PRIVACY POLICY
Last updated: April 1st, 2025 - Version 1.0
This privacy policy applies to our mobile iOS and Android apps (hereinafter "APP" and/or"PRODUCT"), as you can use all platforms simultaneously with your WhosClose account.
This Privacy Notice for WhosClose App (“we”, “us” or “our”) explains how and why wecollect, use, store, and share (“process”) your personal data when you use our services(“Services”). This includes when you:
This Privacy Notice for WhosClose App (“we”, “us” or “our”) explains how and why wecollect, use, store, and share (“process”) your personal data when you use our services(“Services”). This includes when you:
- Download and use our mobile APP, or any other application of ours that links to thisPrivacy Notice
- Use the features and functionalities of APP
- Interact with us through our websites, support channels, sales activities, events, ormarketing materials
Questions or concerns? Reading this Privacy Notice will help you understand your privacyrights and choices. We are responsible for making decisions about how your personalinformation is processed. If you do not agree with our policies and practices, please do notuse our Services. If you still have any questions or concerns, please contact us at dp@whosclose.com. WhosApp GmbH, with registered office at Zugspitzstraße 15, 82049Pullach, Germany, acts as the Data Controller of your personal information.
We may update this document from time to time to reflect changes in legal requirements orour services. All changes will be published here, and if the changes are significant, we willnotify you through the app or by email.
We may update this document from time to time to reflect changes in legal requirements orour services. All changes will be published here, and if the changes are significant, we willnotify you through the app or by email.
SUMMARY OF KEY POINTS
This summary provides key points from our Privacy Notice, but you can find out more detailsabout any of these topics by clicking the link following each key point or by using our table ofcontents below to find the section you are looking for.
What personal information do we process?
When you visit, use, or navigate our Services, we may process personal informationdepending on how you interact with us and the Services, the choices you make, and theproducts and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information?
Some of the information may be considered "special" or "sensitive" in certain jurisdictions, forexample your racial or ethnic origins, sexual orientation, and religious beliefs. We do notprocess sensitive personal information.
Do we collect any information from third parties?
We do not collect any information from third parties.
How do we process your information?
We process your information to provide, improve, and administer our Services, communicatewith you, for security and fraud prevention, and to comply with law. We may also processyour information for other purposes with your consent. We process your information onlywhen we have a valid legal reason to do so. Learn more about how we process yourinformation.
In what situations and with which parties do we share personalinformation?
We may share information in specific situations and with specific third parties. Learn moreabout when and with whom we share your personal information.
How do we keep your information safe?
We have adequate organizational and technical processes and procedures in place toprotect your personal information. However, no electronic transmission over the internet orinformation storage technology can be guaranteed to be 100% secure, so we cannotpromise or guarantee that hackers, cybercriminals, or other unauthorized third parties willnot be able to defeat our security and improperly collect, access, steal, or modify yourinformation. Learn more about how we keep your information safe.
What are your rights?
Depending on where you are located geographically, the applicable privacy law may meanyou have certain rights regarding your personal information.
How do you exercise your rights?
The easiest way to exercise your rights is by contacting us. We will consider and act uponany request in accordance with applicable data protection laws. Want to learn more about what we do with any information we collect? Review the PrivacyNotice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on theServices, express an interest in obtaining information about us or our products and Services,when you participate in activities on the Services, or otherwise when you contact us.
We collect personal information that you voluntarily provide to us when you register on theServices, express an interest in obtaining information about us or our products and Services,when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You.
The personal information that we collect depends on the context of your interactions with usand the Services, the choices you make, and the products and features you use. Thepersonal information we collect may include the following:
- names
- phone numbers
- email address
We do not knowingly collect personal information from individuals under the age of 16. Youmust be at least 16 years old (or the minimum age required by your country’s data protectionlaws) to use the Services or provide personal data to us. By registering, you confirm that youare at least 16 years old. We do not use technical age verification, but will act promptly todelete any account if we learn that a user is under the required age.
For more information on eligibility, please see our Terms and Conditions.
Sensitive Information. We do not process sensitive information.
Social Media Login Data. We may provide you with the option to register with us using yourexisting social media account details, like your Google Login, Apple Login, or other socialmedia account. If you choose to register in this way, we will collect certain profile informationabout you from the social media provider, as described in the section called "HOW DO WEHANDLE YOUR SOCIAL LOGINS?" below.
Application Data. If you use our application(s), we also may collect the following informationif you choose to provide us with access or permission:
Geolocation Information. We may request access or permission to track location-basedinformation from your mobile device, either continuously or while you are using our mobileapplication(s), to provide certain location-based services. If you wish to change our accessor permissions, you may do so in your device’s settings.
Mobile Device Access. We may request access or permission to certain features from yourmobile device, including your mobile device’s contacts, camera, and other features. If youwish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Data. We automatically collect device information (such as your mobile deviceID, model, and manufacturer), operating system, version information and systemconfiguration information, device and application identification numbers, browser type andversion, hardware model Internet service provider and/or mobile carrier, and InternetProtocol (IP) address (or proxy server). If you are using our application(s), we may alsocollect information about the phone network associated with your mobile device, your mobiledevice’s operating system or platform, the type of mobile device you use, your mobiledevice’s unique device ID, and information about the features of our application(s) youaccessed.
