties
We might collect Personal Data about you from trusted third parties like our payment providers. We use this information to validate the Personal Data you provide.
4. Why We Collect and How We Use Personal Data
We may use your Personal Data for a number of purposes, which may include the following:
- To operate our Website, ensure our Website and Services work as intended and deliver Services you have requested;
- To monitor and analyze trends, usage, and activities in connection with the Website and Services it provides and for marketing and advertising purposes;
- To determine if you may use certain Services;
- To set up and operate your account;
- To perform legal duties, responsibilities and obligations, to comply with any laws and regulations that apply to us;
- To support you, including assisting with the resolution of technical or payment issues or other issues relating to the Website or the Services;
- To process your requests to opt out;
- To enhance our Website and Services, test and develop new features and carry out technical analysis of our Website and Services so that we can optimize your user experience and provide you with more efficient tools;
- To analyze and aggregate data, to prepare statistics, in particular, to produce aggregated and anonymized analytics and reports, which we may use internally or share publicly or with third parties;
- To facilitate, manage and confirm financial transactions;
- To exercise our rights set out in the Terms;
- To disclose information to companies in our group of companies following restructure or for internal administrative purposes; and
- To manage our relationship and communicate with you including operational communications, like changes to our Website and Services, information about new features and promotions, security updates, or assistance with using our Website and Services; marketing communications; and providing you with information you have requested from us or information we are required to send to you.
Our processing of your Personal Data is necessary for us to provide you with the Services you have requested. If we do not process your Personal Data, we may be unable to provide you with all of our Services, and some functions and features on our Website may not be available to you.
5. How We Can Share Your Personal Data
There will be times when we need to share your Personal Data with third parties. We will disclose your Personal Data to:
- Other companies in our group of companies, who have agreed to keep your Personal Data confidential;
- Third-party service providers and partners who assist us in providing the Website and Services which you have requested, for example, to those who support delivery of or provide functionality on the Website or for the Services, or market or promote our Website and/or Services;
- Regulators, law enforcement agencies, government bodies, courts, fraud prevention agencies or other third parties, where we think it is necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights;
- Affiliates and other persons that introduce you to us;
- An actual or potential buyer (and its agents and advisers) in connection with an actual or proposed purchase, merger or acquisition of any part of our business; and/or
- Other persons where we have your consent.
6. Our Use of Tracking Technologies
We also use Local Storage. Local Storage is an industry-standard technology that allows us to store information locally on your computer or mobile device. We may use Local Storage to store information about your preferences or your authorization details.
7. Use of Third-Party Services Like Google Analytics and Facebook Pixel
Google Analytics employs cookies to define user sessions, which allows for the collection of data about how visitors are using the websites. Google Analytics uses only first-party cookies for data analysis. This means that the cookies are linked to a specific website domain, and Google Analytics will only use that cookie data for statistical analysis related to your browsing behavior on that specific website. According to Google, the data collected cannot be altered or retrieved by services from other domains.
If you choose, you can opt out by turning off cookies in the preferences settings in your web browser. For more information on Google Analytics, please visit http://www.google.com/analytics/ .
We utilize Facebook Pixel service provided by Facebook Inc. This tool allows us to follow the actions of users after they are redirected to the Website by clicking on a Facebook advertisement. We are thus able to record the efficacy of Facebook advertisements for statistical and market research purposes. The collected data remain anonymous and non-personally identifiable. However, the collected data are saved and processed by Facebook. Facebook is able to connect the data with your Facebook account and use the data for their own advertising purposes, in accordance with Facebook’s Data Use Policy . In addition, a cookie from Facebook will be saved onto your device for these purposes.
Third-party services like Google Analytics and Facebook Pixel plant a permanent cookie on your web browser to identify you as a unique user the next time you visit the Website. Google Analytics and Facebook Pixel use only first-party cookies for data analysis. This means that the cookies are linked to a specific website domain, and Google or Facebook will only use that cookie data for statistical analysis related to your browsing behavior on that specific website.
We do not control when or how other third parties place cookies on your computer. For example, third party websites to which a link or advertisement points may set cookies on your computer. Some of these services may be used to track your behavior on other websites and we have no control over this.
