Whisper Website Privacy Policy

Effective date: May 10, 2023

At Whisper, we take your privacy seriously. Please read this Website Privacy Policy to learn how we treat your personal data. By using or accessing our website at https://whisper.ai/ (“Services”) in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of Whisper’s Services is at all times subject to our Website Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

You may print a copy of this Privacy Policy by clicking here.

Website Privacy Policy Table of Contents

What this Privacy Policy Covers

• Personal Data
• • Categories of Personal Data We Collect
  • Categories of Sources of Personal Data
  • Our Commercial or Business Purposes for Collecting Personal Data
• How We Share Your Personal Data
• Cookies
• Data Security and Retention
• Personal Data of Children
• California Resident Rights
• Other State Law Privacy Rights
• Changes to this Privacy Policy
• Contact Information

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

 

Category of Personal Data	Examples of Personal Data We Collect	Categories of Third Parties With Whom We Share this Personal Data:
Profile or Contact Data	First and last name  Postal address  Email  Practice/clinic name for hearing care professional (“HCP”)  Phone number	Service Providers Advertising Partners Business Partners (such as our HCP partners) Parties You Authorize, Access or Authenticate
Commercial Data	Transactional information such as products purchased.	Service Providers Advertising Partners Business Partners (such as our HCP partners) Parties You Authorize, Access or Authenticate
Device/IP Data	IP address Device ID Unique personal identifier and online identifiers such as advertising identifier  Domain server Type of device/operating system/browser used to access the Services	Service Providers Advertising Partners Business Partners Parties You Authorize, Access or Authenticate
Web Analytics and Network Activity Data	Browsing history  Search history Web page interactions Advertisement interactions Clickstream data Referring webpage/source through which you accessed the Services Non-identifiable request IDs Statistics associated with the interaction between device or browser and the Services	Service Providers Advertising Partners Business Partners Parties You Authorize, Access or Authenticate
Social Network Data	Email Phone number User name for social network IP address Device ID	Service Providers Advertising Partners Business Partners Parties You Authorize, Access or Authenticate
Consumer Demographic Data	Zip code	Service Providers Advertising Partners Business Partners Parties You Authorize, Access or Authenticate
Geolocation Data	IP-address-based location information Zip code	Service Providers Advertising Partners Business Partners Parties You Authorize, Access or Authenticate
Inferences Drawn From Other Personal Data Collected	Information generated from your use of our Services reflecting your preferences, such as preferred language.	Service Providers Advertising Partners Business Partners Parties You Authorize, Access or Authenticate
Other Identifying Information that You Voluntarily Choose to Provide	Identifying information in emails or letters you send us Identifying information you voluntarily disclose to us via phone communication or your social media posts	Service Providers Advertising Partners Business Partners Parties You Authorize, Access or Authenticate

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

• You
  • When you provide such information directly to us.
    • When you use our interactive tools and Services.
    • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
    • When you send us an email or otherwise contact us.
  • When you use the Services and such information is collected automatically.
    • Through Cookies (defined in the “Cookies” section below).

• Third Parties
  • Vendors/ Service Providers
    • We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
    • We may use vendors to obtain information to generate leads and create user profiles.
  • Advertising Partners
    • We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.

Our Commercial or Business Purposes for Collecting Personal Data

• Providing, Customizing and Improving the Services
  • Providing you with the products, services or information you request.
  • Meeting or fulfilling the reason you provided the information to us.
  • Providing support and assistance for the Services.
  • Improving the Services, including testing, research, internal analytics and product development.
  • Personalizing the Services, website content and communications based on your preferences.
  • Doing fraud protection, security and debugging.
  • Carrying out other business purposes stated when collecting your Personal Data.

• Marketing the Services
  • Sending emails and other communications according to your preferences or that display content that we think will interest you.
  • Showing you advertisements about Whisper products and services, including interest-based or online behavioral advertising.
  • Assisting and collaborating with our business partners (including our HCP partners) so that they can market and sell Whisper products and services to you.
  • Working with our advertising partners to show you advertisements about Whisper products and services.

• Corresponding with You
  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Whisper or the Services.
  • Sending emails and other communications according to your preferences or that display content that we think will interest you.

• Meeting Legal Requirements and Enforcing Legal Terms
  • Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
  • Protecting the rights, property or safety of you, Whisper or another party.
  • Enforcing any agreements with you.
  • Responding to claims that any posting or other content violates third-party rights.
  • Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

How We Share Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section.

• Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
  • Hosting, technology and communication providers.
  • Security and fraud prevention consultants.
  • Analytics providers.
  • Support and customer service vendors.

• Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you.

• Business Partners. These parties partner with us in offering Whisper Products and Services and various other services. They include:
  • Hearing care professionals that partner with us in offering Whisper Products, i.e. our HCP partners.  You may purchase Whisper Products through our HCP partners, and we’ll need to share some of your Personal Information to our HCP partners to enable them to reach out to you to set up an appointment or respond your inquiries, and to facilitate your purchase and/or their promotion and/or sales of the Whisper Products.
  • Allegro, who we partner with to offer you with lease programs to help you with your leasing of the Whisper Products.
  • Businesses that you have a relationship with.
  • Companies that we partner with to offer joint promotional offers or opportunities.

• Parties You Authorize, Access or Authenticate
  • Third parties you access through the services.
  • Social media services.

Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

Cookies

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. These Cookies are named essential cookies, and are required to provide our Services. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. Although we work to protect the security of your data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 13  years of age; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at [email protected].

What choices do I have?

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

You may be able to access, and, in some cases, update, edit or delete certain Personal Data you’ve provided to us. Please send an email to us at [email protected] that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it.

When you update information, however, we may maintain a copy of the unrevised information in our records.  We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at [email protected].

Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes that materially impact our use of your information by placing a notice on the Whisper website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

• Phone: (855) 765-0088
• Website: https://whisper.ai/
• Email: [email protected]
• Address: 260 8th St, San Francisco, CA 94103