Push Notifications. We may request to send you push notifications regarding your account orcertain features of the application(s). If you wish to opt out from receiving these types ofcommunications, you may turn them off in your device’s settings.
This information is primarily needed to maintain the security and operation of ourapplication(s), for troubleshooting, and for our internal analytics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, andyou must notify us of any changes to such personal information.
For more information on eligibility, please see our Terms and Conditions.
Sensitive Information. We do not process sensitive information.
Social Media Login Data. We may provide you with the option to register with us using yourexisting social media account details, like your Google Login, Apple Login, or other socialmedia account. If you choose to register in this way, we will collect certain profile informationabout you from the social media provider, as described in the section called "HOW DO WEHANDLE YOUR SOCIAL LOGINS?" below.
Application Data. If you use our application(s), we also may collect the following informationif you choose to provide us with access or permission:
Geolocation Information. We may request access or permission to track location-basedinformation from your mobile device, either continuously or while you are using our mobileapplication(s), to provide certain location-based services. If you wish to change our accessor permissions, you may do so in your device’s settings.
Mobile Device Access. We may request access or permission to certain features from yourmobile device, including your mobile device’s contacts, camera, and other features. If youwish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Data. We automatically collect device information (such as your mobile deviceID, model, and manufacturer), operating system, version information and systemconfiguration information, device and application identification numbers, browser type andversion, hardware model Internet service provider and/or mobile carrier, and InternetProtocol (IP) address (or proxy server). If you are using our application(s), we may alsocollect information about the phone network associated with your mobile device, your mobiledevice’s operating system or platform, the type of mobile device you use, your mobiledevice’s unique device ID, and information about the features of our application(s) youaccessed.
Push Notifications. We may request to send you push notifications regarding your account orcertain features of the application(s). If you wish to opt out from receiving these types ofcommunications, you may turn them off in your device’s settings.
This information is primarily needed to maintain the security and operation of ourapplication(s), for troubleshooting, and for our internal analytics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, andyou must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browserand device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services.This information does not reveal your specific identity (like your name or contact information)but may include device and usage information, such as your IP address, browser and devicecharacteristics, operating system, language preferences, referring URLs, device name,country, location, information about how and when you use our Services, and other technicalinformation. This information is primarily needed to maintain the security and operation ofour Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
Log and Usage Data.
Log and usage data is service-related, diagnostic, usage, and performance information ourservers automatically collect when you access or use our Services and which we record inlog files. Depending on how you interact with us, this log data may include your IP address,device information, browser type, and settings and information about your activity in theServices (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device eventinformation (such as system activity, error reports (sometimes called "crash dumps"), andhardware settings).
Device Data.
We collect device data such as information about your computer, phone, tablet, or otherdevice you use to access the Services. Depending on the device used, this device data mayinclude information such as your IP address (or proxy server), device and applicationidentification numbers, location, browser type, hardware model, Internet service providerand/or mobile carrier, operating system, and system configuration information.
Location Data.
We collect location data from your device to enable features such as live location sharing,proximity-based visibility, or location history. Depending on your device and settings, thismay include precise location (via GPS or Wi-Fi) or approximate location (via IP address).If you enable location-based features in the app, your location may be stored to create apersonal location history — for example, to help you view where you have been while usingthe service. This location history is stored securely and cannot be manually deleted by theuser. Upon account deletion, the history is anonymized by removing all identifiers linking it toyour user profile, making it no longer attributable to you.Your location data is processed based on your explicit consent (Art. 6(1)(a) GDPR), whichyou can grant or withdraw via your device’s settings or within the app. If location-basedservices are an essential part of your account features, we may rely on contractual necessity(Art. 6(1)(b) GDPR).Please note that disabling location access may affect certain functionalities of the app.
Google API
Our use of information received from Google APIs will adhere to Google API Services UserData Policy, including the Limited Use requirements.
Chat Feature
If you use the chat feature in our app, we may collect and process personal data you submitin messages (such as text, profile name, or metadata) as part of your communication withother users.
Mobile Phone Number
We collect your mobile phone number when you register or update your profile. This isrequired to verify your identity and protect against fraudulent account creation.
We automatically collect certain information when you visit, use, or navigate the Services.This information does not reveal your specific identity (like your name or contact information)but may include device and usage information, such as your IP address, browser and devicecharacteristics, operating system, language preferences, referring URLs, device name,country, location, information about how and when you use our Services, and other technicalinformation. This information is primarily needed to maintain the security and operation ofour Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
Log and Usage Data.
Log and usage data is service-related, diagnostic, usage, and performance information ourservers automatically collect when you access or use our Services and which we record inlog files. Depending on how you interact with us, this log data may include your IP address,device information, browser type, and settings and information about your activity in theServices (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device eventinformation (such as system activity, error reports (sometimes called "crash dumps"), andhardware settings).
Device Data.
We collect device data such as information about your computer, phone, tablet, or otherdevice you use to access the Services. Depending on the device used, this device data mayinclude information such as your IP address (or proxy server), device and applicationidentification numbers, location, browser type, hardware model, Internet service providerand/or mobile carrier, operating system, and system configuration information.
