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Privacy Police

Updated Aug 15, 19
Print Terms

Whosup takes all necessary measures to protect the privacy of the Member of its community (our user), in compliance with the legislation in force. This document details the ways of collecting, storing, using, sharing and disseminating personal data, as well as the measures taken to ensure the protection of the data collected.

The Member gives the free, express, informed and unequivocal consent for Whosup to use the information obtained, in addition to the services offered by its Platform (Web and App), the customization of Member service, as well as the identification of those responsible for undue and / or illegal conduct performed using the Whosup Platform.


Data collect.

  • Register. The data to be provided by the Member when the profile is created in the Platform will depend on how the Whosup services will be used. In addition to general information such as email, phone, date of birth, gender and full name, the Member may complete a detailed questionnaire on different topics. This information will only be used to customize the Whosup services, and display events and people/groups compatible to the Member’s interests, personality and profile.
  • CoachBot Pep. The conversations generated with Pep, Whosup’s lifestyle and relationship coach (artificial intelligence), will be collected and stored for the customization of the service offered in terms of improving assertiveness in offering options of activities or people/groups to meet, as well as general conversations between Member and Pep. All data provided in this context will be confidential and used anonymously, that is, they will not be able to identify a particular person.
  • Cookies. In order to offer the best browsing experience and shopping to the Member, Whosup uses technologies to collect and store information related to the Member's visit to the Platform (Web and App), and this may include the sending of one or more anonymous cookies or identifiers that collect data related to the browsing preferences and pages visited by the Member. In this way, the presentation of Whosup services is personalized and aligned with the personal interests of each member. The use of this data is restricted to the stated purpose and Whosup undertakes not to use or allow the use of such data for any other purpose. In addition, the collection, storage and processing of these data is absolutely automated, and there is no possibility of human contact with the data in question. The Member may and at any time, in case of disagreement with the above cookies policy, use the browser tools which prevent the installation of cookies and also delete any cookies on the internet connection device. In this case, some features of the Whosup Platform may have errors. Whosup may also use other technologies to collect Member’s browsing data and undertake to save, treat and use them in accordance with this Privacy Policy.
  • Access records. Whosup will maintain in its database all information regarding Member access to the Platform, including but not limited to the IP address, the pages accessed, the times and dates of access, and the access device used, in accordance with the current legislation. Such records may be used in internal or public audits to investigate practices that could generate any harm to Whosup or third parties on the Platform, including the practice of crimes in virtual environments.
  • Purchases made on the Platform. When the Member contracts a paid service or makes a purchase directly on Whosup Platform, the Member provides information such as debit or credit card number, validity and/or other financial information.
  • Conversations with other Members. When a Member exchanges messages with another Member (or group of Members) through Whosup Platform, the messages will be stored in our servers and we can collect the information transmitted there. This information will be confidential and used anonymously, that is, they will not be able to identify a particular person.
  • Geolocation, photos and videos. If Member authorizes, Whosup Platform may collect the respective exact geolocation, according to the means of service and how the Member uses the Platform, including GPS, Bluetooth or Wi-Fi wireless connections. The geolocation collection may also occur in background when the Member is not using the Platform directly. In the same way, if the Member also grants permission to do so, Whosup may collect photos and videos posted on the Platform as well as the list of telephone and email contacts on the mobile devices. Also, as per Member authorization, pushes (alerts) of event, people and groups, and/or Pep conversations could be sent to Member devices.

Use of data. The Members’ data will be used for the following purposes: sending information on purchases made on the Platform, advertising, statistics’ development and/or improvement of interactivity tools, depending on the service plan contracted by the Members. The Members’ data will also be used to comply with legal/court orders. The data stored in the Whosup Platform will not be used in a different way without the prior consent of the Member.

Data storage. Whosup will store all collected data in its protected and secure databases. Such data will be accessed only by computerized automated processes, authorized professionals and in the cases listed in this Privacy Policy.

Whosup has a specific regulation to Members regarding the characteristics and conditions of use of its services: Terms and Conditions of Use.


