Whering Privacy Policy

Last modified: 13th August 2023

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING WHERING LTD SERVICES.

You must be 16 years old or older to use our Services.

Protecting your privacy is very important to Whering Ltd (“Whering”, “us”, “our” or “we”). Our privacy policy (the “Privacy Policy”) together with our Terms and Conditions, our Cookies Policy and any other documents referred therein, is an opportunity for us to be transparent with you about our privacy practices when you use our mobile application (the “App”) and our website (whering.co.uk, hereinafter the “Website”) or any of our related products and services (together the “Services”).

Please read this Privacy Policy carefully to understand the type of personal data (as defined under the General Data Protection Regulation (EU) 2016/679, hereinafter the “Personal Data”) we collect from you when you use our Services, how and why we will use it, how we will protect it, and what are your rights in relations to it.

By requesting access to or using our Services you are agreeing to this Privacy Policy. If you do not agree to this Privacy Policy, please do not use our Services.

If after reading this Privacy Policy you still have questions, please don’t hesitate to contact us on data@whering.co.uk.

  1. Who we are

The company in charge of your Personal Data (also known as the data controller, as defined under the General Data Protection Regulation (EU) 2016/679, hereinafter the “Data Controller”) is Whering Ltd, with an address at 396 Saint John St EC1V 4NJ, and registered with the UK Information Commissioner’s Officer under the number 00310075129.

  1. What Personal Data we collect from you, how we collect it and for what purpose

We collect Personal Data from you either automatically, when you give it to us directly, or when we receive it from other sources. We do this to operate effectively and provide you with the best experience when using our Services.

You have choices about the Personal Data we collect from you. So, when you are asked to provide us with your Personal Data, you always have the right not to do so. Please note however that if you choose not to provide us with your Personal Data when prompted, you may not be able to use our Services.

The Personal Data we collect depends on the context of your interactions with our Services and the choices you make, and includes the following:

  1. When you access our Services

Types of Personal Data:

  • Device and technical information: unique device identifiers, browser type and version, operating system and platform, hardware used, browser plug-in types and versions.
  • Location and Usage information: IP address, URLs, Referrer URL, date and time of access, information about page response times, length of visits to certain pages, interaction information (such as scrolling, clicks, and mouse-overs), error reports and performance data.
  • Payment information: If you make any payments on our Website, we will retain details of your transactions. We will not retain your credit or debit card information - it will be processed directly by a third-party processor

Purpose:  We use your Personal Data to provide you with access to our Services.

How we collect it: Automatically when you access our Services.

Legal basis: Legitimate interest

Storage duration: We store your Personal Data for sixty (60) days. After sixty (60) days your Personal Data is deleted, unless a security event which requires us to keep your Personal Data occurs. In such a case, your Personal Data will be deleted once the security event is remediated.

  1. When you open a Whering account and use our Services

Types of Personal Data:

  • Contact and identification information: First name, last name, e-mail address, username, gender preference, profile picture, phone number, personal description, country, date of birth.
  • Security information: login information, password
  • Location and technical information:  time and location of registration
  • Identification information: clothes photos

Purpose: We use your Personal Data to provide you with a Whering account and allow you to use our Services.

How we collect it: When you directly give it to us by opening a Whering account.

Legal basis: Consent and contract performance

Storage duration: We store your Personal Data until the deletion of your Whering account. Once you delete your Whering account, we will - with your consent - keep your Personal Data for three (3) months thereafter, in case you change your mind and want to easily use our Services again. You always have the choice to tell us that you want your Personal Data to be deleted immediately following the deletion of your Whering account by writing to us on data@whering.co.uk

  1. To ensure the functioning, maintenance, and improvement our Services

Types of Personal Data:

  • Device and technical information: Device ID, unique device identifiers, operating system and platform, hardware used, browser plug-in types and versions, error, crash reports.
  • Location and Usage information: IP address, URL, Referrer URL, length of visits to certain pages and page interaction information such as scrolling, finger gestures, clicks, and mouse-overs, geographic location, date and time of access.Identification information: clothes photos

Purpose: We use your Personal Data to ensure the proper use, functioning, maintenance and improvement of our Services including our Artificial Intelligence system.s.

How we collect it: Automatically when you use our Services.

Legal basis: Legitimate interest

Storage duration: We store your Personal Data for sixty (60) days. After sixty (60) days your Personal Data is deleted, unless a security event which requires us to keep your Personal Data occurs. In such a case, your Personal Data will be deleted once the security event is remediated.

  1. Facebook, Google and Apple log-in

Types of Personal Data:

  • Identification informatioFacebook ID, Apple user ID, Google user ID, email address.
  • Usage information: Time and date of the login.