Location Data.
We collect location data from your device to enable features such as live location sharing,proximity-based visibility, or location history. Depending on your device and settings, thismay include precise location (via GPS or Wi-Fi) or approximate location (via IP address).If you enable location-based features in the app, your location may be stored to create apersonal location history — for example, to help you view where you have been while usingthe service. This location history is stored securely and cannot be manually deleted by theuser. Upon account deletion, the history is anonymized by removing all identifiers linking it toyour user profile, making it no longer attributable to you.Your location data is processed based on your explicit consent (Art. 6(1)(a) GDPR), whichyou can grant or withdraw via your device’s settings or within the app. If location-basedservices are an essential part of your account features, we may rely on contractual necessity(Art. 6(1)(b) GDPR).Please note that disabling location access may affect certain functionalities of the app.
Google API
Our use of information received from Google APIs will adhere to Google API Services UserData Policy, including the Limited Use requirements.
Chat Feature
If you use the chat feature in our app, we may collect and process personal data you submitin messages (such as text, profile name, or metadata) as part of your communication withother users.
Mobile Phone Number
We collect your mobile phone number when you register or update your profile. This isrequired to verify your identity and protect against fraudulent account creation.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services,communicate with you, for security and fraud prevention, and to comply with law. We mayalso process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how youinteract with our Services, including:
- To facilitate account creation and authentication and otherwise manage useraccounts.
We may process your information so you can create and log in to your account, aswell as keep your account in working order. We use your mobile phone number tosend a one-time SMS verification code during account setup or updates. Thisprocess ensures that the number belongs to you and helps maintain the integrity ofour user base. - To enable user-to-user communications.
We may process your information if you choose to use any of our offerings that allowfor communication with another user. - To request feedback.
We may process your information when necessary to request feedback and tocontact you about your use of our Services. - To identify usage trends.
We may process information about how you use our Services to better understandhow they are being used so we can improve them. - To provide location-based services
WhosClose uses your device’s location data to support features such as live location sharing, visibility of nearby friends, and more relevant social suggestions. To make these features work reliably and accurately, we may process and store precise location information, including latitude and longitude coordinates.
We use this information only for the operation, personalisation, and improvement of our location-based features, and protect it with appropriate security measures. We keep precise location data only for as long as needed for these purposes and according to our retention policy.
Location data is processed only with your explicit consent under Art. 6(1)(a) GDPR. You can withdraw your consent at any time through your device settings and, where available, in the app’s privacy settings. - To save or protect an individual’s vital interest.
We may process your information when necessary to save or protect an individual’svital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESSYOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary andwe have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill ourcontractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain thevalid legal bases we rely on in order to process your personal information. As such, we mayrely on the following legal bases to process your personal information:
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain thevalid legal bases we rely on in order to process your personal information. As such, we mayrely on the following legal bases to process your personal information:
- Consent.
We may process your information if you have given us permission (i.e., consent) touse your personal information for a specific purpose. You can withdraw your consentat any time. Learn more about withdrawing your consent. - Performance of a Contract.
We may process your personal information when we believe it is necessary to fulfillour contractual obligations to you, including providing our Services or at your requestprior to entering into a contract with you. - Legitimate Interests.
We may process your information when we believe it is reasonably necessary toachieve our legitimate business interests and those interests do not outweigh yourinterests and fundamental rights and freedoms. For example, we may process yourpersonal information for some of the purposes described in order to:
- Analyze how our Services are used so we can improve them to engage andretain users
- Understand how our users use our products and services so we can improveuser experience - Legitimate Interests.
We may process your information when we believe it is reasonably necessary toachieve our legitimate business interests and those interests do not outweigh yourinterests and fundamental rights and freedoms. For example, we may process yourpersonal information for some of the purposes described in order to:
- Analyze how our Services are used so we can improve them to engage andretain users
- Understand how our users use our products and services so we can improveuser experience - Vital Interests.
We may process your information where we believe it is necessary to protect yourvital interests or the vital interests of a third party, such as situations involvingpotential threats to the safety of any person.
In legal terms, we are generally the "data controller" under European data protection laws ofthe personal information described in this Privacy Notice, since we determine the meansand/or purposes of the data processing we perform. This Privacy Notice does not apply tothe personal information we process as a "data processor" on behalf of our customers. Inthose situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the "data controller" responsible for your personalinformation, and we merely process your information on their behalf in accordance with yourinstructions. If you want to know more about our customers’ privacy practices, you shouldread their privacy policies and direct any questions you have to them.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., expressconsent) to use your personal information for a specific purpose, or in situations where yourpermission can be inferred (i.e., implied consent). You can withdraw your consent at anytime.
In some exceptional cases, we may be legally permitted under applicable law to processyour information without your consent, including, for example:
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., expressconsent) to use your personal information for a specific purpose, or in situations where yourpermission can be inferred (i.e., implied consent). You can withdraw your consent at anytime.
