Table of contents

Updated: June 5, 2024

Privacy Policy

Your privacy is important to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights with respect to your data.

What we collect and why

Identity and access

When you sign up for Whirr, we ask for identifying information such as your name, email address, and maybe a company name. That’s so you can personalize your new account, and we can send you product updates and other essential information. We may also send you optional surveys from time to time to help us understand how you use our products and to make improvements, as well as emails and other updates. We sometimes also give you the option to add a profile picture that displays in our products.

Billing information

If you sign up for a paid Whirr product, you will be asked to provide your payment information and billing address. Credit card information is submitted directly to our payment processor and doesn’t hit Whirr servers. We store a record of the payment transaction, including the last 4 digits of the credit card number, for purposes of account history, invoicing, and billing support. We store your billing address so we can charge you for service, calculate any sales tax due, send you invoices, and detect fraudulent credit card transactions. We occasionally use aggregate billing information to guide our marketing efforts.

Product interactions

We store on our servers the content that you upload or receive or maintain in your Whirr product accounts. This is so you can use our products as intended, for example, to create projects or to receive email. We keep this content as long as your account is active. If you delete your account, we’ll schedule a deletion of the contents.

General Geolocation data

For most of our products, we log the full IP address used to sign up a product account and retain that for use in mitigating future spammy signups. We also log all account access by full IP address for security and fraud prevention purposes, and we keep this login data for as long as your product account is active.

Website interactions

We collect information about your browsing activity for analytics and statistical purposes such as conversion rate testing and experimenting with new product designs. This includes, for example, your browser and operating system versions, your IP address, which web pages you visited and how long they took to load, and which website referred you to us. If you have an account and are signed in, these web analytics data may be tied to your IP address and user account until your account is no longer active. The web analytics we use are described further in the Advertising and Cookies section.

Anti-bot assessments

We may use CAPTCHA across our applications to mitigate brute force logins and as a means of spam protection. We have a legitimate interest in protecting our apps and the broader Internet community from credential stuffing attacks and spam. When you log into your Whirr accounts and when you fill in certain forms, the CAPTCHA service evaluates various information (e.g., IP address, how long the visitor has been on the app, mouse movements) to try to detect if the activity is from an automated program instead of a human. The CAPTCHA service then provides us with the spam score results; we do not have access to the evaluated information.

Ads and Cookies

We sometimes run contextual ads on various third-party platforms such as Google, Reddit, and LinkedIn. Users who click on one of our ads will be sent to the Whirr marketing site. Where permissible under law, we may load an ad-company script on their browsers that sets a third-party cookie and sends information to the ad network to enable evaluation of the effectiveness of our ads, e.g., which ad they clicked and which keyword triggered the ad, and whether they performed certain actions such as clicking a button or submitting a form.

We also use persistent first-party cookies and some third-party cookies to store certain preferences, make it easier for you to use our applications, and perform A/B testing as well as support some analytics.

A cookie is a piece of text stored by your browser. It may help remember login information and site preferences. It might also collect information such as your browser type, operating system, web pages visited, duration of visit, content viewed, and other click-stream data. You can adjust cookie retention settings and accept or block individual cookies in your browser settings, although our apps may not work and other aspects of our service may not function properly if you turn cookies off.

Voluntary correspondence

When you email Whirr with a question or to ask for help, we keep that correspondence, including your email address, so that we have a history of past correspondence to reference if you reach out in the future.

We also store information you may volunteer, for example, written responses to surveys. If you agree to a customer interview, we may ask for your permission to record the conversation for future reference or use. We will only do so with your express consent.

When we access or disclose your information

To provide products or services you’ve requested

We use some third-party subprocessors to help run our applications and provide the Services to you. We also use third-party processors for other business functions such as managing newsletter subscriptions, sending customer surveys, and providing our company storefront. We may disclose your information at your direction if you integrate a third-party service into your use of our products.

We may also access your data if required in order to respond to legal process (see "When required under applicable law" below).

To exclude you from seeing our ads

Where permissible by law and if you have a Whirr account, we may disclose a one-way hash of your email address with ad companies to exclude you from seeing our ads.

