Privacy Policy

1. Definitions

• Account: A unique profile created to access Our Services.
• App User: Individuals who use the Whisper Sweet Nothings mobile application.
• Personal Data: Information that identifies or relates to a natural person (e.g., name, messages, payment details, verification information).
• Processing: Any operation performed on Personal Data (e.g., collection, storage, analysis).
• Services: Whisper Sweet Nothings' dating application, website at whispersweetnothings.app, and related tools.
• User: Anyone interacting with Our Services, including App Users and website visitors.

2. Data Collection and Use

2.1 Data Provided Directly by You

App Users:

Data collected includes name, email, date of birth, phone number, profile preferences, game responses, messages, and verification information. The purpose of collecting this data is for account creation, identity verification, matchmaking, service delivery, safety, and customer support. This data may be shared with payment processors (Stripe, PayPal), cloud hosting providers (AWS), and safety or moderation service providers.

Website Visitors:

Data collected includes IP address, cookies, session activity, and contact form submissions. The purpose of collecting this data is to support website functionality, perform analytics, conduct marketing, and respond to inquiries. This data may be shared with marketing tools (HubSpot) and cookie management platforms (OneTrust).

Demo/Trial Users:

Data collected includes name, email, phone number, and location details. The purpose of collecting this data is to provide product demonstrations and evaluate trial eligibility. This data may be shared with sales automation tools (Salesforce) and communication platforms (Twilio).

Job Applicants:

Data collected includes resume, employment history, education, and references. The purpose of collecting this data is to evaluate candidacy for open roles. This data may be shared with HR management systems (Greenhouse) and background check providers.

2.2 Data Collected Automatically

• Game Interaction Data: Game responses, match activity, and metadata (e.g., session duration, participation patterns) to improve the dating experience and platform safety.
• Usage Analytics: Feature adoption rates, error logs, and session heatmaps to optimize service performance.
• Device/Technical Data: Browser type, operating system, device identifiers, and IP address for security monitoring and compatibility fixes.

3. Data Sharing and Disclosure

We share Personal Data with:

• Matched Users: Limited profile and interaction information is shared with other users only when you match and choose to interact.
• Service Providers: Payment processors (Stripe), cloud hosts (AWS), analytics providers, and safety partners under strict confidentiality agreements.
• Legal Authorities: To comply with lawful requests, court orders, or regulatory requirements.
• Business Transfers: In mergers, acquisitions, or asset sales, with guarantees of continued privacy compliance.

We do not sell Personal Data to third parties for marketing purposes.

4. International Data Transfers

Data may be transferred globally, including to the U.S., India, and EU-based servers. Transfers adhere to:

• GDPR: Standard Contractual Clauses (SCCs) for EU/UK data.
• CCPA/CPRA: Limits on "selling/sharing" California residents' data.

5. Legal Basis for Processing (GDPR/UK)

• Contractual Necessity: Use cases under this basis include providing services, processing payments, and enforcing Terms of Use.
• Legitimate Interest: This basis covers use cases such as fraud prevention, service improvements, safety moderation, and marketing (with opt-out options).
• Consent: This applies to optional data uses (e.g., newsletters, beta testing).

6. California Privacy Rights (CCPA/CPRA)

California residents may:

• Opt out of data "sales" (though We do not sell data).
• Request deletion of Personal Data, excluding legally retained records.
• Access a report detailing data categories collected in the past 12 months.

Submit requests to activate@pingbase.ai.

7. Security Measures

• Encryption: Personal and payment data encrypted in transit (TLS 1.2+) and at rest (AES-256).
• Access Controls: Role-based permissions and audit logs for employee/data contractor access.
• Incident Response: 24/7 monitoring and breach notification within 72 hours of detection.

8. Data Retention

• Account Data: Retained while your account is active and for a reasonable period after deletion, unless longer retention is required by law.
• Payment Information: Retained until subscription termination plus 7 years for tax compliance.
• Analytics Data: Retained for 3 years (aggregated/anonymized after 12 months).

9. Your Rights

• Access/Portability: Request a copy of your data in machine-readable format.
• Correction: Update inaccuracies in your Account profile.
• Deletion: Delete your whole account in the app: Lobby → Profile → Delete account. Steps, and what is deleted or kept, are at whispersweetnothings.app/delete-account.
• Object/Restrict: Limit processing for marketing or legitimate interests.

Submit requests to activate@pingbase.ai. Response time: 30 days.

10. Cookies and Tracking

• Essential Cookies: Used for session management, security, and payment processing. Opt-out is not optional.
• Analytics Cookies: Used for feature usage trends and error rate monitoring (Google Analytics). Opt-out is available through browser settings or the cookie banner.
• Marketing Cookies: Used for retargeting ads and campaign performance (LinkedIn, Facebook Pixel). Opt-out is available via ad platform opt-out tools or the cookie banner.

11. Children's Privacy

Services are not intended for users under 18. We do not knowingly collect data from minors.

12. Updates and Contact

Policy changes will be posted at https://whispersweetnothings.app/privacy. For questions, contact:

Email: activate@pingbase.ai
Mail: Pingbase, Inc., 2136 Ford Parkway, Saint Paul, MN 55116