In some exceptional cases, we may be legally permitted under applicable law to processyour information without your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtainedin a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess,process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victimof financial abuse
- If it is reasonable to expect collection and use with consent would compromise theavailability or the accuracy of the information and the collection is reasonable forpurposes related to investigating a breach of an agreement or a contravention of thelaws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules ofthe court relating to the production of records
- If it was produced by an individual in the course of their employment, business, orprofession and the collection is consistent with the purposes for which the informationwas produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOURPERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/orwith the following third parties.
We may need to share your personal information in the following situations:
- Business Transfers.
We may share or transfer your information in connection with, or during negotiationsof, any merger, sale of company assets, financing, or acquisition of all or a portion ofour business to another company. - When we use Google Maps Platform APIs.
In order to provide certain location-based functionalities (such as map display orproximity-based services), we may integrate and use Google Maps Platform APIs(e.g., Google Maps API, Places API). These services are provided by Google IrelandLimited, Gordon House, Barrow Street, Dublin 4, Ireland.When using these APIs, location data is processed based on your device’stechnologies, such as GPS, Wi-Fi, and mobile network signals, to estimate yourapproximate position. This data allows Google Maps to offer services like routecalculation or displaying nearby places. The accuracy of the location may varydepending on the technology and environment.You may revoke your consent at any time by adjusting your device's location settingsor by contacting us directly. Further details on how Google processes data can befound in the Google Privacy Policy. - Other Users and Public Sharing
Our Services may offer features that allow you to share certain content, such as ameetup or event, with others through a publicly accessible link. If you choose toactivate this option, anyone with access to the unique link may view the sharedinformation — including details such as the meetup title, time, location (if provided),and other information you voluntarily include.We only make such information publicly available with your prior action or explicitconsent. You are always in control of whether your meetups or events are sharedpublicly, and you may disable or delete the public link at any time via your account orevent settings.If you interact with other users within the Services (e.g., through profile interactions,user-to-user messaging, or social logins like Google Login), your basic profileinformation — such as your name, profile photo, and activity description — may bevisible to other registered users, depending on your privacy settings.Please note that when you voluntarily share personal information in public areas orvia public links, that information may be accessible by others and may be indexed bysearch engines depending on the sharing settings and platform visibility. - Chat Feature
To provide chat functionality, we use Stream, a real-time messaginginfrastructure service operated by GetStream.io, Inc., headquartered in theUnited States. Personal information such as message content, user IDs, andtimestamps may be processed by GetStream to operate and deliver the chatservices. Where data is transferred to countries outside the EuropeanEconomic Area (such as the United States), we ensure appropriate safeguardsare in place in accordance with Article 46 GDPR, such as StandardContractual Clauses (SCCs). You can learn more about Stream’s privacypractices at: https://getstream.io/legal/privacy/ - SMS Messages
To send SMS messages, we use the third-party communications service providerTwilio Inc., headquartered in the United States. Twilio processes your mobile phonenumber solely for the purpose of delivering verification codes via SMS for accountauthentication and security purposes.Since this involves a transfer of personal data outside the European Economic Area(EEA), we ensure appropriate safeguards are in place according to Article 46 GDPR,including Standard Contractual Clauses (SCCs) approved by the EuropeanCommission.For more details, please see Twilio’s Privacy Policy. - Deep-Linking Services
We use the deep-linking service provided by AppsFlyer to enable seamlessnavigation directly to specific content within our app. AppsFlyer helps us ensure thatlinks shared through various channels open correctly in the intended location insidethe app.To deliver this functionality, AppsFlyer may process technical information from yourdevice, such as:○ Device identifiers○ IP addresses○ Referral URLsWe do not share directly identifiable personal information (e.g., your name, emailaddress, or phone number) with AppsFlyer.For further details, please review AppsFlyer’s Privacy Policy. - Analytics & Usage Insights
We use PostHog, an analytics platform operated by PostHog, Inc., headquartered inthe United States, to analyze user behavior and interactions within our Services. Thishelps us identify usage patterns, optimize user experience, and improve the overallquality and performance of our app.PostHog processes certain personal and technical information, including:
- Device information (type, operating system)
- Session details (duration, screens viewed)
- Interaction data (clicks, taps, events within the app)
- IP addresses (anonymized or truncated for enhanced privacy)
- Approximate location (derived from IP address)
PostHog acts as a data processor for WhosClose, processing data solely on ourinstructions and based on our legitimate interests under Art. 6(1)(f) GDPR, specifically for service improvement, debugging, and enhancing user experience. Where applicable, data transfers outside the European Economic Area (EEA) to theUnited States are safeguarded through appropriate measures, such as StandardContractual Clauses (SCCs) pursuant to Article 46 GDPR. PostHog does not independently share your data with third parties, and we have executed a Data Processing Agreement (DPA) with PostHog to ensure GDPRcompliance. For more details, please review PostHog’s Privacy Policy. You can opt-out ofanalytics data collection anytime through your in-app settings or by contacting usdirectly as detailed in "How can you contact us about this notice?". - Email Marketing & Transactional Communication
We use MailerLite, a newsletter and email marketing platform provided by UAB“MailerLite”, based in the European Union, to send marketing communications tousers who have expressly opted in.If you subscribe to receive newsletters, updates, or promotional offers from us, yourname and email address will be processed by MailerLite solely for this purpose,under our instructions and in accordance with a Data Processing Agreement (DPA)as required by Article 28 GDPR. You can unsubscribe from marketingcommunications at any time by clicking the unsubscribe link included in every emailor by contacting us directly. MailerLite does not use your data for its own purposes.For more information, please refer to MailerLite’s Privacy Policy.