To help you troubleshoot or squash a software bug

If at any point we need to access your content to help you with a support case

To investigate, prevent, or take action regarding restricted uses

Accessing a customer’s account when investigating potential abuse is a measure of last resort. We want to protect the privacy and safety of both our customers and the people reporting issues to us, and we do our best to balance those responsibilities throughout the process. If we discover you are using our products for a restricted purpose, we will take action as necessary, including notifying appropriate authorities where warranted.

Aggregated and de-identified data

We may aggregate and/or de-identify information collected through the services. We may use de-identified or aggregated data for any purpose, including marketing or analytics.

When required under applicable law

Requests for user data. Our policy is to not respond to government requests for user data unless we are compelled by legal process or in limited circumstances in the event of an emergency request. However, if U.S. law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring us to disclose data, we must comply. Likewise, we will only respond to requests from government authorities outside the U.S. if compelled by the U.S. government through procedures outlined in a mutual legal assistance treaty or agreement. It is our policy to notify affected users before we disclose data unless we are legally prohibited from doing so, and except in some emergency cases.

Preservation requests. Similarly, our policy is to comply with requests to preserve data only if compelled by the U.S. Federal Stored Communications Act, 18 U.S.C. Section 2703(f), or by a properly served U.S. subpoena for civil matters. We do not disclose preserved data unless required by law or compelled by a court order that we choose not to appeal. Furthermore, unless we receive a proper warrant, court order, or subpoena before the required preservation period expires, we will destroy any preserved copies of customer data at the end of the preservation period.

If we are audited by a tax authority, we may be required to disclose billing-related information. If that happens, we will disclose only the minimum needed, such as billing addresses and tax exemption information.

Finally, if Whirr is acquired by or merges with another company we’ll notify you well before any of your personal information is transferred or becomes subject to a different privacy policy.

How we secure your data

All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted. In addition, all data is encrypted at rest and in transit.

What happens when you delete content in your account

In Whirr, we give you the option to trash content. Anything you trash in your account will be immediately and irrevocably deleted. This means the trashed content cannot be accessed via the application and we are not able to retrieve it for you.

If you choose to cancel your account, your content will become immediately inaccessible and should be purged from our systems in full within 60 days. This applies both for cases when an account owner directly cancels and for auto-canceled accounts.

Subprocessors

We use third-party subprocessors, such as cloud computing providers and customer support software, to run Whirr (the service).

The following is a list of personal data subprocessors we use and their purpose. These subprocessors are all located in the United States:

Data retention

We keep your information for the time necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and your choices, after which time we may delete and/or aggregate it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Through this policy, we have provided specific retention periods for certain types of information.

Location of site and data

Our products and other web properties are operated in the United States. If you are located in the European Union, UK, or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to and stored in the United States. By using our websites or Services and/or providing us with your personal information, you consent to this transfer.

We recommend speaking with legal counsel to determine how data privacy laws apply to specifically to you and your business.

GDPR and the European Union

Lawfulness of processing

When a user signs up with Whirr they are entering into a contract with Whirr, the service provider. The contract involves providing access to the SaaS platform, which allows them to create, manage, and deploy content like forms, onboarding, and surveys. The processing of personal data (such as email addresses, billing information, and account details) is necessary to fulfill the obligations of this contract. This includes setting up and maintaining the user’s account, providing access to the services, offering support, and handling billing and payments.

Data from the EU

The European Data Protection Board (EDPB) has issued guidance that personal data transferred out of the EU must be treated with the same level of protection that is granted under EU privacy law. UK law provides similar safeguards for UK user data that is transferred out of the UK.

There are also a few ad hoc cases where EU personal data may be transferred to the U.S. in connection with Whirr operations, for instance, if an EU user signs up for our newsletter or participates in one of our surveys. Such transfers are only occasional and data is transferred under the Article 49(1)(b) derogation under GDPR and the UK version of GDPR.

Inquiries related to Article 27 can be directed towards DataRep at: DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland. For other inquiries, please see the section below.

For information regarding GDPR please read our guide to create GDPR compliance for your online forms.

Changes and questions

We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will refresh the date at the top of this page.

For any questions, comments, or requests about this privacy policy or your data please get in touch by emailing us at privacy@whirr.co

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