1. Who we are and what this policy covers
Whisperr, Inc., a Delaware corporation (File No. 10571843) (Whisperr, we, us) operates the Whisperr retention platform. Address: 2803 Philadelphia Pike, Suite B #1462, Claymont, DE 19703, United States.
This policy covers three groups of people:
- Website visitors. People who visit whisperr.net and docs.whisperr.net.
- Customer staff. People who use the Whisperr dashboard (app.whisperr.net), API, MCP server, install wizard or PR agent for a business customer.
- End Users. The users of our customers’ apps and websites. Our customers send us data about these people so that Whisperr can understand their activity and send them messages.
This policy does not yet cover phone calls that Whisperr Recall places. For questions about Recall, write to privacy@whisperr.net.
Words with capital letters, such as Customer, End User and Customer Data, have the meaning given in our Customer Terms.
2. Our two roles
Controller. For website visitors and for customer staff, Whisperr decides why and how data is processed. Whisperr is the controller.
Processor. For End User data, our Customer (the app business) is the controller. Whisperr is the Customer’s processor (a “service provider” under US state laws). We process End User data only to provide the service on the Customer’s instructions. Our Data Processing Addendum (DPA) sets out these terms.
If you are an End User, the privacy notice of the app you use applies to you first. Send your request to that app. If you send it to us, we will forward it to the Customer and help the Customer answer it.
3. Data about website visitors
What we collect
- Usage data. Pages you view, clicks, the page that sent you, browser, device, and approximate location from your IP address. We collect this with PostHog. PostHog stores an identifier in a cookie and in local storage to recognise repeat visits. Session recording is off on whisperr.net.
- Advertising data. We use the Meta pixel to measure our ads on Facebook and Instagram. It sends Meta the pages you view, your browser, device and IP address, and when you click a trial or call button or book a call. Meta stores an identifier in the
_fbpcookie, and in_fbcif you came from a Meta ad. - Form data. When you join a waitlist or launch list, request a report or book a walkthrough, we collect what you enter: for example your email, name, company, role, answers and calculator inputs. Walkthrough bookings go through Cal.com.
- Chat widget. Some pages show a chat widget from Whisperr Recall, hosted on Vercel. If you use it, the messages you type go to that service so that it can answer you.
- Technical data. Cloudflare processes your IP address and request data to deliver the site and to block attacks. Your browser also sends your IP address to Google when it loads our web fonts.
- Emails you send us. The content of your message and your contact details.
The churn calculators run in your browser. They send nothing to us until you submit a form.
4. Data about customer staff
What we collect
- Account data. Name, work email, password (stored by our sign-in provider in hashed form), organisation, role and settings. If you sign in with Google or GitHub, we receive your name and email from that service.
- Billing data. Billing contact, company details and plan. Stripe processes card details. We do not see full card numbers.
- Usage data. Actions you take in the dashboard, errors and performance data. We collect this with PostHog. The dashboard keeps analytics identifiers in memory only and does not set analytics cookies.
- Onboarding data. Answers you give during setup, and public pages of the company website you give us. We read those pages to understand your product.
- Source code. If you install the Whisperr PR agent GitHub App, it reads the repositories you select and opens pull requests. If you use the install wizard or a coding agent through our MCP server, we receive the event definitions, mappings and test events that it sends.
- Support data. Messages you send to support and our replies.
5. Data about End Users (we process it for our Customers)
Our Customers decide what to send. The Whisperr SDKs, API and connectors can send:
- Identifiers. A user ID that the Customer chooses (we ask Customers to use an internal ID, not an email address), and a random anonymous ID that the SDK creates.
- Activity. Events and their properties, for example “app opened” or “workout completed”, with timestamps.
- Device context from the SDK. Time zone, language, operating system, SDK version and a session ID. The SDKs do not collect advertising IDs (IDFA or GAID), precise location or device fingerprints. The API does not store IP addresses.
- Profile attributes. Attributes the Customer sends, for example plan, language or a display name.
- Contact channels. If the Customer sends them: email address, phone number or push token, so that messages can reach the End User.
- Subscription and order data. From sources the Customer connects, for example Stripe, RevenueCat or Shopify.
- Data that Whisperr creates. Lifecycle stage, engagement and risk scores, decisions, holdout group, message text, delivery and open status, and consent and opt-out records.
Customers must not send special categories of data (for example health, religion or sexual orientation), government IDs, payment card numbers or data about children, unless we agree to it in writing.
6. How we use data
Website and customer staff data
- To run the website and the service, create accounts and sign you in.
- To bill, to give support and to send service emails (for example security notices and changes to terms).
- To send launch news or product updates when you ask for them. Every such email has an unsubscribe link.
- To measure and improve our website and product.
- To keep our systems secure and to prevent abuse.
- To comply with the law.
End User data
Only to provide the service to the Customer: to analyse activity, find users who may leave, decide who should get a message and when, write the message, deliver it through the Customer’s own providers, and measure the result. We may create aggregated, de-identified statistics to improve the service. These statistics do not identify a Customer or an End User. We do not use one Customer’s identifiable data to serve another Customer.
What we do not do
- We do not sell personal data or “share” it for cross-context behavioural advertising.
- We do not show ads, and we do not use personal data for advertising.
- We do not let our AI providers train their models on our data. Their API terms do not allow it.
