WhoSay Inc. Application Privacy Policy

Thank you for using this WhoSay Inc. ("us," "we" or "our") site or application and using our applications and services made available through it (together, the "Service") in connection with your hosted WhoSay page ("WhoSay Page"). Your use of the Service and your WhoSay Page is governed by the Whosay Talent Terms of Use. Your privacy is important to us. To help you understand our privacy practices, we provide this notice explaining how we collect, use, and disclose your information when you are using the Service. By using the Service, you agree to the terms and conditions of this Privacy Policy.

What Information We May Collect about you

In connection with your use of the Service, we may collect different types of personally identifiable information including but not limited to your name, address, gender, e-mail address, SMS number, telephone number, or fax number when you provide such information to us. We may also collect information about your personal or professional interests and use of or opinions about various products, programs and services. In addition , we collect information about you that is included in any content you post to your WhoSay Page, as described in more detail below

We may also collect certain information automatically when you use our Service, such as the type of browser and operating system you are using, your IP address, Internet service provider, platform type, referring and exit websites, your use and navigation of the Service, and other clickstream data. When you use a WhoSay application on your mobile device, we may also collect information about your mobile's location (for example, to display the approximate geographic location from which you have uploaded Content on your WhoSay Page) and your unique device identifier. Your mobile device settings allow you to control whether or not we can collect information about your location.

We may combine the information we collect from and about you with information we lawfully receive from and about you from other online and offline sources.

How We Use the Information

We use information provided by you in order to enable you to post to your WhoSay Page information, text and opinions, and photographs, images, video and audio relating to you, and relating to groups, events, locations, products, topics of interest and good and services (such materials provided by you, "Content"). This Content will be made available to members of the public that view your WhoSay Page and those who have registered with WhoSay ("Viewers"), and we cannot accept responsibility for how those Viewers access, comment on, share, or otherwise use your Content. For this reason, you should take care only to post Content that you are comfortable sharing publicly with Viewers – in exactly the same way that you should when posting Content to any online social networking site. Please be aware that Viewers may choose to "follow" your WhoSay Page, meaning that they will be kept informed (including through e-mail) when you post new Content.

If your Content contains personal information relating to or about other individuals, such as your family, friends, colleagues or any other person, you must check that they are happy for you to post that Content before you upload it to your WhoSay Page. When you post Content including information about another individual, you confirm that you have informed them of our identity and the purposes for which their information will be used as set out in this Privacy Policy and that you have obtained their consent to such use.

We also use the information you provide to process your registration with the Service, to respond to your inquiries and fulfill your requests and to send you administrative information, such as updates to our Service or its policies. We may also use the information we collect to personalize your experience and to offer you products, programs or services that may be of interest. We may combine information we receive with outside records and share such information with third parties to enhance our ability to market to you those products or services that may be of interest to you. In addition, we may use the information we collect from and about you for our business purposes, such as data analysis, audits, and improving our marketing and our services.

If you choose to submit Content to the Service and/or your WhoSay Page, we may publish your name, screen name and other information you have provided to us. As explained above, please note that any Content you post or disclose through your WhoSay Page may be available to Viewers and to the general public.

Furthermore, we may make such Content available to third parties so that it can be embedded within their web sites and networks in accordance with the WhoSay Viewer Terms of Use

We use the information that we collect automatically when you use the Service for research and analytics purposes, including to improve the Service's design, content, and user experience

Cookies and other Technologies

To enhance both your and that of third party viewers of the WhoSay Page online experience, we use cookies. Cookies are text files we or our service providers place in computer browsers to store preferences. Cookies, by themselves, do not tell us an e-mail address or other personally identifiable information. However, once a user chooses to furnish the Service with personally identifiable information, this information may be linked to the data stored in the cookie.

Cookies allow us to collect information such as browser type and time spent on the Service or WhoSay Page. We use the information to understand Internet usage and to improve our content, services, offerings and advertisements. We may also use cookies to personalize a Viewer’s experience in using the Service (e.g., to recognize them by name when they return to the Service) and save their password in password-protected areas.

We may also use small pieces of code such as "web beacons", "pixel tags", or "clear gifs" in connection with the WhoSay Page to, among other things, track the actions of the WhoSay Page Viewers and email recipients, measure the success of our marketing campaigns, and compile statistics about the Service and WhoSay Page usage and response rates.