We use MailerSend, also operated by UAB “MailerLite”, to send essentialtransactional emails, such as important service-related updates (e.g. changes to ourPrivacy Policy or Terms of Service). These communications are necessary for theperformance of our services and may not be unsubscribed from.MailerSend processes your email address and related technical data solely to deliverthese messages on our behalf and under our instructions, in full compliance withGDPR and pursuant to Article 28 GDPR.Learn more about MailerSend’s privacy practices here: https://www.mailersend.com/legal/privacy-policy Both MailerLite and MailerSend store and process data in secure, ISO-certified datacenters located in the European Union. Where necessary, and in accordance withGDPR requirements, data transfers outside the EEA are protected using StandardContractual Clauses (SCCs). - Infrastructure and Cloud Hosting
We use cloud services provided by Amazon Web Services (AWS) to support varioustechnical components of our platform, including data hosting, account management,authentication, and transactional communications. Personal data may be processedby AWS solely on our behalf and under strict contractual and security controls incompliance with Article 28 GDPR.Where data is transferred outside the European Economic Area (EEA), such as to AWS infrastructure in the United States, we ensure appropriate safeguards are inplace, including Standard Contractual Clauses (SCCs) approved by the EuropeanCommission. You can learn more about AWS’s data protection practices at: https://aws.amazon.com/privacy/
5. DO WE USE COOKIES AND OTHER TRACKINGTECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store yourinformation.We use cookies and similar tracking technologies (like web beacons and pixels) to gatherinformation when you interact with our Services. These technologies help maintain thesecurity of our Services and your account, prevent crashes, fix bugs, save your preferences,and assist with basic functionality and user experience optimization. We may also allow third-party service providers to use tracking technologies on our Servicesfor analytics and marketing purposes. Specific details regarding the third-party providers weuse, such as our analytics provider, can be found under "WHEN AND WITH WHOM DO WESHARE YOUR PERSONAL INFORMATION?".We do not use cookies or tracking technologies before you create an account. By registeringand agreeing to our Privacy Policy, you consent to the use of necessary technologies foroperating and improving the app. You can manage analytics preferences at any time in theapp settings. Specific information about how we use such technologies and how you can refuse certaincookies can be followed in the next chapters.
5.1 Cookie Notice
This Cookie Notice explains how WhosClose ("we", "us", or "our") uses cookies and similartracking technologies in our mobile app. By using our services, you acknowledge our use ofthese technologies as described in this Notice.
5.2 What Are Cookies and Similar Technologies?
Cookies, SDKs (Software Development Kits), and similar tracking technologies are smallpieces of data stored on your device or sent from your device to a server. They help usprovide essential app functionalities, analytics, and better user experiences.
5.3 Categories of Cookies and Technologies We Use
(a) Essential and Functional TechnologiesThese technologies are necessary for the app to function correctly. Without them, keyfeatures such as user authentication, chat services, and SMS verification cannot operate.
- Twilio: Used for SMS verification codes essential for securing user accounts.
- GetStream: Powers our chat functionality, enabling real-time messaging and userinteractions.
(b) Analytics and Performance TechnologiesThese help us understand user behavior, optimize performance, and improve userexperience.
- PostHog: Provides insights on user interactions, app performance, and usagepatterns. Data collected includes device type, session duration, screen visits, IPaddresses (anonymized or truncated), and approximate location (based on IP).
(c) Location-Based ServicesThese technologies help us deliver location-based functionalities, such as event suggestionsor interactive maps.
- Google Maps API: Processes device location data (approximate or precise) toprovide map displays and nearby place recommendations.
(d) AI-Powered FeaturesSome features in our app are powered by artificial intelligence to assist with contentgeneration and personalization.
- OpenAI: We use services from OpenAI, L.L.C., based in the United States, to provideAI-assisted functionalities such as generating titles or content suggestions. Inputsand outputs may be processed by OpenAI. No directly identifiable personal data istransmitted. Data may be transferred to the U.S., and we rely on appropriatesafeguards such as Standard Contractual Clauses (SCCs) under Article 46 GDPR.For more information, see OpenAI’s Privacy Policy.
- Twilio: Used for SMS verification codes essential for securing user accounts.
- GetStream: Powers our chat functionality, enabling real-time messaging and userinteractions.
(b) Analytics and Performance TechnologiesThese help us understand user behavior, optimize performance, and improve userexperience.
- PostHog: Provides insights on user interactions, app performance, and usagepatterns. Data collected includes device type, session duration, screen visits, IPaddresses (anonymized or truncated), and approximate location (based on IP).
(c) Location-Based ServicesThese technologies help us deliver location-based functionalities, such as event suggestionsor interactive maps.
- Google Maps API: Processes device location data (approximate or precise) toprovide map displays and nearby place recommendations.
(d) AI-Powered FeaturesSome features in our app are powered by artificial intelligence to assist with contentgeneration and personalization.