Purpose: We use your Personal Data to allow you to login via Facebook, Apple or Google. 

How we collect it: Automatically when you choose to login via Facebook, Apple or Google. 

Legal basis: Legitimate interest

Storage duration: We store your Personal Data for as long as you have a Whering account. Please note that if you use the Facebook login, Google login or the Apple login, Facebook, Google or Apple may also process your Personal Data. We are not responsible for this data processing and we urge you to review their respective privacy policies. Personal Data may remain in Facebook’s, Google’s or Apple’s server. Should you delete your Facebook or Google account or stop using your Apple device and wish to use the App, you will be directed to sign-in with an email or other login procedure. 

  1. For marketing purposes and to optimise our marketing initiatives

Types of Personal Data:

  • Contact information: First name, last name, e-mail address, gender preference.
  • Device and technical information: Device ID, operating system and browser type.
  • Location and Usage information: Length of visits to certain pages, and page interaction information such as scrolling, finger gestures, clicks, and mouse-overs, geographic location, date and time of access.

Purpose: We use your Personal Data to send your marketing communications that we believe will be of interest to you, and to optimise our marketing initiatives. You can always change your marketing preferences at any time by unsubscribing via the link at the bottom of each marketing email, and/or customising your privacy settings within the App.

How we collect it: When you explicitly give it to us by subscribing to our marketing communications.

Legal basis: Consent

Storage duration: We store your Personal Data until you revoke your consent.

  1. For push notifications

Types of Personal Data:

  • Contact information: First name, last name, e-mail address

Purpose: To send you push notifications in the App to help you make the best use of our functionalities.

How we collect it: When you explicitly give it to us by agreeing to receive push notifications. 

Legal basis: Consent

Storage duration: We store your Personal Data until you revoke your consent.

  1. For important communication purposes

Types of Personal Data:

  • Contact information: First name, last name, e-mail address, gender preference

Purpose: We use your Personal Data to send you important communications about our Services (ie:, for example to update you about changes to our Terms and Conditions or when our Services are down). Please note that you cannot unsubscribe from these types of communications as they contain important information about our Services. We will not send your marketing content as part of these communications.

How we collect it: When you directly give it to us by opening a Whering account. . 

Legal basis: Legitimate interest

Storage duration: We store your Personal Data until the deletion of your Whering account.

  1. For feedback and research purposes

Types of Personal Data:

  • Contact information: First name, last name, e-mail address, age, gender preference.
  • Feedback information such as quotes regarding your use of our Services.

Purpose: We use your Personal Data to assess your satisfaction with our Services.

How we collect it: When you directly give it to us when contacted for feedback and research purposes.

Legal basis: Consent

Storage duration: We will store your Personal Data until it is no longer required for the feedback or research purposes for which it was collected. This depends on the setup of the individual survey or equivalent process you take part in.

  1. For job application purposes

Types of Personal Data:

  • Contact information: First name, last name, e-mail address, phone number, gender preference.
  • Location information: Geographic location.
  • Social media information: LinkedIn profile.

Purpose: We use your Personal Data to check your suitability for the position and to conduct the application process.

How we collect it: When you directly give it to us when applying for a job at Whering.

Legal basis: Consent

Storage duration: In the event of a rejection, your Personal Data will be deleted after six (6) months. If you have agreed for us to keep your Personal Data, we will add your Personal Data to our applicant pool. If you are offered a job in the context of the application process, your Personal Data will be transferred to our human resources.

  1. Where we store your Personal Data

We store your Personal Data on Google Cloud Platform. We use the europe-west2 (UK), europe-west1 (Belgium), europe-west4 (Netherlands) and europe-north1 (Finland) data centers.

Please note that your Personal Data may however be processed by our business partners and service providers operating outside of the European Union (as further set forth in Section 4 and 5 of this Privacy Policy). We have agreed on Standard Contractual Clauses and additional contractual obligations with each of these business partners service providers. In addition, we will assess, on a case-by-case basis, the risks for your rights and privacy, together with and the necessity to keep them to provide you with our Services.

  1. Who we share your Personal Data with

First of all, please rest assured that we do not use or share your Personal Data with others except as described in this Privacy Notice, nor do we ever sell your Personal Data.

We may however disclose your Personal Data in the following circumstances:

  • When the disclosure is requested by you, with consent or to perform a contract with you.
  • When working with our business partners and our service providers, who act as our processors under Data Processing Agreements. Please note that to a limited extent, we do work with business partners and service providers situated outside of the European Union, but only do so with the appropriate safeguards in place, including Standard Contractual Clauses as well as additional contractual obligations. A list of business partners and service providers can be found in section 5 of this Privacy Policy.
  • When we sell, merge, or change the control of Whering or in preparation for any of these events, in which case the prospective buyer will have the right to continue to use your Personal Data, but only in the manner set out in this Privacy Policy unless you agree otherwise.
  • When required by law, subpoenas, court orders, or other legal processes.