You can prevent Google Analytics, Facebook Pixel and other third-party services we may use from recognizing you on return visits to the Website by disabling cookies on your browser. If you choose, you can opt out by turning off cookies in the preferences settings in your web browser.
8. E-mail Communications and Marketing
When you submit your email address through the Website, you are consenting to receive offers and information about our services and products by e-mail, as well as for us to communicate with you about your account, purchases, and subscriptions, at the e-mail address provided. If you subsequently decide that you wish to no longer receive marketing e-mails, please follow the instructions at the end of any email message to unsubscribe or e-mail us at [email protected] and request to unsubscribe. Please allow up to 10 business days for any removal request to be processed. Please note that if you decide not to receive marketing emails from us, you may still receive transactional email messages regarding your account and subscription. If you have questions or concerns regarding this provision, please contact us by e-mail at [email protected].
9. Third-Parties’ Links
10. Data Retention
The time periods for which we retain your Personal Data depend on the purposes for which we use it. We will keep your Personal Data for as long as you are a user and, thereafter, for no longer than is reasonably necessary for reporting and reconciliation purposes pursuant to legal requirements and to provide you with any feedback or information you might request or require.
11. Your Consent
You expressly consent to our processing, collection, transfer, storage, disclosure and other uses of your Personal Data as described in this Policy and the Terms when you:
- Register with us,
- Provide Personal Data to us through the Website or the Services (e.g. when submitting an opt-out request), and/or
- Browse and use the Website.
In addition, through this use and interactions with the Website, you specifically consent to our (or our suppliers and contractors):
- Use of your name and email address for sending you alerts or information on features, products and promotions related to our Services (you can opt out from these emails at any time, including by sending your request to [email protected]);
- Collection of information by automated means, such as cookies or other tracking technologies, and to our subsequent processing and using of information in accordance with this Policy and the Terms ; and
- Storage and transfer of your Personal Data to locations wherever we and our service providers have facilities.
12. The California Consumer Privacy Act
When we collect Personal Data from California residents we become subject to, and those residents have rights under, the California Consumer Privacy Act (“CCPA”). This section applies only to those California residents who are visitors to our Website and/or users of our Services and thus for purposes of Sections 12 and 13, the words “you” and “your” mean only those California residents.
Please note that Personal Data does not include:
- publicly available information obtained from government records, including but not limited to property records, street address and criminal records;
- information that is de-identified or aggregated;
- medical information governed by the Confidentiality of Medical Information Act or protected health information governed by the Health Insurance Portability and Accountability Act;
- information collected as part of a clinical trial;
- personal information governed by the Fair Credit Reporting Act, Gramm-Leach-Bliley Act or California Financial Information Privacy Act, or Driver’s Privacy Protection Act.
What Personal Data did we collect?
We collected, within the last 12 months, the following categories of Personal Data:
- identifiers such as name and IP address;
- personal information under the Customer Records provision of the California Civil Code such as a name, address, and telephone number, and physical characteristics or description;
- characteristics of protected classifications such as race and gender;
- online activity such as browsing history and search history.
What Personal Data did we disclose for a business purpose?
We disclosed for a business purpose, within the last 12 months, the following categories of Personal Data:
- identifiers such as name and IP address;
- personal information under the Customer Records provision of the California Civil Code such as a name, address, and telephone number, and physical characteristics or description;
- internet/electronic activity such as browsing history and search history.
Please review Section 5 above where we describe the categories of third parties we may have disclosed your Personal Data to.
What Personal Data did we sell?
We do not sell to third parties, and within the last 12 months have not sold, any of your Personal Data automatically collected from your use of the Website and Services (please review Section 3 above for examples) or provided by you to us (e.g. your name and email address collected when you set up your account or contacted our support team).
What sources did we obtain Personal Data from?
Please review Section 3 above where we describe the sources from which we collect Personal Data.
Why did we collect your Personal Data?
Please review Section 4 above where we describe our business purposes for collecting Personal Data.
13. Rights of California Residents
You have the below-listed rights under the CCPA with respect to your Personal Data.
Right to Know
You have the right to request that we disclose to you, specifically, beyond the general statement above, the categories and specific elements of Personal Data collected about you including the source of the information and our use of it or the Personal Data that was disclosed or sold to third parties.
Right to Request Deletion
You have the right, under certain circumstances, to request that we delete the Personal Data we collected from you.
