Privacy Policy

PRIVACY POLICY Last updated January 10, 2025 This Privacy Notice for DRIVE2DlGlT PRODUCTS PRIVATE LIMITED ('we', 'us', or 'our'), describes how and why we might access, collect, store, use, and/or share ('process') your personal information when you use our services (Services'), including when you: • Visit our website at https://whatsyfly.com/, or any website of ours that links to this Privacy Notice • Download and use our Facebook application (What-Sy-Fly), or any other application of ours that links to this Privacy Notice • Use Whatsapp Tech Provider. Comprehensive WhatsApp Marketing Platform. • Engage with us in other related ways, including any sales, marketing, or events Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@whatsyfly.com. SUMMARY OF KEY POINTS This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us. Do we process any sensitive personal information? Some of the information may be considered 'special' or 'sensitive' in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information. Do we collect any information from third parties? We may collect information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources. How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information. In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information. What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights. How do you exercise your rights? The easiest way to exercise your rights is by visiting or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws. Want to learn more about what we do with any information we collect? Review the Privacy Notice in full. TABLE OF CONTENTS 1. WHAT INFORMATION DO WE COLLECT? 2. HOW DO WE PROCESS YOUR INFORMATION? 3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION? 4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? 5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? 6. HOW DO WE HANDLE YOUR SOCIAL LOGINS? 7. HOW LONG DO WE KEEP YOUR INFORMATION? 8. DO WE COLLECT INFORMATION FROM MINORS? 9. WHAT ARE YOUR PRIVACY RIGHTS? 10. CONTROLS FOR DO-NOT-TRACK FEATURES 11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? 12. DO WE MAKE UPDATES TO THIS NOTICE? 13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE? 14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU? 1. WHAT INFORMATION DO WE COLLECT? Personal information you disclose to us In Short: We collect personal information that you provide to us. We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. Personal Information Provided by You. The personal information that wecollect depends on the context of your interactions with us and theServices, the choices you make, and the products and features you use.The personal information we collect may include the following: names email addresses phone numbers usernames passwords contact preferences Sensitive Information. We do not process sensitive information. Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number,and the security code associated with your payment instrument. No payment data is handled and stored by us. We may provide you with the option to registerwith us using your existing social media account details, like yourFacebook, X, or other social media account. If you choose to register in thisway, we will collect certain profile information about you from the socialmedia provider, as described in the section called ' HOW DO WE HANDLEYOUR SOCIAL LOGINS? ' below. All personal information that you provide to us must be true, complete, andaccurate, and you must notify us of any changes to such personalinformation. Information collected when you use our Facebook application(s). Weby default access your Facebook basic account information, including yourname, email, gender, birthday, current city, and profile picture URL, as wellas other information that you choose to make public. We may also requestaccess to other permissions related to your account, such as friends,check-ins, and likes, and you may choose to grant or deny us access toeach individual permission. For more information regarding Facebookpermissions, refer to the Facebook Permissions Reference page. 2. HOW DO WE PROCESS YOUR INFORMATION? In Short: We process your information to provide, improve, and administerour Services, communicate with you, for security and fraud prevention, andto comply with law. We may also process your information for otherpurposes with your consent. We process your personal information for a variety of reasons,depending on how you interact with our Services, including: To facilitate account creation and authentication and otherwisemanage user accounts. We may process your information so youcan create and log in to your account, as well as keep your accountin working order. To save or protect an individual's vital interest. We may processyour information when necessary to save or protect an individual’svital interest, such as to prevent harm. 3. WHAT LEGAL BASES DO WE RELY ON TOPROCESS YOUR INFORMATION? In Short: We only process your personal information when we believe it isnecessary and we have a valid legal reason (i.e. legal basis) to do so underapplicable law, like with your consent, to comply with laws, to provide youwith services to enter into or fulfil our contractual obligations, to protectyour rights, or to fulfil our legitimate business interests. If you are located in the EU or UK, this section applies to you. The General Data Protection Regulation (GDPR) and UK GDPR require usto explain the valid legal bases we rely on in order to process your personalinformation. As such, we may rely on the following legal bases to processyour personal information: Consent. We may process your information if you have given uspermission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learnmore about withdrawing your consent . Legal Obligations. We may process your information where webelieve it is necessary for compliance with our legal obligations, suchas to cooperate with a law enforcement body or regulatory agency,exercise or defend our legal rights, or disclose your information asevidence in litigation in which we are involved. Vital Interests. We may process your information where we believeit is necessary to protect your vital interests or the vital interests of athird party, such as situations involving potential threats to the safetyof any person. If you are located in Canada, this section applies to you. We may process your information if you have given us specific permission(i.e. express consent) to use your personal information for a specificpurpose, or in situations where your permission can be inferred (i.e. impliedconsent). You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted under applicablelaw to process your information without your consent, including, forexample: If collection is clearly in the interests of an individual and consentcannot be obtained in a timely way For investigations and fraud detection and prevention For business transactions provided certain conditions are met If it is contained in a witness statement and the collection isnecessary to assess, process, or settle an insurance claim For identifying injured, ill, or deceased persons and communicatingwith next of kin If we have reasonable grounds to believe an individual has been, is,or may be victim of financial abuse If it is reasonable to expect collection and use with consent wouldcompromise the availability or the accuracy of the information andthe collection is reasonable for purposes related to investigating abreach of an agreement or a contravention of the laws of Canada ora province If disclosure is required to comply with a subpoena, warrant, courtorder, or rules of the court relating to the production of records If it was produced by an individual in the course of their employment,business, or profession and the collection is consistent with thepurposes for which the information was produced If the collection is solely for journalistic, artistic, or literary purposes If the information is publicly available and is specified by theregulations 4. WHEN AND WITH WHOM DO WE SHARE YOURPERSONAL INFORMATION? In Short: We may share information in specific situations described in thissection and/or with the following third parties. We may need to share your personal information in the following situations: Business Transfers. We may share or transfer your information inconnection with, or during negotiations of, any merger, sale ofcompany assets, financing, or acquisition of all or a portion of ourbusiness to another company. Offer Wall. Our application(s) may display a third-party hosted 'offerwall'. Such an offer wall allows third-party advertisers to offer virtualcurrency, gifts, or other items to users in return for the acceptanceand completion of an advertisement offer. Such an offer wall mayappear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographicinformation. When you click on an offer wall, you will be brought toan external website belonging to other persons and will leave ourapplication(s). A unique identifier, such as your user ID, will beshared with the offer wall provider in order to prevent fraud andproperly credit your account with the relevant reward. 5. DO WE USE COOKIES AND OTHER TRACKINGTECHNOLOGIES? In Short: We may use cookies and other tracking technologies to collectand store your information. We may use cookies and similar tracking technologies (like web beaconsand pixels) to gather information when you interact with our Services.Some online tracking technologies help us maintain the security of ourServices and your account , prevent crashes, fix bugs, save yourpreferences, and assist with basic site functions. We also permit third parties and service providers to use online trackingtechnologies on our Services for analytics and advertising, including to helpmanage and display advertisements, to tailor advertisements to yourinterests, or to send abandoned shopping cart reminders (depending onyour communication preferences). The third parties and service providersuse their technology to provide advertising about products and servicestailored to your interests which may appear either on our Services or onother websites. To the extent these online tracking technologies are deemed to be a 'sale'/'sharing' (which includes targeted advertising, as defined under theapplicable laws) under applicable US state laws, you can opt out of theseonline tracking technologies by submitting a request as described belowunder section ' DO UNITED STATES RESIDENTS HAVE SPECIFICPRIVACY RIGHTS? ' Specific information about how we use such technologies and how you canrefuse certain cookies is set out in our Cookie Notice . Google Analytics We may share your information with Google Analytics to track and analyse the use of the Services. To opt out of being tracked by Google Analyticsacross the Services, visit https://tools.google.com/dlpage/gaoptout . Formore information on the privacy practices of Google, please visit the Google Privacy & Terms page . 