privacy policy

Effective Date: 1 November 2020

Welcome! You have arrived at Whatever Brands website, provided by Whatever Brands Ltd. (“ Whatever ” or “ we ,” “ our ” or “ us ”), or you are otherwise interacting with our services or engaging with our events (the “ Services ”). We are committed to respecting and protecting your privacy.  It is important that you read and understand this Privacy Policy before using the Service.  To ease review, please click on each section heading below to link to the full explanation.

1. Scope

Except where otherwise stated, this Privacy Policy applies to the personal information (“ Personal Information ”) we collect through any online service location (e.g., website) that posts a link to this Privacy Policy (each a “ Site ”) (“ Online Channels ”); a certain offline collection of Personal Information through the Services (“ Offline Channels ”); and third-party sources (collectively, the “ Channels ”), as described in more detail below.

This Privacy Policy is intended to describe what information we collect about you, why we collect it, how we use it, and under what circumstances we may share it with third parties. To the extent we provide you different or additional privacy policies or notices in connection with the Services (e.g., at the point of our collection), those additional terms shall govern such data collection and use. In addition, please review the Site’s Terms of Use, which, in addition to this Privacy Policy, governs your use of the Site.   If you voluntarily provide your information in the course of participating with our Services or otherwise using or interacting with our Sites, you consent to our Privacy Policy and Terms of Use, including our collection, use, and sharing of your information and data, and other activities, as described in this Privacy Policy.   

Please note, unless otherwise stated, this Privacy Policy does not apply to the following:

  • Any Sites or Services that post separate online privacy policies;

  • Data collection activities that occur outside the Channels or Services;

  • Data collection practices of third parties that interact with or use our Services. For example, where we perform Services on behalf of our clients, the collection and use of Personal Information in connection with those Services is governed by our clients’ privacy policies, not this Privacy Policy.

2. Information We Collect

We may obtain the categories of Personal Information described below through the Channels, including from the following categories of sources.

a. Information You Provide to Us

On our Site or through our Services, we may ask you to provide us with or we may otherwise collect the following categories of Personal Information:

  • Your contact information (such as first and last name, phone number, email address, and postal address) for you or others (e.g., principals in your business);

  • Contact information you provide about other people that you refer to us;

  • Information used to create online accounts, such as username and password;

  • Certain biographical or demographic information (such as date of birth, age, gender, and job title/position);

  • Information relating to your Internet activity (such as IP address, browsing actions, usage patterns, and device information), as more fully described below;

  • Inferences about you, such as your preferences; and

  • Other information you submit to us, such as through our “Contact Us” feature.

We may also collect Personal Information when you:

  • Create or register for an account or otherwise save your information with us on our Site;

  • Sign up or request to be placed on our mailing, SMS/text and/or email marketing lists;

  • Participate in a survey;

  • Submit a posting on our Site that is viewable by us, and/or the general public; and/or

  • Otherwise interact with us through the Site or Service.

Participation in the Site and Services is completely voluntary.  You are not required to provide all Personal Information identified in this Privacy Policy; however, please be advised that if you do not provide the Personal Information requested, we may be unable to provide some or all of the Services to you, and your ability to use the Site may be limited.   

b. Information From Third-Party Sources 

We may also obtain certain Personal Information about you from third-party sources, such as: our clients and customers or prospective clients and customers; our Affiliates and subsidiaries; our service providers; and other third parties, such as lead generation partners, and other advertising, promotional and joint marketing partners.  We receive this information from third parties to help us provide and improve the Site and Services and for marketing and advertising.  We may supplement the information that you provide with information that we receive from third parties.

c. General Browsing As You Access and Use the Service 

In addition to any Personal Information or other information that you choose to submit to us via the Site or the Services, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Site or the Services (“ Usage Information ”).  This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “ Device ”) whenever you visit or interact with our Sites or the Services.  To the extent we associate Usage Information with your Personal Information we collect directly from you on the Site or the Services, we will treat it as Personal Information unless we have disclosed otherwise.

