Privacy Policy

Privacy Policy

Last Revised: September 4, 2016

Whereabouts, Inc. and its affiliates (“Whereabouts“, “Company” “our” or “we”) respect the privacy of its users (“User” or “you”) and are committed to protect the User’s information. We believe that you have a right to know our practices regarding the information we may collect and use when you use our proprietary geo-location-based application application (the “ App” or the “Services”). Terms not otherwise defined herein shall have the meaning ascribed to them in the Terms of Use (“TOU“), available at

  1. Your consent (important, please read carefully!)

By installing the App, accessing and/or using the Services, and/or any part thereof, you agree to the terms and conditions set forth in this Privacy Policy, including to the collection and processing of your Personal Information (as defined below).


  1. Which information we may collect on our Users?

We may collect two types of data and information on our Users:

  1. a) Non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from which we have collected the Non-personal Information. Non-Personal Information we may collect includes any unconcealed information which does not enable identification of an individual User, and which is available to us when such User installs or uses the App. Non-personal Information which is being gathered consists of technical information and behavioral information, and may contain, among other things, type of mobile device, device version, location of Users posts, posting habits (followers, locations, rooms), certain areas the Users visit, as well as the Users’ search methods, Users scrolling behavior, and swiping methodologies, which may be done through the use of statistical tools designed to record your activity and interface with the App.
  2. b) Personal Information. This information may identify an individual or may be of a private and/or sensitive nature ( “Personal Information”). Personal Information we may collect includes:
  • Any personal details consciously and voluntarily provided by the User. Users interested in accessing the App or Services may be requested to provide the following details directly, via the registration form or via certain service providers (such as Google Play, your Android Account etc.) (“ Publishers”): the Users’ full name, age, e-mail address, phone number, geo-location, personal identifier (i.g. ID number).
  • Also, while Users have already registered to the App, they can attach their existing social media third party accounts (e.g., Facebook and Twitter) used by him/her (“Social Network Account“), to find out which mutual friends are using the App. In the event that a User registers to the App and/or Services through his/her existing Social Network Account, then such Social Network Account provides us with access to certain information about such User as is stored in the User’s Social Network Account, namely, certain public information (e.g. full name, profile picture and cover photos, networks gender, user name and user ID and any other information which the User made public) and/or any other information which is detailed and displayed to the User in the notice which appears during the “Log in” with such Social Network Account process. Please read carefully such notice in order to understand what information is available to the Company via the Social Network Account. We may collect your login information and other relevant information necessary to enable us to access your Social Network Account (such as, Facebook UserID, User access token) in order to collect and/or store, to the extent legally permissible, your full name, e-mail, and gender as stored in your Social Network Account. Other than the abovementioned information, we do not collect or store any other information made available to us through your Social Network Account. You hereby agree that such information will be stored even after the linkage to your Social Network Account expires, for any reason.
  • Users of the App automatically provide their IP address mainly for enhancing the User’s experience and for geo-location and security purposes as further detailed below.
  • The Users mobile phone number and access to the User’s contacts. In order for us to provide the Service the Company may have to access the Users’ contact list/phone numbers, device camera and import such contacts names onto its servers. The Company does not collect or store the phone numbers of the Users’ contacts onto servers used by the Company but may need to keep certain videos or parts thereof for the operation of the service.
  • User Generated Content that you voluntarily submit using the Services.

We may link any Non personal Information to any Personal Information. Any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your acceptance of the Terms and the Privacy Policy.

Additional Disclosure regarding User Generated Content: When you agree to use the Services, you agree, by uploading Moments and any other User Generated Content, that the other users have the ability to share such videos and make them available to the public through other platforms such as, but not limited to, Facebook. The Company allows you to delete Moments however, the Company cannot guarantee the message thread’s complete and total deletion as other Users may store Moments locally on their mobile devices and such locally stored Moments are beyond the Company’s control. Please see additional information regarding Moments deletion in Section 6.

Use common sense, don’t upload a Moment that you wouldn’t want someone to save or share.

  1. How do we collect information on our Users?

There are two main methods we use:

We collect information through your installation and use of the App and/or the Services:

(a) We collect information while you access or use the Services. In other words, when you access or use the Services we are aware of your usage of the Services, and may gather, collect and record the information relating to such usage for example when you navigate between screens.

(b) We collect information in order to allow you to back-up your contact lists and User Generated Content logged into the Services with respect to such contacts. The Company may, at any time and at its sole discretion, elect to discontinue provision of the cloud back-up service.

We collect information which you may, at your discretion, provide us voluntarily:

(a) We collect Personal Information when you, at your discretion, decide to provide us, when opening an Account and/or when you post User Generated Content, including Moments.

  1. What are the purposes of the collection of information?

We collect Non-personal Information and Personal Information in order to provide the Services.