6. HOW DO WE HANDLE YOUR SOCIAL LOGINS? In Short: If you choose to register or log in to our Services using a socialmedia account, we may have access to certain information about you. Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Whereyou choose to do this, we will receive certain profile information about youfrom your social media provider. The profile information we receive mayvary depending on the social media provider concerned, but will ofteninclude your name, email address, friends list, and profile picture, as wellas other information you choose to make public on such a social mediaplatform. If you log in using Facebook, we may also request access toother permissions related to your account, such as your friends, check-ins,and likes, and you may choose to grant or deny us access to eachindividual permission. We will use the information we receive only for the purposes that aredescribed in this Privacy Notice or that are otherwise made clear to you onthe relevant Services. Please note that we do not control, and are notresponsible for, other uses of your personal information by your third-partysocial media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information,and how you can set your privacy preferences on their sites and apps. 7. HOW LONG DO WE KEEP YOUR INFORMATION? In Short: We keep your information for as long as necessary to fulfil thepurposes outlined in this Privacy Notice unless otherwise required by law. We will only keep your personal information for as long as it is necessaryfor the purposes set out in this Privacy Notice, unless a longer retentionperiod is required or permitted by law (such as tax, accounting, or otherlegal requirements). No purpose in this notice will require us keeping yourpersonal information for longer than the period of time in which users havean account with us . When we have no ongoing legitimate business need to process yourpersonal information, we will either delete or anonymise such information,or, if this is not possible (for example, because your personal informationhas been stored in backup archives), then we will securely store yourpersonal information and isolate it from any further processing until deletionis possible. 8. DO WE COLLECT INFORMATION FROMMINORS? In Short: We do not knowingly collect data from or market to childrenunder 18 years of age . We do not knowingly collect, solicit data from, or market to children under18 years of age, nor do we knowingly sell such personal information. Byusing the Services, you represent that you are at least 18 or that you arethe parent or guardian of such a minor and consent to such minordependent’s use of the Services. If we learn that personal information fromusers less than 18 years of age has been collected, we will deactivate theaccount and take reasonable measures to promptly delete such data fromour records. If you become aware of any data we may have collected fromchildren under age 18, please contact us at support@whatsyfly.com . 9. WHAT ARE YOUR PRIVACY RIGHTS? In Short: Depending on your state of residence in the US or in someregions, such as the European Economic Area (EEA), United Kingdom(UK), Switzerland, and Canada , you have rights that allow you greateraccess to and control over your personal information. You may review,change, or terminate your account at any time, depending on your country,province, or state of residence. In some regions (like the EEA, UK, Switzerland, and Canada ), you havecertain rights under applicable data protection laws. These may include theright (i) to request access and obtain a copy of your personal information,(ii) to request rectification or erasure; (iii) to restrict the processing of yourpersonal information; (iv) if applicable, to data portability; and (v) not to besubject to automated decision-making. In certain circumstances, you mayalso have the right to object to the processing of your personal information.You can make such a request by contacting us by using the contact detailsprovided in the section ' HOW CAN YOU CONTACT US ABOUT THISNOTICE? ' below. We will consider and act upon any request in accordance with applicabledata protection laws. If you are located in the EEA or UK and you believe we are unlawfullyprocessing your personal information, you also have the right to complainto your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal DataProtection and Information Commissioner . Withdrawing your consent: If we are relying on your consent to processyour personal information, which may be express and/or implied consentdepending on the applicable law, you have the right to withdraw yourconsent at any time. You can withdraw your consent at any time bycontacting us by using the contact details provided in the section ' HOWCAN YOU CONTACT US ABOUT THIS NOTICE? ' below . However, please note that this will not affect the lawfulness of theprocessing before its withdrawal nor, when applicable law allows, will itaffect the processing of your personal information conducted in reliance onlawful processing grounds other than consent. Account Information If you would at any time like to review or change the information in youraccount or terminate your account, you can: Log in to your account settings and update your user account. Contact us using the contact information provided. Upon your request to terminate your account, we will deactivate or deleteyour account and information from our active databases. However, we mayretain some information in our files to prevent fraud, troubleshoot problems,assist with any investigations, enforce our legal terms and/or comply withapplicable legal requirements. If you have questions or comments about your privacy rights, you mayemail us at support@whatsyfly.com . 