Privacy policy

1. Introduction

1.1 We at Who Represents Inc. (“We,” “Us,” “Our”) are committed to safeguarding your privacy. This Privacy Policy applies where we are acting as a data controller with respect to the personal data of users registering for an account and those users subscribing for access at WhoRepresents.com, which includes the use of our iOS and Android applications (“Service”); in other words, where we determine the purposes and means of the processing of that personal data.

1.2 We use cookies on our website. These cookies are used to create a better experience for our users; for example, so users are able to move fluidly throughout the site after logging in, viewing all content included in their subscription.

1.3 Our users always have the right to request that their personal data be deleted from our system, as well as to elect whether or not they would like to receive promotional or informational email communication from Who Represents Inc. Our interactions with third party agents is strictly limited to what is necessary to the scope of our Service (e.g. payment processing), the improvement of our Service (e.g. analytics) and the promotion of our Service (e.g. discount coupons for our Service). We do not sell or otherwise make available the personal data of any of our users to any third party for purposes of direct marketing or other unsolicited communication. We do not allow third party advertising of any kind on our site. For more information regarding your personal data contained on our site, please contact us.

2. How we use your personal data

2.1 We may process data about your use of our website and Service ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your Service use. This usage data may be processed for the purposes of analyzing the use of the website and Service. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and Service.

2.2 We may process your account data ("account data"). The account data may include your name, billing address, phone number, credit card information and email address. The account data may be processed for the purposes of operating our website, providing our Service, ensuring the security of our website and Service, maintaining back-ups of our databases and communicating with you (e.g. password recovery). The legal basis for this processing is your consent in registering an account with our site. As a paid subscriber to our Service (a secondary action beyond registration), you are consenting that we may process this account data with a third party payment processor, as well as communicate with you via email within the scope of this agreement (e.g. failed payment notice or internal promotional offer).

2.3 We may process information that you provide to us for the purpose of subscribing you to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you relevant newsletters and other content we believe may be of interest to our subscribers. The legal basis for this processing is your consent to be contacted given within the registration process.

2.4 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and for record keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.5 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.6 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.7 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.8 Please do not supply any other person's personal data to us, unless we prompt you to do so.

3. Providing your personal data to others

3.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.2 Financial transactions relating to our website and Service are handled by our payment services providers, Authorize.net and PayPal (as elected by the user at sign up). We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://www.authorize.net/company/privacy/ and https://www.paypal.com/us/webapps/mpp/ua/privacy-full.

3.3 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. International transfers of your personal data

4.1 The hosting facilities for our website are situated in the United States. Transfers to the United States will be protected by standard data protection clauses. While we treat data security with the utmost seriousness, please note that data protection and privacy laws in the United States may offer a lower level of protections than in your country/region.

4.2 You acknowledge that personal data that you submit for publication through our website or Service may be available, via the Internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. Retaining personal data

5.1 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.2 We will retain your personal data for as long as you maintain an account or as otherwise necessary to provide our Service by allowing you access to your account.

5.3 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Amendments

6.1 We may update this policy from time to time by publishing a new version on our website.

6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3 We will notify you of significant changes to this policy by email and/or through a prominent notice on our site.

7. Your rights

7.1 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. You can access your personal data by visiting https://www.whorepresents.com/user when logged into our website.

7.2 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.3 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

7.4 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.5 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7.6 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.7 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. (EU citizens only, per GDPR.)

7.8 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.9 You may exercise any of your rights in relation to your personal data by written notice sent to [email protected].

8. About cookies

8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

9. Cookies that we use

9.1 We use cookies for the following purposes:

(a) authentication - we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: session cookies);

(b) security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are: session cookies).

10. Cookies used by our service providers

10.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

10.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.

11. Managing cookies

11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari);

11.2 Blocking all cookies will have a negative impact upon the usability of many websites.

11.3 If you block cookies, you will not be able to use all the features on our website.

12. Links

12.1 Many areas of this Site may contain links to other Web sites. Please note that when you click on any of these links, you are entering another Web site for which we have no responsibility or control. The inclusion of any link does not imply affiliation, endorsement or adoption by us of the linked site or any information contained therein. We encourage you to read the terms and conditions, data-gathering practices and privacy policies of all linked sites as they may materially differ from ours.

13. Our details

13.1 This website is owned and operated by Who Represents Inc.

13.2 Our principal place of business is at

3030 Pennsylvania Avenue

Santa Monica, CA 90404

United States

Primary Support Contact: [email protected]