We will use the information and personal data of Members to provide the best possible service. In addition, we will use the information collected and transmitted to:

  • Enable connection, communication, entertainment, support and enrichment for the creation and development of relationships with other Platform Members;
  • Recommend Members who have common interests and/or temperament (personality) complementarity, via the compatibility index among Members;
  • Ensure a solid and consistent experience in all devices for use;
  • Provide new services or third party offerings that might be of Members’ interests;
  • Enhance Whosup’s services and develop new ones according to the Members’ interests;
  • Provide ads according to Members’ preferences and interests;
  • Prevent, detect and combat violations and fraud or other unauthorized activities that could harm the Platform Members and/or the Whosup community.

Whosup will use Member’s information through:

  • Free, express, informed and unequivocal consent of the Member. Whosup may, from time to time, request consent to use Members’ information for specific reasons. Thes Members may revoke their consent at any time by contacting the email
  • Legitimate interest. Whosup may use its Member’s information in cases where Whosup has the legitimate interest to do so, such as support and promotion of Whosup activities, the protection of the regular exercise of Member’s rights or the provision of services that benefit individual or collectively the Whosup community, respecting the Members’ legitimate expectations with respect to Whosup's services and fundamental rights and freedoms related to information privacy.

Members have the following rights regarding the use of their personal data:

  • The right to deactivate and remove their data and to delete their account;
  • The right to access, rectify and cancel, and opposes the processing of their data, including for marketing and advertising preferences of the account;
  • The right to determine how data will be used and processed, and the use of personal data after death;
  • The right to request the receipt of personal data by Members.

Members may exercise and practice such rights through the Whosup Platform itself or by a specific tool created in the future. They may also request such rights directly by email to

The privacy laws applicable to this document guarantee the Members’ right to review their personal information that Whosup has, as a right of access. Members may request a copy of their personal information by submitting a request at this link or by sending this request to

  • Intracompany sharing. The data can be shared within Whosup’s subsidiaries, as well as among companies of the same economic group, both national or international.
  • Transfer to trading partners. In the case of transfer of pertinent data to transactions with trading partners, they will be contractually obliged to protect the information provided.
  • Transfer to third parties: In the event that statistics are compiled by a third party company, the shared data will not have any element of identification of the Member.
  • Disclosure of Member’s data to other Members of the Platform: According to the services provided, Whosup will disclose the data of Member’s profile with other Members which have "compatible profiles". Information such as photos, name, age, posts published and affinity groups will be available to Members with whom your profile is aligned and compatible.

Whosup will not disclose your contact information to any Platform Member, unless you post such information openly on your profile, leaving yourself at your own risk.


If you are a resident of the State of California, located in the United States of America, and under the California Consumer Privacy Act, you may request notice with disclosure of categories of your personal information that Whosup shares with business commercial partners for purposes of direct marketing during the previous year. To request such notification, send your request through this link.

In order for Whosup to review your request, Whosup may take about 30 days to return with a response and Whosup may also request proof of identity to grant its response.


Whosup can provide links to external sites, plug-ins, and business partner applications. If access to other sites occurs from the links made available in Whosup Platform, the operators of these other sites and the commercial partners may collect, store and share the personal information of the Members who have accessed.

Whosup does not control third-party sites and Whosup recommends that you review the privacy policies of these third parties, which may be different from Whosups, so that you can understand the procedures for collecting, using and storing personal data.


The services offered by Whosup Platform are limited only to those who are 18 years of age or over. Whosup will not permit the use of its Platform for persons under the age of 18 and will not, knowingly, collect personal information from such persons.

If there is any personal information about a person under the age of 18 in its Platform (Web or App), Whosup will delete or destroy this information as soon as reasonably possible.


Technological resources. Whosup adopts advanced technological resources to ensure the security of all personal data collected and stored. Access to the Members database is limited only to those whose functions require the contact with personal data.

The Members declare that they are the legitimate holders of their personal data and may at any time use the Platform's tools to edit, update or remove them from the database.

Monitoring. Whosup monitors its systems to address possible vulnerabilities, in order to avoid inconsistencies and security events. Whosup also reviews, regularly, its data collection, storage, and processing practices to maintain its security standards.

Total or partial suspension of services. Whosup may suspend all or part of the services provided to a Platform Member without prior notice, if Whosup suspects or detects a security breach.


Whosup, in order to always be in compliance with the applicable laws and procedures for the protection of the personal data of its Members, may change this Privacy Policy from time to time. When Whosup makes any significant changes to this Privacy Policy, a notification will be sent to the member or alert within the Platform, so that the Member has time to review the changes.