10. CONTROLS FOR DO-NOT-TRACK FEATURES Most web browsers and some mobile operating systems and mobileapplications include a Do-Not-Track ( 'DNT' ) feature or setting you canactivate to signal your privacy preference not to have data about youronline browsing activities monitored and collected. At this stage, no uniformtechnology standard for recognising and implementing DNT signals hasbeen finalised . As such, we do not currently respond to DNT browsersignals or any other mechanism that automatically communicates yourchoice not to be tracked online. If a standard for online tracking is adoptedthat we must follow in the future, we will inform you about that practice in arevised version of this Privacy Notice. California law requires us to let you know how we respond to web browserDNT signals. Because there currently is not an industry or legal standardfor recognising or honouring DNT signals, we do not respond to them atthis time. 11. DO UNITED STATES RESIDENTS HAVESPECIFIC PRIVACY RIGHTS? In Short: If you are a resident of California, Colorado, Connecticut,Delaware, Florida, Indiana, Iowa, Kentucky, Minnesota, Montana,Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah,or Virginia , you may have the right to request access to and receive detailsabout the personal information we maintain about you and how we haveprocessed it, correct inaccuracies, get a copy of, or delete your personalinformation. You may also have the right to withdraw your consent to ourprocessing of your personal information. These rights may be limited insome circumstances by applicable law. More information is provided below. Categories of Personal Information We Collect We have collected the following categories of personal information in thepast twelve (12) months: Category Examples Collected A. Identifiers Contact details, such as real name,alias, postal address, telephone ormobile contact number, uniquepersonal identifier, online identifier,Internet Protocol address, emailaddress, and account name NO B. Personal informationas defined in theCalifornia CustomerRecords statute Name, contact information,education, employment, employmenthistory, and financial information NO C . Protectedclassificationcharacteristics understate or federal law Gender, age, date of birth, race andethnicity, national origin, maritalstatus, and other demographic data NO D . Commercialinformation Transaction information, purchasehistory, financial details, and paymentinformation NO E . Biometric information Fingerprints and voiceprints NO F . Internet or othersimilar network activity Browsing history, search history,online behaviour , interest data, andinteractions with our and otherwebsites, applications, systems, andadvertisements NO G . Geolocation data Device location NO H . Audio, electronic,sensory, or similarinformation Images and audio, video or callrecordings created in connection withour business activities NO I . Professional oremployment-relatedinformation Business contact details in order toprovide you our Services at abusiness level or job title, workhistory, and professionalqualifications if you apply for a jobwith us NO J . Education Information Student records and directoryinformation NO K . Inferences drawnfrom collected personalinformation Inferences drawn from any of thecollected personal information listedabove to create a profile or summaryabout, for example, an individual’spreferences and characteristics NO L . Sensitive personalInformation NO We may also collect other personal information outside of these categoriesthrough instances where you interact with us in person, online, or by phoneor mail in the context of: Receiving help through our customer support channels; Participation in customer surveys or contests; and Facilitation in the delivery of our Services and to respond to yourinquiries. We will use and retain the collected personal information as needed toprovide the Services or for: Category H - As long as the user has an account with us Sources of Personal Information Learn more about the sources of personal information we collect in ' WHATINFORMATION DO WE COLLECT? ' How We Use and Share Personal Information Learn more about how we use your personal information in the section, ' HOW DO WE PROCESS YOUR INFORMATION? ' Will your information be shared with anyone else? We may disclose your personal information with our service providerspursuant to a written contract between us and each service provider. Learnmore about how we disclose personal information to in the section, ' WHENAND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? ' We may use your personal information for our own business purposes,such as for undertaking internal research for technological developmentand demonstration. This is not considered to be 'selling' of your personalinformation. We have not disclosed, sold, or shared any personal information to thirdparties for a business or commercial purpose in the preceding twelve (12)months. We will not sell or share