(a) Non-personal Information is collected in order to:

  • Enhance the User’s experience on the Services (e.g. by determining the screen resolutions).
  • Learn about the preferences of Users and general trends on and uses of the Services (e.g. understand which features are more popular than others).
  • Statistical analysis of the Services.

(b) Personal Information is collected in order to:

  • Enable the overall operation of the Services.
  • Personalize your experience on the Services.
  • Determine geo-location information from which the User’s mobile device or computer is connected to the Internet in order for us to present You with Moments and User Generated Content posted by Users who are close to Your location as well as in order to safeguard our App.
  • Be able to contact Users for the purpose of providing them with technical assistance and support and collect feedback regarding the Service as well as to notify Users of new features.
  • Be able to inform you regarding our products and services which may interest you, and to engage in other direct marketing activities, transmitted to you through the contact information you provided us.
  • Enable the User to use public social features (such as to like, comment, follow, block, report and share) and private social features (such as to chat, share, like, comment and invite).
  • Allow you to register for special offers, contests or premium services.
  • Send push notifications to the User’s device after the User agreed to accept push notifications from the Company. Users can deactivate push notifications by changing the notification settings in accordance with the instructions of the operating system running on the Users’ device.
  • Verify the User’s identity when he/she signs in to the App or Services, as well as verifying User’s identity for the purpose of dealing with inappropriate interactions of User and/or unauthorized use of the App and/or the Services.
  1. Sharing Personal Information with Third Parties

The Company may disclose Personal Information in the following cases:

(a) Legal, Compliance and Protection of Rights: (i) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (ii) to enforce this Privacy Policy and/or the TOU, including investigation of potential violations thereof; (iii) to detect, prevent, or otherwise address fraud, security or technical issues; (iv) respond to claims that any content available on the App or the Services violates the rights of third-parties; (v) to respond to claims that contact information of a third-party had been posted or transmitted without their consent or as a form of harassment; and (vi) to protect the rights, property, or personal safety of the Company, its Users, or the general public.

(b) Business Transactions: when the Company is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets

(c) Pursuant to your explicit approval prior to the disclosure.

For avoidance of doubt, the Company may transfer and disclose Non-personal Information to third parties at its own discretion.

  1. Saving of, Modifications to, or Deletion of Personal Information

(a) Saving Personal Information- Users can only save their own User Generated Content and Moments. Other Users may not save User Generated Content which is not their own through the App. However, the Company cannot guarantee that User Generated Content shall not be stored on other Users’ mobile devices, as other Users may store such User Generated Content locally on their mobile devices through use of features which are beyond the Company’s control (such as screen grabs).

(b) Modifying or Deleting Personal Information

  1. If for any reason you wish to modify or delete your Personal Information, you may send us e-mail to The Company shall remove Personal Information in a reasonable amount of time, in accordance with applicable privacy laws, once you have removed the App from your device. You can also modify or delete certain Personal Information from the Services, by accessing the “Settings” menu available on the Services and making your desired modifications and changes.
  2. Even after information is deleted from the servers used by the Company, that same data may remain in backup for a limited period of time. The Company may, receive requests from law enforcement requiring it by law to suspend its server deletion practices for specific information. In addition, there may be ways to access information while still in temporary storage on the recipient’s device or, forensically, even after they deleted it.
  3. We may retain and use your Personal Information for a reasonable time after termination as necessary to comply with our legal or business requirements or obligations (including as required by applicable law), to resolve disputes and/or to enforce our Terms, all as permitted under any applicable privacy laws. Aggregated and/or anonymous data derived from your account may remain on the servers we use indefinitely. The Company cannot ensure that third parties who gained access to the Personal Information deleted your Personal Information and cannot monitor their use of such information.
  4. How we protect your information

We take a great care in implementing and maintaining the security of the Services and our Users’ Personal Information. The Personal Information is hosted on the AWS servers which provide advanced security features. The Company uses generally accepted industry standard technologies and internal procedures, including through the use of tokens and encryption mechanisms to secure our Users’ Personal Information. However, we cannot and do not guarantee that unauthorized access will never occur.

  1. International Data Transfer

We may transfer information collected about you, including Personal Information, to affiliated entities, or to other third party service provides (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information.

  1. Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the App and any information collected therein. The Company reserves the right to change this policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this policy on the App and/or we will send you an e-mail regarding such changes to the e-mail address that you provided in the registration form. Such substantial changes will take effect seven (7) days after such notice was provided on the App or sent by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the App after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

  1. Minors

The App is intended for Users over the age of thirteen (13). The Company does not intend and does not knowingly collect Personal Information from minors under the age of thirteen (13) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of thirteen (13) are not using the App. If we learn that we collected Personal Information from minors under the age of thirteen (13), we will delete that information as quickly as possible. Please contact the Company at: if you have reasons to suspect that the Company collected Personal Information from minors under the age of thirteen (13) and we will delete that information as quickly as possible.

  1. Got any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are most welcomed to send us an email to the following address: and we will make an effort to reply within a reasonable timeframe.