- OpenAI: We use services from OpenAI, L.L.C., based in the United States, to provideAI-assisted functionalities such as generating titles or content suggestions. Inputsand outputs may be processed by OpenAI. No directly identifiable personal data istransmitted. Data may be transferred to the U.S., and we rely on appropriatesafeguards such as Standard Contractual Clauses (SCCs) under Article 46 GDPR.For more information, see OpenAI’s Privacy Policy.
5.4 How to Manage or Opt-Out
You have the right to manage or disable certain cookies and tracking technologies:
- PostHog Analytics: Adjust your in-app settings to opt-out of analytics tracking.
- Location Services: Manage your location permissions directly in your device’ssettings to restrict or disable access to location data.
Note: Essential technologies (Twilio, GetStream) are necessary for core functionalities, and itis not possible to manage or opt-out of these without significantly affecting your appexperience or rendering some services unavailable.
- PostHog Analytics: Adjust your in-app settings to opt-out of analytics tracking.
- Location Services: Manage your location permissions directly in your device’ssettings to restrict or disable access to location data.
Note: Essential technologies (Twilio, GetStream) are necessary for core functionalities, and itis not possible to manage or opt-out of these without significantly affecting your appexperience or rendering some services unavailable.
5.5 How Long Do Cookies and Data Remain Active?
Analytics data: Retained as defined in our Privacy Policy, typically not longer than necessaryfor analysis (see Privacy Policy “4. WHEN AND WITH WHOM DO WE SHARE YOURPERSONAL INFORMATION?”) Esential functionalities (Twilio, GetStream): Data retained as necessary for account management and service provision.
6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASEDPRODUCTS?
In Short: We offer products, features, or tools powered by artificial intelligence, machinelearning, or similar technologies.
As part of our Services, we offer features that are powered by artificial intelligence (AI) ormachine learning technologies (“AI Products”) to enhance functionality and improve userexperience. These features may include, for example, automatic generation of titlesbased on your interests and, in the future, AI-powered chat assistants to help youcreate meetups or use other parts of the platform. We provide these AI features through carefully selected third-party service providers (“AIService Providers”), including OpenAI. Your data — including inputs (e.g., interests,descriptions), outputs (e.g., suggested titles), and relevant context — may be processed bythese providers to deliver the AI-powered functionality described above.We use OpenAI’s API in a way that minimizes data exposure. No personally identifiableinformation is shared. Data sent through OpenAI is not used to train models, in accordancewith OpenAI's API data usage policy.All personal data processed using our AI Products is handled in accordance with this PrivacyNotice and applicable data protection laws, including the General Data ProtectionRegulation (GDPR). The processing is based on legitimate interest (Art. 6(1)(f) GDPR)and/or your consent where required (Art. 6(1)(a) GDPR), and is protected by appropriatesafeguards, including data minimization and secure transmission.You do not need to take any action to enable or disable these AI-powered features — theyare part of the platform’s core functionality. We remain fully responsible for ensuring thatyour data is processed securely and lawfully, and you are not responsible for the terms oractions of any AI provider.We do not use AI for profiling or automated decision-making that produces legal or similarlysignificant effects on you.
As part of our Services, we offer features that are powered by artificial intelligence (AI) ormachine learning technologies (“AI Products”) to enhance functionality and improve userexperience. These features may include, for example, automatic generation of titlesbased on your interests and, in the future, AI-powered chat assistants to help youcreate meetups or use other parts of the platform. We provide these AI features through carefully selected third-party service providers (“AIService Providers”), including OpenAI. Your data — including inputs (e.g., interests,descriptions), outputs (e.g., suggested titles), and relevant context — may be processed bythese providers to deliver the AI-powered functionality described above.We use OpenAI’s API in a way that minimizes data exposure. No personally identifiableinformation is shared. Data sent through OpenAI is not used to train models, in accordancewith OpenAI's API data usage policy.All personal data processed using our AI Products is handled in accordance with this PrivacyNotice and applicable data protection laws, including the General Data ProtectionRegulation (GDPR). The processing is based on legitimate interest (Art. 6(1)(f) GDPR)and/or your consent where required (Art. 6(1)(a) GDPR), and is protected by appropriatesafeguards, including data minimization and secure transmission.You do not need to take any action to enable or disable these AI-powered features — theyare part of the platform’s core functionality. We remain fully responsible for ensuring thatyour data is processed securely and lawfully, and you are not responsible for the terms oractions of any AI provider.We do not use AI for profiling or automated decision-making that produces legal or similarlysignificant effects on you.
7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our Services using a social media account, wemay have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party social mediaaccount details (like your Facebook or X logins). Where you choose to do this, we willreceive certain profile information about you from your social media provider. The profileinformation we receive may vary depending on the social media provider concerned, but willoften include your name, email address, friends list, and profile picture, as well as otherinformation you choose to make public on such a social media platform.
We will use the information we receive only for the purposes that are described in thisPrivacy Notice or that are otherwise made clear to you on the relevant Services. Please notethat we do not control, and are not responsible for, other uses of your personal informationby your third-party social media provider. We recommend that you review their privacy noticeto understand how they collect, use, and share your personal information, and how you canset your privacy preferences on their sites and apps.