This Usage Information may include:

  • your IP address, UDID or other unique identifier (“ Device Identifier ”).  A Device Identifier is a number that is automatically assigned to your Device used to access the Site or the Services, and our computers identify your Device by its Device Identifier;

  • your Device functionality (including browser, operating system, hardware, mobile network information);

  • the URL that referred you to our Site or Services;

  • the areas within our Site or Service that you visit and your activities there, including remembering you and your preferences;

  • your Device location;

  • your Device characteristics; and

  • certain other Device data, including the time of day, among other information.

d. Use of Cookies and Other Tracking Technologies

We may use various methods and technologies to store or collect Usage Information (“ Tracking Technologies ”).  Tracking Technologies may set, change, alter or modify settings or configurations on your Device.  The Tracking Technologies we use on our Sites and other Services may include the following (and subsequent technology and methods later developed):

  • Cookies .  A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device.  Our Site may use HTTP cookies, HTML5 cookies, Flash cookies and other types of cookie technology to store information on local storage.

  • Web Beacons .  A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages.

  • Embedded Scripts .  An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links that you may click.

  • ETag .  An ETag or entity tag is a feature of the cache in browsers.  It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.

  • Browser Fingerprinting .  Collection and analysis of information from your Device, for example, your operating system, plug-ins, system fonts and other data, for purposes of identification.

  • Recognition Technologies .    Technologies that include application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

We use Tracking Technologies for a variety of purposes, including:

  • To allow you to use and access our Site and Service;

  • To prevent fraudulent activity and improved security functionality or to allow you to make use of other Site functionality;

  • To assess the performance of the Site for analytic purposes or otherwise to improve our Services offered through the Site;

  • To offer you enhanced functionality when accessing the Site, including identifying you when you sign in to our Site, keeping track of your specified preferences or to track your online activities over time and across third-party sites; and

  • To deliver ads and other content which may be of interest to you on our Site as well as third party sites, based on how you interact with the ads or other content on the Site.

There may be other Tracking Technologies used by us now or later developed and used by us in connection with the Service. For information and options to control or opt-out of certain data collection or uses related to Tracking Technologies, you can utilize the “Cookie Settings” button below, or see the Ads and Your Information section of this Privacy Policy. Please be aware that any changes you make to cookie settings may render certain functions of our website inoperable or more difficult to use. 


Cookie Settings

Internet browsers also provide help pages relating to cookie management. Below are links to the help pages for the most common internet browsers:

  • Google Chrome

  • Internet Explorer

  • Mozilla Firefox

  • Safari (desktop)

  • Safari (mobile)

  • Android Browser

e. Information We Collect When You Interact with Third-Party Sites  

In addition, third parties may use Tracking Technologies in connection with our Sites, which may include the collection of information about your online activities over time and across third-party web sites or online services.  We may not control those Tracking Technologies, and we are not responsible for them.  For example, the Site may include functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application.  The use of this functionality may involve the third-party site providing information to us.  For example, we may provide links on the Site to facilitate you sending a communication from the Site or we may use third parties to facilitate you sending emails, or making Tweets or Facebook, Instagram, or Pinterest postings.  These third parties may retain any information used or provided in any such communications or activities, and these third parties’ practices are not subject to our Privacy Policy.  We may not control or have access to your communications sent through those third parties.  Further, when you use third-party sites or services, you are using their services and not our Services and the third parties, not Whatever Brands, are responsible for their practices.  You should review the applicable third-party privacy policies before using such third-party tools on our Site.

f. Information You Provide About a Third Party 

You may send someone else a communication from the Site or using the Services, such as sending posting to a friend.  In addition, you may send us information regarding someone else.  If so, the information you provide (names, e-mail addresses, etc.) is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise.  Please be aware that when you use any send-to-a-friend functionality on our Site or Service, your contact information, name or user name and message may be included in the communication sent to your addressee(s).  Some of these tools may be third-party tools subject to third-party privacy policies.

g. Anonymised Information

We may create de-identified or anonymous data from Personal Information by removing data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you or through obfuscation or through other means (“ Anonymised Information ”).  Our use of Anonymised Information is not subject to this Privacy Policy.

3. Why We Collect Your Information

We may use your Personal Information or Usage Information for the following purposes:

  • Helping to establish and verify the identity of visitors to the Site or users of the Services;

  • Opening, maintaining, administering and servicing accounts on our Site or through our Services;

  • Communicating transaction opportunities and related communications;

  • Providing the Services;

  • Improving the Site, including performing usage analytics and tailoring to your preferences;

  • Providing you with updates to the Services and other important updates;

  • Responding to your questions, inquiries, comments, complaints and instructions; and

  • Maintaining the security and integrity of our systems, including the Site.

