Version: 9-2-2021

Data collected on the basis of legitimate interest

Based on our legitimate interests, we collect the following data for the purpose of delivering products and services that we have contracted with the Program Sponsor to provide on their behalf. Your data is shared only with the Program Sponsor and vendors under contract with Whistle to deliver incentives on an as-needed basis, such as our physical award provider. We also collect data regarding your usage of our application, which we use for analytical purposes related to platform improvement and to generate insights and reports for the Program Sponsor. All personal and application data is removed upon your request.

You have the right to opt out from participating in our programs. In this case we will not collect any additional data from you, and will delete all data that the Program Sponsor provided to us for the purposes of onboarding you to our platform. We will notify the Program Sponsor of your decision to opt out of the program, since they have contracted us to deliver services specifically to you. 

Personal data

Onboarding - The Program Sponsor provides us with personal information including your email address, first name, last name, employer name, and country of residence for the purpose of onboarding onto our platform. This information was used to initially contact you. 

Additional Information From Program Sponsor - The Program Sponsor might provide additional information to enhance reporting and other features across the platform. This information includes your job title, birthday, managerial hierarchy, language preference, and business contact information such as your work email address, office phone number, and office address. We include additional data points based on the specific needs of a Program Sponsor to include in this data in custom reporting and analytics that we build for them. Your rights apply to 

Award Redemption - We will collect additional information at the time of redemption in order to deliver incentive awards to you. We require shipping information such as your home address, personal phone number, and personal email address in order to deliver awards to you. We only collect this information when you initiate a redemption after earning an award, and we store this information to help save time for future award redemptions. You are free to choose not to provide this information, but we will be unable to fulfill your award without it. 

Platform usage data - We will collect data regarding the usage of our platform. This includes login information such as the date and time of each login, the IP address you used, the login method (web/mobile), and geo-location data from your browser. We also collect data regarding your interactions with learning content, including the date and time of each card that you view, answers you provide to quiz questions, and aggregate scores on assessments. 

Embedded content from other websites

Content within this application may include embedded content (e.g. videos, charts, etc.). Embedded content from other websites behaves in the exact same way as if the visitor had visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

Your rights pertaining to your data

If you have received an invitation to join the Whistle platform, you can request to receive an exported file of the personal data we hold about you, including any data you and/or the Program Sponsor have provided to us. You can also request that we rectify or erase any personal data we hold about you. Please send your request to privacy@wewhistle.com

• The right to withdraw consent
• The right of access
• The right to erasure
• The right to rectification
• The right to data portability
• The right to object
• Notification of data breaches
• The right to lodge a complaint with a supervisory authority