This Privacy Notice was last updated on 3/16/2020.

This Privacy Notice for California Residents (“Privacy Notice”) supplements the information contained in our Privacy Policy, accessible at https://whisps.com/policies/privacy-policy, and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). Whisps Acquisition Corp. ("Whisps," "We," “Us,” or “Our”) adopts this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws

Your Rights and Choices

The CCPA provides California consumers specific rights concerning their personal information, including, the right to request that we disclose what personal information we collect, use, disclose, and sell. This Section describes your rights and how you may exercise those rights as well as describes how we and third parties handle your personal information.

You or your authorized agent can request: 1) a disclosure of your personal information we collect, use, disclose, or sell; 2) to delete your personal information we collect, or maintain; and 3) to opt-out of the sale of your personal information. If you choose to submit a request through an authorized agent, we will require proof that the authorized agent has your written permission to submit a request on your behalf. Additionally, we may require you to verify your identity with us through the verification process detailed below.

If you choose to exercise these rights, we will not discriminate against you because of it. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and will be described to you in writing. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Requests to Know and Requests to Delete

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you.
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

You also have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request to delete, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

You may submit a request to know or request to delete, free of charge, online through our interactive webform here, or through our toll-free number at 18334WHISPS. Note that for requests to delete, we will require you to separately confirm that you want your personal information deleted. To verify your identity, we require you provide your name and email or any other information necessary to verify your identity.  For some requests, we may also require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. Once submitted, you will receive an email within 10 days that we will use to verify your identity and provide confirmation of your request. We will respond to your request to know or request to delete within 45 days from the day we receive the request. If necessary, we may extend the time period to a maximum total of 90 days from the day we receive the request. In such case, you will receive an email notifying you of the extension and explaining the reason for the extension. Any disclosure in response to a request to know will cover the 12-month period preceding the business’s receipt of the request and will be delivered in a readily useable format, by mail or electronically at the consumer’s option.

Your request to know or request to delete may be denied for any reason allowable under the CCPA. For example, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it or any other purpose permitted by the CCPA.

Similarly, we may deny requests:

  • For specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of that personal information, your account with us, or the security of our systems or networks.
  • To access or delete information that is de-identified.
  • If your identity cannot be verified to a degree of certainty required by the CCPA.
  • From an authorized agent that does not submit proof that they have been authorized by the consumer to act on the consumer’s behalf.

Requests to Opt-Out

If you are 16 years of age or older, you have the right to opt-out from a sale of your personal information. We do not sell the personal information of consumers we actually know are less than 18 years of age, unless we receive affirmative authorization (the "right to opt-in") frin the parent or guardian of a consumer less than 18 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you may submit a request at Do Not Sell My Personal Information or through our toll-free number at18334WHISPS. We will act upon your request no later than 15 days from the date we received the request. Note that we may deny a request to opt-out if we have a good-faith, reasonable, and documented belief that the request is fraudulent. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time online here.

Collection of Personal Information

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

YES

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

NO

H. Sensory data.


Audio, electronic, visual, thermal, olfactory, or similar information.

 

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YES

 

We may obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you or your agent.
  • Indirectly from you or your agent. For example, through cookies and other automated technologies.
  • Directly and indirectly from activity on the Website.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • Provide you with functionality of the Website;
  • Administer and manage Whisps;
  • Provide client service and/or marketing products or services;
  • Conduct research and perform analysis to measure, maintain, protect, develop, and improve our products or services;
  • Administer, enhance, and communicate with you regarding Whisps’ events, marketing, and advertising; and/or
  • Make communications necessary to notify you regarding order confirmations, products, services, market research, requests, marketing, security, privacy, and administrative issues.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

Sharing Personal Information

In the preceding 12 months, we have disclosed and/or sold personal information to third parties for a commercial or business purpose, as authorized under applicable law. We do not sell the personal information of minors under 18 years of age without affirmative consent. In the preceding twelve (12) months, we have disclosed and sold the following categories of personal information for a business purpose:

Category A:         Identifiers.
Category B:         California Customer Records personal information categories.

Category C:         Protected Classification Characteristics.
Category D:         Commercial information.

Category F:         Internet or other similar network activity.

Category K:         Inferences drawn from other personal information.

We disclose and sell your personal information for a business purpose to the following categories of third parties:

  • Our affiliates and subsidiaries.
  • Vendors, consultants, and suppliers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

 

Contact Us

If you have any questions about this Privacy Notice or this Website, you may contact:

hello@whisps.com

18334WHISPS

199 Water Street

New York, NY 10018

 

 

 

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