4. How Do We Share Your Information?

We do not share your Personal Information that we have collected directly from you on our Service with third parties for those third parties’ direct marketing purposes unless we have given you the choice to consent or withhold consent to such sharing at the time you provide your Personal Information.  In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy or any notice provided at the time your Personal Information is collected.

(a) When You Request Information From Third Parties.  You may be presented with an option on our Site or through our Services to receive certain information and/or marketing offers directly from third parties, or to have us send certain information to third parties or give them access to it for the purpose of providing information to you.  If you choose to do so, your Personal Information and other information may be disclosed to such third parties, and the disclosed information will also be subject to the privacy policies and practices of those third parties.  In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our Sites or link to them from our Site or Services.  This may include using third-party tools such as Facebook, Linkedin, Twitter, Pinterest or other third-party posting or content sharing tools.  We are not responsible for the privacy policies and practices of such third parties; therefore, you should review carefully the privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.

(b) Third Parties Providing Services on Our Behalf .  We may use third-party service providers to perform certain services on behalf of us or the Site, such as (i) assisting with the Site operations, (ii) hosting the Site, (iii) designing and/or operating the Site’s features, (iv) tracking the Site’s activities and analytics, and (v) enabling us to send you special offers or perform other administrative services.  We may provide these service providers with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing.

(c) To Protect the Rights of Whatever Brands and Others .  We may share Personal Information with governmental authorities when legally required to do so, and to cooperate with such authorities investigating claims of illegal activity such as (but not limited to) illegal transfer of copyrighted material, or user website postings or email messages that contain threats of violence. To the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Whatever Brands or third parties (including through the enforcement of this Privacy Policy, our Terms of Use, and other applicable agreements and policies); (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders); or (iii) in other cases where we have reason to believe that disclosure is necessary to enforce compliance with our Terms of Use.  To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.

(d) Affiliates and Business Transfer.   Subject to applicable law, we may share your information, including your Device Identifiers and Personal Information, and Usage Information with our affiliated companies, subsidiaries, joint ventures, and other companies under our common control (“ Affiliates ”).  We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Site or Service or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including during the course of any due diligence process.

(e) Co-Branded Areas.  Certain areas of the Service may be provided to you in association with third parties (“Co-Branded Areas”) and may request that you disclose Personal Information to them.  Such Co-Branded Areas will identify the third party and indicate if they have a privacy policy that applies to their collection and use of your information.  If you elect to register for services, communicate with such third parties or download their content or applications, at Co-Branded Areas, you may be providing your information to both Whatever Brands and the third party.  Further, if you sign-in to a Co-Branded Area with a username and password obtained on the Service, your Personal Information may be disclosed to the identified third parties for that Co-Branded Area.  We are not responsible for such third party’s data collection or practices and you should review such third-party privacy policies for more information.   

(f) Our Clients and Customers. If we collect Personal Information from you in connection with Services we perform on a client’s or customer’s behalf, we may share that Personal Information with such client or customer. In such cases, the collection and use of this Personal Information is governed by our client’s or customer’s (as applicable) privacy policy, and not by our Privacy Policy. For more information, you will need to contact the relevant client or customer.

5. Third-Party Content and Links to Other Sites

The Service may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Site are served to you.  In addition, the Site or Service may contain links or otherwise provide access to another website, mobile application, or Internet location that we do not control (collectively “Third-Party Sites”).  Occasionally, when linking to a Third-Party Site, you may still see our Site’s logo or frame. This is to provide you with a seamless experience when visiting our Site.  In those cases, you are no longer on our Site and are now on a different website whose information collection practices may differ from ours. Please note that we have no control over and are not responsible for Third-Party Sites, their content, or any goods or services available through the Third-Party Sites. Our Privacy Policy does not apply to Third-Party Sites.  We encourage you to read the privacy policies of any Third-Party Site with which you choose to interact.

6. Ads and Your Information

You may see certain ads on other websites because we participate in advertising networks administered by third parties.  These networks track your online activities over time and across third party websites and online services by collecting information through automated means, including through the use of the Tracking Technologies described above, and they use this information to show you advertisements that are tailored to your individual interests.  The information they collect includes information about your visits to our Site, such as the pages you have viewed.  This collection and ad targeting takes place both on our Site and on third-party websites that participate in the ad network. This process also helps us track the effectiveness of our marketing efforts.