7. Legal bases (EU and UK)
For data where Whisperr is the controller, we rely on these legal bases:
| Purpose | Legal basis (GDPR / UK GDPR) |
|---|---|
| Provide the service to your company, create and secure accounts, bill | Performance of a contract (Art. 6(1)(b)). Where the contract is with your employer: our legitimate interest in serving our customer (Art. 6(1)(f)). |
| Keep our systems secure, prevent abuse and fraud | Legitimate interests (Art. 6(1)(f)). |
| Measure and improve our website and product | Legitimate interests (Art. 6(1)(f)), or consent where the law requires it for cookies. |
| Measure our ads on Meta | Legitimate interests (Art. 6(1)(f)), or consent where the law requires it for cookies. |
| Send launch news and product updates you asked for | Consent (Art. 6(1)(a)). You can withdraw it at any time. |
| Answer your questions and requests | Legitimate interests (Art. 6(1)(f)). |
| Keep billing records and comply with the law | Legal obligation (Art. 6(1)(c)). |
For End User data, the Customer chooses the legal basis as controller.
8. How we use AI
Whisperr uses AI models from OpenAI and Anthropic. We call them through their business APIs.
What the AI receives
- Business context: the Customer’s product, brand and goals.
- For a message: the End User’s language, lifecycle stage, preferred channel and a short summary of recent activity. Event property values pass a filter first. The filter removes email addresses, phone numbers, links, IDs and HTML. It does not remove names.
- For the install wizard and the PR agent: source code and event definitions from the Customer.
What the AI does not receive
We do not send email addresses, phone numbers or push tokens to AI providers. The message writer does not receive the End User’s name trait. It writes a placeholder, and we add the first name only at send time.
Records and control
We keep a record of each AI request and response to check quality and to fix errors (see Retention). Messages run in approval mode by default: the Customer reviews messages before they are sent, until the Customer allows more autonomy. Whisperr chooses who gets a marketing or service message. It does not make decisions that have legal or similarly significant effects on End Users.
10. Where data goes (international transfers)
The Whisperr API, workers and main database run in Microsoft Azure in Sweden (EU). Backups stay in Sweden. Dashboard sign-in runs on Supabase in the United Kingdom.
Whisperr, Inc. is a US company. Some providers are in the United States: OpenAI, Anthropic, PostHog, Meta, Stripe, GitHub, Cal.com and Vercel. Cloudflare runs a global network. Our team also works from countries outside the EEA, including Georgia, and can access data from there to run the service.
When data leaves the EEA, the UK or Switzerland for a country without an adequacy decision, we use the European Commission’s Standard Contractual Clauses (and the UK Addendum), or the EU-U.S. Data Privacy Framework where the recipient is certified. We add other safeguards where needed. To get a copy of the safeguards, write to privacy@whisperr.net.
11. Retention
We keep data only as long as we need it for the purposes above.
| Data | How long we keep it |
|---|---|
| End User profiles, events, consent records and channels | Until the Customer deletes them, asks us to delete them, or closes the workspace. Then as in the last row. |
| Engine evaluation details (scores and reasons) that did not lead to a decision | 90 days. Then we delete them automatically. |
| Decision log, exposure log and holdout group | For the life of the workspace. We use them to measure the effect of messages against the holdout group (by default, 10% of End Users who get no messages). We delete them when the End User or the workspace is deleted. |
| Generated messages, delivery status and AI request logs | For the life of the workspace. We plan a shorter limit for AI request logs and will update this table when it is live. |
| Raw incoming payloads | Deleted after processing, normally within seconds. |
| Payloads that failed processing | 30 days. Profile traits and contact addresses are removed before storage. |
| Background job records | 7 days after success, 30 days after failure. |
| Audit log of MCP tool calls | 90 days. |
| Database backups | 14 days, on a rolling cycle. |
| Customer account data | While the account is open. After it closes, as in the last row. |
| Billing records | As long as tax and accounting law requires. |
| Website analytics | Up to 24 months. |
| Launch list and waitlist entries | Until you unsubscribe or ask us to delete them. |
| All Customer Data after a workspace closes | Available for export for 30 days, then deleted within 30 days. Backup copies expire on the 14-day backup cycle. |
12. Your rights and how to use them
Depending on where you live, you can ask us to:
- give you a copy of your data (access and portability);
- correct it;
- delete it;
- restrict or object to how we use it, including for direct marketing and profiling;
- withdraw consent, at any time, without effect on earlier processing.
California and other US states. You have the right to know, correct and delete personal information, and not to be treated differently for using your rights. We do not sell or share personal information, and we do not use sensitive personal information to infer characteristics.
How to ask. Write to privacy@whisperr.net. You can use an authorised agent. We may ask for information to confirm your identity. We answer within one month (45 days under US state laws). If a request is complex, we may extend this as the law allows, and we will tell you why.
End Users. Please contact the app you use first. That app is the controller. We help our Customers answer requests, including deletion and export, within the same time limits.
Complaints. You can complain to a data protection authority, for example the authority in the EU country where you live, or the UK Information Commissioner’s Office. Please contact us first. We want to fix the problem.
13. Children
Whisperr is a business service. It is not for children, and we do not knowingly collect data from children under 16 for our own purposes. Customers must not send us data about children unless we agree to it in writing. If you think we hold such data, write to privacy@whisperr.net and we will delete it.
14. Security
We encrypt data in transit with TLS and store it in encrypted Azure storage. We encrypt the credentials that Customers give us for their delivery providers. Access to production is limited to a small number of named staff. Read more on our Security page. To report a vulnerability, write to security@whisperr.net.
No system is perfectly secure. If a personal data breach affects you, we will tell you or the Customer as the law requires.
16. Changes to this policy
We will post any change on this page with a new effective date. If a change is material, we will also tell account owners by email or in the dashboard before it takes effect.
17. Contact
- Privacy questions and requests: privacy@whisperr.net
- Security reports: security@whisperr.net
- Support: support@whisperr.net
- Post: Whisperr, Inc., 2803 Philadelphia Pike, Suite B #1462, Claymont, DE 19703, United States
Questions? privacy@whisperr.net