  1. Our business and service providers

We work with the following business partners and service providers to provide you with our Services:

  • Infrastructure
  • Google LLC (Google Cloud Platform, Firebase)
  • Mongo DB Inc. (Mongo DB Cloud Services)
  • Nevercode Ltd. (Codemagic)
  • Pixyle B.V. (pixyle.ai)
  • Kaleido AI GmbH. (remove.bg)
  • Platform hosting
  • Apple, Inc. (Apple Store)
  • Google, Inc. (Google Play Store)
  • Web hosting
  • Vercel, Inc. (Vercel)
  • Monitoring
  • Google LLC (Firebase)
  • Tracking
  • Adjust GmbH (Adjust)
  • Google, Inc. (Google Analytics)
  • Mixpanel, Inc. (Mixpanel)
  • Registration and Authentication
  • Google LLC (Firebase)
  • Customer Support
  • Braze, Inc (Braze) 
  • Instabug, Inc. (Instabug)
  • Website content management
  • Builder.io, Inc. (Builder.io)

  1. How long we retain your Personal Data

We will hold your Personal Data for as long as it is necessary or required by law, and always in compliance with the data minimization principle. Specific storage periods for the respective processing activities are detailed in section 2 above. We restrict access to your Personal Data to the people who need to use it for the relevant purpose(s). If the processing of your Personal Data is no longer necessary for any purpose it is either irreversibly anonymized (and the anonymized data may be retained), or securely erased.

  1. How we protect your personal data

Your security really matters to us, this is why we have security systems in place to protect your Personal Data. Once we have received your Personal Data, we will use the following security measures to protect it:

  • Use secure servers to store your Personal Data.
  • Implement security safeguards designed to protect your Personal Data such as HTTPS.
  • Use passwords to protect your Whering account.
  • Restrict access of your Personal Data to those of our employees who need to know it do their job, and ensure that all our employees sign a confidentiality clause as part of their employment.
  • Follow tight security procedures, such as maintaining physical, electronic and procedural safeguards to protect your Personal Data from unauthorised access.
  • Continuously educate and train our employees about the importance of confidentiality.
  • Continuously monitor our systems for possible vulnerabilities and attacks.
  • Regularly review and update our privacy controls and policy.

Although we do our best to protect your Personal Data we cannot guarantee its security during the transmission of information via the internet, as any such transmission is at your own risk.

  1. Your rights regarding your Personal Data

The GDPR gives you the following rights in relation to your Personal data:

  • Right to withdraw consent: You have the right, at any time, to withdraw consent to the processing of your Personal Data.
  • Right to object: You have the right, at any time, to object to the processing of your Personal Data.
  • Right to be informed: You have the right to obtain, at any time, confirmation from us as to whether we are processing your Personal Data or not.
  • Right to erasure: You have the right to obtain from us, at any time, the erasure of your Personal Data.
  • Right to restriction of processing: You have the right to obtain from us, at any time, the restriction of processing of your Personal Data.
  • Right to data portability: You have the right to receive, at any time and without cost, your Personal Data in a structured, commonly used and machine-readable format.
  • Right to rectification: You have the right to receive from us, at any time, the rectification of inaccuracies in your Personal Data.
  • Right to complain: You have the right, at any time, to lodge a complaint with a supervisory authority (as set forth in section 10 below).

All of these rights can be exercised by contacting us at data@whering.co.uk. Please note that to verify your request, we will take reasonable security and verification steps such as asking you to send us a confirmation from the email address associated with your Whering account. We will respond to requests to exercise these rights without undue delay and at least within one (1) month.

  1. Cookies and tracking when using our Website  

We use cookies and other similar technologies to provide you with a user-friendly experience.

Cookies are small text files which our Website may put on your device during your first visit. The cookie helps our Website to recognize your device the next time you visit it. There are many functions cookies serve. For example, they can help us remember your username and preferences, analyze how well the Website is performing, or even allow us to recommend content we believe will be most relevant to you. Your Personal Data collected in this way is pseudonymized, and is not stored together with your other Personal Data. This processing is carried out on a legal basis and, where required by law, based on your consent.

For detailed information on the cookies we use, the purposes for which we use them and to manage your Cookie preferences, please see our  Cookies Policy.