We may also use Tracking Technologies, such as our own cookies, to provide you with personalized online display advertising tailored to your interests.  We and third-party service providers, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as a DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Site.  To learn more about how to opt out of Google’s use of the Google analytics cookies, visit, here .  To learn more about how to opt out of DoubleClick’s use of cookies, visit the DoubleClick opt-out page, here .  If you would like more information about behavioral advertising practices, please visit www.aboutads.info .  To learn about your choices in connection with these practices on the particular device on which you are accessing this Privacy Policy, please visit http://www.networkadvertising.org/choices and http://www.aboutads.info/choices .  You may also click on the informational icon contained within each interest based ad.

Third-party Tracking Technologies are not controlled by us, even if they use our technology to help store or collect data.  Statements regarding our practices do not apply to the methods for collecting information used by these third-party advertisers and others or the use of the information that such third parties collect.  The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices.  We make no representations regarding the policies or practices of third-party advertisers or advertising networks or exchanges or related third parties.

7. Your California Privacy Rights

This section applies to any California residents about whom we have collected Personal Information from any source, including through your interaction with the Site or the Services, or by communicating with us electronically, in paper correspondence, or in person. As a reminder, this Privacy Policy does not apply to the data practices of third parties, including our clients and customers. If we collected your Personal Information on a client’s or customer’s behalf, you must submit any requests under this section to the relevant client or customer for which we collected your Personal Information.

a. Your Information

To review what information we collect, where we get it from, how we use it and how we share it, please visit the following sections of this Privacy Policy:

  • Information We Collect – to review what information we collect and where we get it from

  • Why We Collect Your Information – to review how we use your Personal Information

  • How Do We Share Your Information? – to review who has access to your Personal Information

b. Your Rights Under California Law

If you are a California resident, subject to applicable law, you have the following rights under California law with respect to your Personal Information:

  • Right to Know.   You have the right to request what Personal Information we collect, use, disclose, and/or sell, as applicable.

  • Right to Delete.  You have the right to request the deletion of your Personal Information that is collected or maintained by us.

  • Right to Non-Discrimination.   You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.

  • Right to Opt Out of “Sale”. You have the right to direct us not to “sell” your Personal Information, as that term is defined in the CCPA. Because some uses of third party services identified in the Use of Cookies and Other Tracking Technologies sections may constitute a “sale” under the CCPA, we encourage you to exercise the choices available there from every browser that you use to access our Sites and the Services. Other than the foregoing, the Sites and Services covered by this Privacy Policy do not sell your Personal Information.

You may also authorize someone to exercise the above rights on your behalf. When this individual submits a request, they will need to indicate on the webform or during the phone call that they are authorized to do so on your behalf, and supply us with evidence of this authorization; we will not fulfill a request submitted by a third party related to your Personal Information until we have received confirmation of your authorization for that individual to submit a request on your behalf.  If we have collected information on your minor child, you may exercise the above rights on behalf of your minor child.

The above rights are subject to our being able to reasonably verify your identity and authority to make these requests.  These rights are also subject to various exclusions and exceptions under applicable laws.  We will verify your identity by matching information you provide in your request with the information in our systems; and by requiring you to respond to an automated email sent to your email address upon submitting a request.

If you are a California resident and wish to exercise these rights, please reach us in one of the following ways:

For more information regarding this Privacy Policy, or if you have any questions or concerns, you may contact us in the following ways:

Whatever Brands Ltd.

71-75 Uxbridge Road,

Ealing, London, W5 5SL

 

T: +44 (0) 207 117 2970
 

8. Your Rights and Choices About the Information We Collect

Individuals in certain jurisdictions have certain rights under applicable data protection law.  Rights specific to California residents are described in Section 7 .  Subject to applicable law, you may have the right to request access to, modification or correction of, or deletion of certain of your Personal Information that we maintain, and how that information has been used or disclosed. In addition, you may also have the right to direct Whatever Brands not to sell certain of your Personal Information that we have collected or will collect about you.

To exercise your rights, you may contact us as at privacy@advantagesolutions.net or at the mailing address noted below. As permitted by law, certain data elements may not be subject to access, modification, correction, and/or deletion.  Furthermore, where permissible, we may charge for this service.  We will respond to reasonable requests as soon as practicable and as required by law.  To protect your privacy and security, we may take steps to verify your identity in order to respond to your request.

Applicants can update or change your contact information by logging into your account and making changes in your Profile Settings.