Our Services offer you the ability to register and log in using your third-party social mediaaccount details (like your Facebook or X logins). Where you choose to do this, we willreceive certain profile information about you from your social media provider. The profileinformation we receive may vary depending on the social media provider concerned, but willoften include your name, email address, friends list, and profile picture, as well as otherinformation you choose to make public on such a social media platform.
We will use the information we receive only for the purposes that are described in thisPrivacy Notice or that are otherwise made clear to you on the relevant Services. Please notethat we do not control, and are not responsible for, other uses of your personal informationby your third-party social media provider. We recommend that you review their privacy noticeto understand how they collect, use, and share your personal information, and how you canset your privacy preferences on their sites and apps.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposesset out in this Privacy Notice, unless a longer retention period is required or permitted by law(such as tax, accounting, or other legal requirements). No purpose in this notice will requireus keeping your personal information for longer than the period of time in which users havean account with us.When we have no ongoing legitimate business need to process your personal information,we will either delete or anonymize such information, or, if this is not possible (for example,because your personal information has been stored in backup archives), then we willsecurely store your personal information and isolate it from any further processing untildeletion is possible.
We will only keep your personal information for as long as it is necessary for the purposesset out in this Privacy Notice, unless a longer retention period is required or permitted by law(such as tax, accounting, or other legal requirements). No purpose in this notice will requireus keeping your personal information for longer than the period of time in which users havean account with us.When we have no ongoing legitimate business need to process your personal information,we will either delete or anonymize such information, or, if this is not possible (for example,because your personal information has been stored in backup archives), then we willsecurely store your personal information and isolate it from any further processing untildeletion is possible.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizationaland technical security measures.
We have implemented appropriate and reasonable technical and organizational securitymeasures designed to protect the security of any personal information we process. However,despite our safeguards and efforts to secure your information, no electronic transmissionover the Internet or information storage technology can be guaranteed to be 100% secure,so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized thirdparties will not be able to defeat our security and improperly collect, access, steal, or modifyyour information. Although we will do our best to protect your personal information,transmission of personal information to and from our Services is at your own risk. You shouldonly access the Services within a secure environment.
We have implemented appropriate and reasonable technical and organizational securitymeasures designed to protect the security of any personal information we process. However,despite our safeguards and efforts to secure your information, no electronic transmissionover the Internet or information storage technology can be guaranteed to be 100% secure,so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized thirdparties will not be able to defeat our security and improperly collect, access, steal, or modifyyour information. Although we will do our best to protect your personal information,transmission of personal information to and from our Services is at your own risk. You shouldonly access the Services within a secure environment.
10. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom(UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at anytime, depending on your country, province, or state of residence.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights underapplicable data protection laws. These may include the right (i) to request access and obtaina copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict theprocessing of your personal information; (iv) if applicable, to data portability; and (v) not to besubject to automated decision-making. In certain circumstances, you may also have the rightto object to the processing of your personal information. You can make such a request bycontacting us by using the contact details provided in the section "HOW CAN YOUCONTACT US ABOUT THIS NOTICE?" below. We will consider and act upon any request in accordance with applicable data protectionlaws. If you are located in the EEA or UK and you believe we are unlawfully processing yourpersonal information, you also have the right to complain to your Member State dataprotection authority or UK data protection authority.If you are located in Switzerland, you may contact the Federal Data Protection andInformation Commissioner.
Withdrawing your consent:If we rely on your consent to process certain types of personal information — such as yourlocation, interests, public sharing of meetups, or the use of optional AI features — you havethe right to withdraw that consent at any time, without affecting the lawfulness of processingbased on consent before its withdrawal. You can withdraw your consent in the following ways:
- For specific features (such as location tracking, notifications, or public sharing), youcan manage or disable them directly via your device settings or, where available, viathe in-app preferences.
- For full withdrawal of consent regarding all processing based on consent, you maycontact us at the details provided in the section "HOW CAN YOU CONTACT USABOUT THIS NOTICE?". If full withdrawal is requested and essential parts of ourservices rely on that consent (e.g. user account functionality), this may result in thedeletion or deactivation of your account.
We will comply with your request in accordance with applicable data protection laws and willinform you about any consequences of the withdrawal (e.g., limitations in service use). However, please note that this will not affect the lawfulness of the processing before itswithdrawal nor, when applicable law allows, will it affect the processing of your personalinformation conducted in reliance on lawful processing grounds other than consent.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights underapplicable data protection laws. These may include the right (i) to request access and obtaina copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict theprocessing of your personal information; (iv) if applicable, to data portability; and (v) not to besubject to automated decision-making. In certain circumstances, you may also have the rightto object to the processing of your personal information. You can make such a request bycontacting us by using the contact details provided in the section "HOW CAN YOUCONTACT US ABOUT THIS NOTICE?" below. We will consider and act upon any request in accordance with applicable data protectionlaws. If you are located in the EEA or UK and you believe we are unlawfully processing yourpersonal information, you also have the right to complain to your Member State dataprotection authority or UK data protection authority.If you are located in Switzerland, you may contact the Federal Data Protection andInformation Commissioner.