personal information in the futurebelonging to website visitors, users, and other consumers. Your Rights You have rights under certain US state data protection laws. However,these rights are not absolute, and in certain cases, we may decline yourrequest as permitted by law. These rights include: Right to know whether or not we are processing your personal data Right to access your personal data Right to correct inaccuracies in your personal data Right to request the deletion of your personal data Right to obtain a copy of the personal data you previously sharedwith us Right to non-discrimination for exercising your rights Right to opt out of the processing of your personal data if it is usedfor targeted advertising (or sharing as defined under California’sprivacy law) , the sale of personal data, or profiling in furtherance ofdecisions that produce legal or similarly significant effects ( 'profiling' ) Depending upon the state where you live, you may also have the followingrights: Right to access the categories of personal data being processed (aspermitted by applicable law, including Minnesota’s privacy law) Right to obtain a list of the categories of third parties to which wehave disclosed personal data (as permitted by applicable law,including California's and Delaware's privacy law) Right to obtain a list of specific third parties to which we havedisclosed personal data (as permitted by applicable law, including Minnesota's and Oregon's privacy law) Right to review, understand, question, and correct how personal datahas been profiled (as permitted by applicable law, includingMinnesota’s privacy law) Right to limit use and disclosure of sensitive personal data (aspermitted by applicable law, including California’s privacy law) Right to opt out of the collection of sensitive data and personal datacollected through the operation of a voice or facial recognitionfeature (as permitted by applicable law, including Florida’s privacylaw) How to Exercise Your Rights To exercise these rights, you can contact us by visiting __________ , by emailing us at support@whatsyfly.com , or by referring to the contact detailsat the bottom of this document. Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf. We may deny arequest from an authorised agent that does not submit proof that they havebeen validly authorised to act on your behalf in accordance with applicablelaws. Request Verification Upon receiving your request, we will need to verify your identity todetermine you are the same person about whom we have the informationin our system. We will only use personal information provided in yourrequest to verify your identity or authority to make the request. However, ifwe cannot verify your identity from the information already maintained byus, we may request that you provide additional information for the purposesof verifying your identity and for security or fraud-prevention purposes. If you submit the request through an authorised agent, we may need tocollect additional information to verify your identity before processing yourrequest and the agent will need to provide a written and signed permissionfrom you to submit such request on your behalf. Appeals Under certain US state data protection laws, if we decline to take actionregarding your request, you may appeal our decision by emailing us at support@whatsyfly.com . We will inform you in writing of any action taken ornot taken in response to the appeal, including a written explanation of thereasons for the decisions. If your appeal is denied, you may submit acomplaint to your state attorney general. California 'Shine The Light' Law California Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits our users who are California residents to request and obtainfrom us, once a year and free of charge, information about categories ofpersonal information (if any) we disclosed to third parties for directmarketing purposes and the names and addresses of all third parties withwhich we shared personal information in the immediately precedingcalendar year. If you are a California resident and would like to make sucha request, please submit your request in writing to us by using the contactdetails provided in the section ' HOW CAN YOU CONTACT US ABOUTTHIS NOTICE? ' 12. DO WE MAKE UPDATES TO THIS NOTICE? In Short: Yes, we will update this notice as necessary to stay compliantwith relevant laws. We may update this Privacy Notice from time to time. The updated versionwill be indicated by an updated 'Revised' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notifyyou either by prominently posting a notice of such changes or by directlysending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information. 13. HOW CAN YOU CONTACT US ABOUT THISNOTICE? If you have questions or comments about this notice, you may email us at support@whatsyfly.com or contact us by post at: DRIVE2DIGIT PRODUCTS PRIVATE LIMITED 34B, Bosepukur Road, Kasba, kolkata-700042 India 14. HOW CAN YOU REVIEW, UPDATE, OR DELETETHE DATA WE COLLECT FROM YOU? Based on the applicable laws of your country or state of residence in the US , you may have the right to request access to the personal informationwe collect from you, details about how we have processed it, correctinaccuracies, or delete your personal information. You may also have theright to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personalinformation, please contact us on support@whatsyfly.com .