If you would like to stop receiving newsletters or other marketing or promotional messages, notifications, or updates from us, you may do so by following the unsubscribe instructions that appear in these e-mail communications.  Alternatively, you may opt-out of marketing e-mails from Whatever Brands by taking any one of the following actions:

  • Send an e-mail with your request and current information to hey@whateverbrands.com; or

  • Send a request in writing with your current information to:

Whatever Brands Ltd.

71-75 Uxbridge Road,

Ealing, London, W5 5SL

T: +44 (0) 207 117 2970

 

Please be advised that you may not be able to opt-out of receiving certain service or transactional messages from us, including legal notices.

9. Protecting the Privacy of Minors

We recognize the importance of children’s safety and privacy. Our Sites and Services are not designed to attract children and are not intended for use by any children under the age of 16. We do not knowingly request or collect Personal Information from children under the age of 16.  We are a general audience Site and Service and do not use the Site to collect Personal Information from children under the age of 16.  If you are under 16 years of age, you are not permitted to use the Site and should not send any information about yourself to us through the Site.

In the event that we become aware that we have collected Personal Information from a child under the age of 16, we will take steps to dispose of that information as permitted by law and in accordance with the Children’s Online Privacy Protection Act (“COPPA”) and other applicable laws and regulations.  If you are a parent or guardian and you believe that your child under the age of 16 has provided us with Personal Information without your consent, please contact us at hey@whateverbrands.com.

10. Do Not Track Disclosures

Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals).  Currently, we do not monitor or take any action with respect to these signals or other mechanisms.

11. Visitors to the Site from the United Kingdom and European Economic Area

This section of our Privacy Policy only applies to the extent you are a resident of the UK or EEA. We are the data controller of your Personal Information that we collect through the Site. For Personal Information we collect or process on behalf of our client, our client is the data controller, and we are the data processor; and any such collection and processing of your Personal Information is governed by our client’s privacy policy.

We process your Personal Information under the following legal bases:

  • Our legal obligations . We may need to process your Personal Information to comply with relevant laws, and regulatory requirements, or to respond to lawful requests, court orders, and legal processes.

  • Your prior consent . For example, we rely on your prior consent to place cookies on your device (subject to certain exceptions) or send you marketing communications. You can withdraw consent at any time for the placement of cookies using the Cookie Settings feature in the Use of Cookies and Other Tracking Technologies section of this Privacy Policy, or for marketing communications by following the unsubscribe instructions contained in that communication.

  • Our legitimate interests . We process your Personal Information:

    • To facilitate communication between you and the Site, or carry out actions you request;

    • For the security and safety of the Site, any technology connected to the Site, and visitors to the Site;

    • To detect and prevent fraud;

    • To protect and defend our rights and property or that of others;

    • To manage and administer the Site, including analyzing web traffic and utilizing web analytics solutions.

  • To perform a contract . We will process your Personal Information in connection with your requests or any contracts which you enter with us.

The following rights are provided to residents of the UK or EEA under the General Data Protection Regulation (GDPR), subject to certain conditions:

  • Right to Know.   You have the right to request what personal information we collect and process.

  • Right to Access. You have the right to request access to, or copies of, the personal information we process in a portable format.

  • Right to Delete.  You have the right to request the deletion of your personal information, subject to legal and other obligations.

  • Right to Correction . You have the right to request corrections to any inaccuracies in your personal information.

  • Right to Object . You have the right to object, with legitimate grounds, to the processing of your personal information, subject to legal and other obligations.

  • Right to Restrict Processing . You have the right to request we restrict the processing of your personal information in certain situations.

  • Right to Lodge a Complaint : You have the right to file a complaint with your applicable data protection authority, which can be located here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm .

If you are a resident of the UK or EEA and wish to exercise these rights, please email hey@whateverbrands.com

12. Security

We implement technical and organizational safeguards designed to help protect and secure your Personal Information. We have taken steps to ensure that only our personnel and contractors who are granted access to your Personal Information are those with a business ‘need-to-know’ or whose duties reasonably require such information.

Please note, however, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from our Site.

13. Updates to Privacy Policy

We may update this Privacy Policy from time to time.  The most recent version of the Privacy Policy is reflected by the version date located at the top of this Privacy Policy. We encourage you to review this Privacy Policy often to stay informed of how we may process your information.

14. Contact Us

For more information about our privacy practices, or if you have questions or concerns, please contact us by e-mail at hey@whateverbrands.com or by mail using the details provided below:

Whatever Brands Ltd.

71-75 Uxbridge Road,

Ealing, London, W5 5SL

T: +44 (0) 207 117 2970