Privacy Policy

Welcome to Whisper Win, operated by Caesium Studios. This Privacy Policy explains how we collect, use, protect, and share your personal information when you use our mobile application. By using Whisper Win, you agree to the practices described in this policy.

1. Overview & Key Principles

Our privacy practices are built on these core principles:

• Transparency: We clearly explain what data we collect and how we use it
• Choice: You control what information you share and how it's used
• Security: We implement robust measures to protect your data
• Minimization: We only collect data necessary for app functionality
• Anonymity: We support anonymous confession sharing while maintaining safety

2. Data Controller Information

Data Controller: Caesium Studios
Address: Grandy Hole, Castleton P.O. St Mary, Jamaica
Email: studios.caesium@gmail.com
Privacy Officer: studios.caesium@gmail.com

3. Information We Collect

3.1 Information You Provide Directly

3.2 Information Collected Automatically

4. How We Use Your Information

We use your personal information for the following purposes:

4.1 Core App Functionality

• Creating and managing your account
• Enabling anonymous confession posting and viewing
• Facilitating user interactions (likes, comments, reactions)
• Personalizing your app experience

4.2 Safety & Security

• Content moderation and community guideline enforcement
• Detecting and preventing harmful or illegal content
• Protecting against fraud, abuse, and security threats
• Age verification and child safety compliance

4.3 Communication & Support

• Providing customer support and responding to inquiries
• Sending important service announcements
• Notifying about policy changes or security issues

4.4 Analytics & Improvement

• Analyzing app usage patterns and performance
• Improving features and user experience
• Developing new functionality
• Bug fixing and technical maintenance

5. Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Contract Performance: Processing necessary for providing app services
• Legitimate Interests: Analytics, security, fraud prevention, app improvement
• Consent: Optional features, marketing communications (where required)
• Legal Compliance: Age verification, content moderation, law enforcement cooperation

6. When We Share Your Information

We do not sell your personal data. We may share information in these limited circumstances:

6.1 Service Providers

• Cloud hosting services for data storage and app infrastructure
• Analytics providers for app performance monitoring
• Content moderation services for safety compliance
• Customer support tools for user assistance

6.2 Legal Requirements

• Compliance with court orders, subpoenas, or legal processes
• Cooperation with law enforcement investigations
• Protection of our legal rights and interests
• Child safety reporting as required by law

6.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your data may be transferred as part of the business transaction.

6.4 Emergency Situations

We may disclose information when we believe in good faith it's necessary to prevent imminent harm to users or the public.

7. Data Retention

8. Data Security & Protection

We implement comprehensive security measures to protect your data:

8.1 Technical Safeguards

• Encryption: Data encrypted in transit (TLS) and at rest (AES-256)
• Access Controls: Multi-factor authentication for staff access
• Network Security: Firewalls, intrusion detection systems
• Regular Updates: Security patches and vulnerability assessments

8.2 Organizational Measures

• Staff privacy training and confidentiality agreements
• Regular security audits and penetration testing
• Incident response procedures
• Data minimization and privacy-by-design principles

9. International Data Transfers

Your data may be processed in countries outside your residence, including:

• Primary Processing: Jamaica (where Caesium Studios is located)
• Cloud Services: United States (AWS, Google Cloud, etc.)
• Analytics: Various countries where service providers operate

When transferring data internationally, we ensure adequate protection through:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions by relevant authorities
• Appropriate technical and organizational measures

10. Your Privacy Rights

You have the following rights regarding your personal data:

10.1 Universal Rights

• Access: Request information about data we hold about you
• Correction: Update or correct inaccurate personal information
• Deletion: Request deletion of your personal data (subject to legal requirements)
• Portability: Receive your data in a structured, machine-readable format

10.2 Additional Rights (Where Applicable)

• Restriction: Limit how we process your data
• Objection: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent for consent-based processing
• Complaint: Lodge complaints with data protection authorities

10.3 How to Exercise Rights

To exercise these rights:

• Email us at studios.caesium@gmail.com with subject "Privacy Rights Request"
• Use in-app settings for account management and data deletion
• Include verification information to confirm your identity
• We will respond within 30 days (or as required by applicable law)

11. Cookies & Tracking Technologies

We use cookies and similar technologies to enhance your experience:

11.1 Types of Cookies

11.2 Managing Cookies

You can control cookies through:

• In-app privacy settings
• Device-level advertising preferences
• Browser settings (for web-based features)

12. Third-Party Services & Links

Our app may include:

• Third-party integrations: Social media sharing, payment processing
• External links: Mental health resources, support websites
• Service providers: Analytics, advertising, cloud services

Important: These third parties have their own privacy policies. We are not responsible for their practices and encourage you to review their policies.

13. Children's Privacy

If we discover we have collected information from someone under 18:

• We will delete the information immediately
• We will terminate the account
• We will implement additional safeguards to prevent future occurrences

If you believe we have collected information from a minor, please contact us immediately.

14. California Residents (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act:

14.1 Categories of Personal Information

• Identifiers: Username, email, device ID
• Internet Activity: Usage patterns, interactions
• Geolocation: General location information
• Inferences: User preferences, interests

14.2 Your CCPA Rights

• Right to know what personal information we collect
• Right to delete personal information
• Right to opt-out of sale (we do not sell data)
• Right to non-discrimination for exercising rights

To exercise CCPA rights, email us at studios.caesium@gmail.com with "CCPA Request" in the subject line.

15. European Residents (GDPR)

If you are in the European Economic Area, you have rights under the General Data Protection Regulation:

• All rights listed in Section 10 apply to you
• You can lodge complaints with your local data protection authority
• We rely on legitimate interests, contract performance, and legal compliance as processing bases
• International transfers are protected by appropriate safeguards

16. Changes to This Policy

We may update this Privacy Policy to reflect:

• Changes in legal requirements
• New app features or functionality
• Evolving privacy practices
• User feedback and suggestions

Notification of Changes:

• Material changes will be communicated via email or in-app notification
• We will post the updated policy with a new "Last Updated" date
• Continued use constitutes acceptance of changes
• You may delete your account if you disagree with changes

17. Contact Us

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