Withdrawing your consent:If we rely on your consent to process certain types of personal information — such as yourlocation, interests, public sharing of meetups, or the use of optional AI features — you havethe right to withdraw that consent at any time, without affecting the lawfulness of processingbased on consent before its withdrawal. You can withdraw your consent in the following ways:
- For specific features (such as location tracking, notifications, or public sharing), youcan manage or disable them directly via your device settings or, where available, viathe in-app preferences.
- For full withdrawal of consent regarding all processing based on consent, you maycontact us at the details provided in the section "HOW CAN YOU CONTACT USABOUT THIS NOTICE?". If full withdrawal is requested and essential parts of ourservices rely on that consent (e.g. user account functionality), this may result in thedeletion or deactivation of your account.
We will comply with your request in accordance with applicable data protection laws and willinform you about any consequences of the withdrawal (e.g., limitations in service use). However, please note that this will not affect the lawfulness of the processing before itswithdrawal nor, when applicable law allows, will it affect the processing of your personalinformation conducted in reliance on lawful processing grounds other than consent.
Account Information
If you would at any time like to review or change the information in your account or terminateyour account, you can:
- Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account andinformation from our active databases. However, we may retain some information in our filesto prevent fraud, troubleshoot problems, assist with any investigations, enforce our legalterms and/or comply with applicable legal requirements.
- Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account andinformation from our active databases. However, we may retain some information in our filesto prevent fraud, troubleshoot problems, assist with any investigations, enforce our legalterms and/or comply with applicable legal requirements.
Cookies and similar technologies:
Most web browsers are set to accept cookies by default. If you prefer, you can usuallychoose to set your browser to remove cookies and to reject cookies. If you choose toremove cookies or reject cookies, this could affect certain features or services of ourServices.If you have questions or comments about your privacy rights, you may email us at dp@whosclose.app.
11. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include aDo-Not-Track ("DNT") feature or setting you can activate to signal your privacy preferencenot to have data about your online browsing activities monitored and collected. At this stage,no uniform technology standard for recognizing and implementing DNT signals has beenfinalized. As such, we do not currently respond to DNT browser signals or any othermechanism that automatically communicates your choice not to be tracked online. If astandard for online tracking is adopted that we must follow in the future, we will inform youabout that practice in a revised version of this Privacy Notice.
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicatedby an updated "Revised" date at the top of this Privacy Notice. If we make material changesto this Privacy Notice, we may notify you either by prominently posting a notice of suchchanges or by directly sending you a notification. We encourage you to review this PrivacyNotice frequently to be informed of how we are protecting your information.
We may update this Privacy Notice from time to time. The updated version will be indicatedby an updated "Revised" date at the top of this Privacy Notice. If we make material changesto this Privacy Notice, we may notify you either by prominently posting a notice of suchchanges or by directly sending you a notification. We encourage you to review this PrivacyNotice frequently to be informed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THISNOTICE?
If you have questions or comments about this notice, you may contact our Data ProtectionOfficer (DPO) by email at dp@whosclose.app, or contact us by post at:
WhosApp GmbHData Protection OfficerZugspitzstraße, 15, 82049, Pullach/Germany
If you are a resident in the European Economic Area or Switzerland, we are the "datacontroller" of your personal information. You can contact them directly regarding ourprocessing of your information, by email at dp@whosclose.app, or by post to:
Data Protection OfficerZugspitzstraße, 15, 82049, Pullach/Germany
WhosApp GmbHData Protection OfficerZugspitzstraße, 15, 82049, Pullach/Germany
If you are a resident in the European Economic Area or Switzerland, we are the "datacontroller" of your personal information. You can contact them directly regarding ourprocessing of your information, by email at dp@whosclose.app, or by post to:
Data Protection OfficerZugspitzstraße, 15, 82049, Pullach/Germany
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THEDATA WE COLLECT FROM YOU?
Based on the applicable laws of your country (such as the General Data ProtectionRegulation – GDPR in the European Union), you may have the right to:● Request access to the personal information we hold about you
- Receive information on how your data has been processed
- Correct inaccurate or outdated data
- Request the deletion of your personal information
- Withdraw your consent to processing where applicable
You can review, update, or delete your personal account information directly within theapp by accessing your account settings.If you wish to exercise other rights under data protection law — such as requesting a copy ofyour data, objecting to certain processing, or limiting its use — please contact us at dp@whosclose.app. We will respond in accordance with applicable legal requirements.Please note that these rights may be subject to certain limitations, for example, where weare legally required to retain data (e.g., for fraud prevention, legal compliance, or taxobligations).
- Receive information on how your data has been processed
- Correct inaccurate or outdated data
- Request the deletion of your personal information
- Withdraw your consent to processing where applicable
You can review, update, or delete your personal account information directly within theapp by accessing your account settings.If you wish to exercise other rights under data protection law — such as requesting a copy ofyour data, objecting to certain processing, or limiting its use — please contact us at dp@whosclose.app. We will respond in accordance with applicable legal requirements.Please note that these rights may be subject to certain limitations, for example, where weare legally required to retain data (e.g., for fraud prevention, legal compliance, or taxobligations).