The use of the technologies described in this section allows our third-party vendors to deliver advertisements when viewers visit the WhoSay Page or other websites or web properties across the Internet. These vendors may place pixel tags, web beacons, clear GIFs of similar technologies by means of the WhoSay Page and third-party websites. These vendors may use information about your use of the Service and other websites to serve advertisements about our products and services, and other companies' products and services. If you would like more information about this practice and to know your choices about not having this information used by these companies, visit the Network Advertising Initiative at www.networkadvertising.org or the Digital Advertising Alliance at www.aboutads.info.

For more information about the specific cookies that may be served on the WhoSay Page, including who serves them and how to refuse those cookies, please see the section entitled Cookies and Other Technologies of the WhoSay Viewer Privacy Policy.

How we disclose the information

We may make the Content you post on your WhoSay Page available to those third party web sites, distribution partners and networks (collectively, "Channels") that you have consented to in accordance with the WhoSay Talent Terms of Use. We are not responsible for the terms of use, privacy policies or other practices of any such Channels.

We do not share your personally identifiable information with third parties for their direct marketing purposes unless you give us your consent.

We engage certain trusted third parties to perform functions and provide services to us, including, without limitation, hosting and maintenance, customer relationship, database storage, management and analysis, and direct marketing campaigns. We will share your personally identifiable information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your data.

We may use and share with third parties certain technical information (including IP addresses) or aggregated information to show general demographic and preference information and viewer patterns among different WhoSay Page viewers.

We may use and disclose the information we collect from and about you as we believe to be necessary or appropriate: (1) under applicable law, including laws outside your country of residence; (2) to comply with legal process; (3) to respond to requests from public and government authorities, including those outside your country of residence; (4) to enforce our viewer Terms of Use or talent Terms of Service; (5) to protect our operations or those of any of our affiliates; (6) to protect our rights, privacy, safety, or property and/or that of our affiliates, you, or others; (7) to allow us to pursue available remedies or limit the damages that we may sustain; and (8) to investigate, prevent or take action regarding illegal or suspected illegal activities.

Please note that if WhoSay Inc. or any of its affiliates, subsidiaries or lines of business is sold or otherwise disposed of, including through merger of, consolidation or sale of assets, or in the unlikely event that WhoSay Inc. goes out of business or enters bankruptcy, our databases, including personally identifiable information we may possess about you, may, in whole or in part, be sold, disposed of, transferred or otherwise disclosed as part of that transaction and you acknowledge that the acquirer of WhoSay Inc. or any of its affiliates, subsidiaries or lines of business may continue to use your information as set forth in this Privacy Policy (as amended from time to time).

Third Party Sites

The Service may contain links to other sites whose information practices may be different than ours and for which we are not responsible. You should consult the other site's privacy policies, as we have no control over information that is submitted to, or collected by, these third parties.


We use appropriate technical and organizational measures to safeguard the personally identifiable information under our control. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure.

Cross-border Transfer

The Site is hosted in the United States. In addition, your information may be transferred to and maintained in whole or in part on computer networks which may be located outside of the state, province, country or other governmental jurisdiction in which you reside, including the United States. You understand that the countries to which we may transfer information many not have as comprehensive data protection rules as in your country. However, please be assured that we take steps to ensure that your personal data is protected in accordance with this Privacy Policy.

Our Policy Toward Children

We do not knowingly collect personally identifiable information by means of the Service from children under the age of thirteen (13) without lawful permission. If we become aware that a child under thirteen (13) has provided us with personally identifiable information without the proper lawful permission or authorization, we will delete such information from our system.

International Viewers

The Service is provided in the United States and is intended for users in the United States. If you are a user accessing the Service from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from laws of the United States, please be advised that through your continued use of the Service, which is governed by United States law, this Privacy Policy, and our Terms of Use, you are transferring your personal information to the United States and you consent to that transfer.

Right To Access

You have a right to access the personally identifiable information we hold about you (for which we reserve the right to charge you a small fee, as permitted by applicable law) and to instruct us to correct or update it. Your right of access can be exercised in accordance with applicable law. Please submit any requests for access to your personal data in writing to privacy@whosay.com.

Retention Period

We will retain your personally identifiable information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required by law.

Privacy Complaints or Queries

In the event you have a privacy complaint or a query with respect to information collected by WhoSay Inc., you may contact us at privacy@whosay.com.

Changes to this Privacy Policy

This Privacy Policy may be changed periodically. We will notify you about material changes by sending a notice to the email address you registered with us and/or by placing a prominent notice on our Service. Your continued use of the Service constitutes your agreement to this Privacy Policy and any future revisions.

Collection and use of user information

Our Viewer Privacy Policy explains how we collect and use information about Viewers who visit your WhoSay Page.

Date Last Modified

January 14, 2013