Please note that this right is not absolute. First of all, not all data published on the Website or available through the Services is Personal Data. For example, public information that is made available by government agencies, including property records, street address and criminal records is not Personal Data.
According to the CCPA we are not required to comply with a consumer’s request to delete the consumer’s Personal Data if it is necessary for us our service providers to maintain the consumer’s Personal Data in order to:
- Complete the transaction for which the Personal Data was collected, provide a service requested by the consumer, or reasonably anticipated within the context of a business’ ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the business’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
- To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
- Comply with a legal obligation.
- Otherwise use the consumer’s Personal Data, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
Right to Opt-out
You have the right, at any time, to request that we not sell your Personal Data. As stated in Section 2 above, you can use the tool available at https://whochs.com/remove_from_directory to request information about you to be removed from the Website’s people search.
Right to Non-discrimination
You have the right not to be discriminated against for exercising any of your rights under the CCPA.
Submitting Requests under the CCPA
You or an authorized agent acting on your behalf can exercise the rights above by contacting us at [email protected] . You may only exercise your right to know up to two different times in a 12 month period. When you submit a request, we may ask you to fill out a request form. The CCPA only allows us to act on your request if we can verify your identity or your authority to make the request, so you will also need to follow our instructions for identity verification.
If you make a verifiable request per the above, we will confirm our receipt and respond in the time frames prescribed by the CCPA.
14. Security of Personal Data
We are committed to protecting your Personal Data and have appropriate technical and organizational measures in place, including:
Data encryption. We encrypt all data that goes between you and us using industry-standard TLS (Transport Layer Security), protecting your personal and financial data. Your password is also encrypted when it is stored on our servers.
Limited access. We restrict access to personal information to our employees, contractors, and agents who need that information in order to process it.
Network protection. Multiple layers of security controls protect access to and within our environment, including firewalls, intrusion protection systems and network segregation. Our security services are configured, monitored and maintained according to industry best practice. We partner with industry-leading security vendors to leverage their expertise and global threat intelligence to protect our systems.
Secure data centers. Our servers are located within enterprise-grade hosting facilities that employ robust physical security controls to prevent physical access to the servers they house. These controls include 24/7/365 monitoring and surveillance, on-site security staff and regular ongoing security audits. We maintain geographically separated data replicas and hosting environments to minimize the risk of data loss or outages.
Security monitoring. Our security team continuously monitors security systems, event logs, notifications and alerts from all systems to identify and manage threats.
However, we do not guarantee or warrant that such techniques will prevent unauthorized access to Information, including Personal Data that we store.
15. Information Concerning Children
Our Website and Services are directed to U.S. residents who are at least 18 years old. We do not knowingly collect or solicit any Personal Data from anyone under the age of 13 or knowingly allow such persons to use the Website or the Services. If we become aware that we have collected Personal Data from a child underage 13 without verification of parental consent, we take immediate steps to remove that information. We do not knowingly aggregate or provide Public Information about people under the age of 18.
16. Business or Asset Transfer
In the event that we, a line of our business, or our assets are transferred, sold or merged with another business, information, including, but not limited to your Personal Data, may be one of the transferred assets and we will not be obliged to notify you or need your consent in order to transfer such information.
We reserve the right, at our sole discretion to put into effect, modify or revise this Policy at any time by posting the Policy or revised Policy on the Website. The Policy or any changes will become effective upon posting of the Policy (revised Privacy). If we make any material changes to the Policy we will use reasonable efforts to inform you by email or by posting a notice on the Website. We encourage you to review this Policy each time you visit the Website to make sure you understand the most current Policy. Your continued use of the Website signifies your acceptance of any implemented or changed terms.
18. Changing or Updating Your Personal Data
We take reasonable steps to ensure that the Personal Data we hold about you is accurate, complete and up-to-date. However, we rely on you to advise us of any changes to your Personal Data. Please log into your account or contact us as at [email protected] as soon as possible if there are any changes to your Personal Data or if you believe the Personal Data we hold about you is not accurate, complete or up-to-date so that we can update our records accordingly.
19. Privacy Related Inquiries
If, for any reason, you are concerned with the way that we may be using your Personal Data or you have questions about the privacy aspects of the Website or the Services, please, contact us at [email protected].
Last updated: Aug 21, 2020