  1. How you can make a complaint

If you have a complaint about how we use your Personal Data, please do not hesitate to contact us on data@whering.co.uk or write to our Data Protection Officer at bianca@whering.co.uk. If you are unhappy with the way that we have dealt with your complaint, you can refer your complaint to the UK’s Independent Authority, the ICO. For more information you can visit their website at ico.org.uk.

  1. Privacy information for California residents

If you are a California resident (as defined in the section 17014 of Title 18 of the California Code of Regulations), California law requires us to provide you with some additional information regarding your rights with respect to your “personal information” (as defined in the California Consumer Privacy Act January 1st 2020 (hereinafter the “CCPA”)).

The categories of personal information we collect about you

As further set forth in Section 2 above, we collect the following categories of personal information about you:

  • Identifiers
  • Internet information
  • Sensory information

How we collect your personal information

Please see Section 2 above.

For what purposes we collect your personal information

Please see Section 2 above.

The categories of personal information we shared and disclosed

We may transfer your personal information to our business partners and service providers in order to achieve the purposes of the processing listed in Section 2 above. In this case, we enter into a written agreement with such business partners and service providers that requires them to keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement. A list of our business partners and services providers can be found in Section 5 above.

The categories of personal information we sold and your right to opt-out

For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means,  your personal information by us to a third party, for monetary or other valuable consideration”. You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request. Such requests can be made freely, at any time, by following the instructions below.

Your rights under the CCPA and how to exercise them

The CCPA provides Californian residents with the following rights:

  • Right to opt-out of the sale of your personal information
  • Right to know and to portability
  • Right to request disclosure of any personal information we collected
  • Right to request deletion of any personal information we collected

All of these rights can be exercised by contacting us at data@whering.co.uk. Please note that, except for your right to opt-out of the sale of your personal information, we may need to verify your request by taking reasonable security and verification steps such as asking you to send us a confirmation from the email address associated with your Whering account. We will respond to requests to exercise these rights without undue delay and at least within forty five (45) days.

  1. Privacy information for Brazilian residents

If you are a Brazilian resident, Brazilian law requires us to provide you with some additional information regarding your rights with respect to your “personal information” September 18th 2020 (as defined in the “Lei Geral de Proteção de Dados” (hereinafter the “LGPD”)).

The categories of personal information we collect about you

Please see Section 2 above.

How we collect your personal information

Please see Section 2 above.

For what purposes we collect your personal information

This is more detailed in Section 2 above. Please note that we can process your personal information solely if we have a legal basis for such processing:

  • Your consent to the relevant processing activities
  • Protection or physical safety of yourself or a third party
  • Compliance with a legal or regulatory obligation that lies with us
  • The carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments
  • Studies conducted by research entities, preferably carried out on anonymized personal information
  • The carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract
  • The exercising of our rights in judicial, administrative or arbitration procedures
  • The protection of health – in procedures carried out by health entities or professionals
  • Our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests.

Transfer of your personal information outside of Brazil

As Whering is based in the UK, we will transfer your personal information to the UK to provide our Services. In addition to this, as we work with business partners and service providers (as set forth in Section 5 of this Privacy Policy) based in third countries, we will also transfer your personal information to such applicable third countries. Please note that we are allowed to transfer your personal information outside of the Brazilian territory in the following cases:

  • When the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law
  • When the transfer is necessary to protect your life or physical security or those of a third party
  • When the transfer is authorized by the ANPD
  • When the transfer results from a commitment undertaken in an international cooperation agreement
  • When the transfer is necessary for the execution of a public policy or legal attribution of public service
  • When the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures

Your rights under the LGPD and how to exercise them

The LGPD provides Brazilian residents with the following rights:

  • Obtain confirmation of the existence of processing activities on your personal information
  • Access to your personal information
  • Have incomplete, inaccurate or outdated personal information rectified
  • Obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD
  • Obtain information on the possibility to provide or deny your consent and the consequences thereof
  • Obtain information about the third parties with whom we share your personal information
  • Obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded
  • Obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply
  • Revoke your consent at any time
  • Lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies
  • Oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law
  • Request clear and adequate information regarding the criteria and procedures used for an automated decision
  • Request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality

All of these rights can be exercised by contacting us at data@whering.co.uk. Please note that to verify your request, we will take reasonable security and verification steps such as asking you to send us a confirmation from the email address associated with your Whering account. If there is no email address associated with your Whering account, we may ask you for proof of ID. We will strive to promptly respond to your requests.

  1. Changes to this Privacy Policy

Any changes we make to our Privacy Policy in the future will be posted on this page, and where appropriate, notified to you by email, via the App, or by any other available means.