For any questions regarding this Privacy Policy or any personal data relationship, please contact:

  • Directly by Whosup Platform;
  • Sending an email to contact;
  • By mail through the address: Whosup Inc., 44 Tehama Street, San Francisco, CA 94105, USA.

Terms and Conditions

Updated Aug 15, 19
Print Terms
1. Presentation

WHOSUP INC., with head office at 44 Tehama Street, San Francisco, CA 94105, USA, with EIN #82-3898859, has created and developed, and maintains a Platform (Web and App) to connect, support, entertain and enrich people for great friendships, for a reason, a season or a lifetime. Whosup believes no one needs to be alone or bored. And happiness is a journey, built with meaningful and authentic relationships. Therefore, the Whosup commitment is to help its Community Members have good off-line experiences.

2. Whosup’s Services

The Whosup Platform provides its Members with three main lines of services, namely:

What events/activities to attend and who to go with (individuals or groups): Whosup helps its Members do more things they enjoy.

  • Members can scroll down the “what to do?” activities’ feed, which can be filtered that by location, date and category. Once they find what to do, just select it, wait for confirmation and then go for that offline activity.
  • If Members do not find an activity of interest, they can create their own activity. Then they choose “who to go with”, either individuals or a group. Members can also post it on the activities’ feed for any other Member to see it. Once they get a response, then they can confirm the activity and go for it.
  • Members are able to check and invite people they don’t know yet with the guidance of Whosup’s compatibility index, which is based on interests and personality. The Radar feature displays Members, within certain distance, according to their temperament.
  • Members can also participate in affinity groups, whose coordinator creates discussions and incentivizes offline get-togethers.

Personal Relationship and Lifestyle Coach: Coachbot Pep is Whosup’s 24x7 artificial intelligence assistant, under continuous enhancement, developed to support Members in three main activities:

  • Coachbot Pep helps Members to complete and improve their personal profile, so they can find compatible, certified and secure people;
  • Coachbot Pep assists Members figuring out "what to do?" and/or "who to go with?", even recommending Members to individuals or groups to increase probability of being accepted;
  • Coachbot Pep can discuss relationship issues. The feature is in continuous training and Coachbot Pep doesn't know all the answers. Coachbot Pep will take note, learn and notify Members when able to give them a good response.

eWallet and WUPs: This service that guarantees Members the possibility of collecting points (“WUPs”) that can be used for payment of expenses and contracting paid services with Whosup and/or its partners, such as event promoters and show tickets, restaurants, hotels, bars, travel/tourism, retailers and gas stations.

Important: Whosup will never use Members’ personal information, or conversations between them and Coachbot Pep, to offer things they haven’t requested nor will Whosup ever sell Members’ personal information. Confidentiality and security of Members’ data are extremely important to Whosup.

The purpose of these Terms and Conditions of Use is to establish the rules and conditions for participation of Users (“Members”) on the Whosup Platform (Web and App), and is properly filed at Whosup’s head office with the date of November 12, 2018, as well as published on the Platform (Web and App) for public and general knowledge.

Members accept these Terms and Conditions of Use by clicking the "accept" button, which is at the end of this document, during the registration process of each Member on the Whosup Platform (Web and App). Members are responsible for knowing the entire content of this document, to decide on their participation on the Whosup Platform, being that through acceptance and adhesion the interested party will be able to make their registration to enjoy all the benefits and advantages of the Platform.

For the purpose of demonstrating the validity of the acceptance of this document by the Member, as well as of its manifestation of will in this sense, Whosup may store log records of its acceptance, at the time of its registration.

In the event of any disagreement, in whole or in part, with the terms described herein, the interested party must refrain from registering and using any Whosup functionality.

3. Rules of use

Member agrees to use the Platform (Web and App) respecting and observing these Terms and Conditions of Use, as well as the current legislation, customs and public order.

The Members agree that they cannot (i) infringe the rights of third parties, regardless of their nature, at any time, including during the use of the Platform; (ii) perform acts that limit or prevent access to and use of the Platform, under appropriate conditions, to other Members; (iii) access to Platform programming areas, databases or any other set of information that escapes the public or restricted areas of the Platform; (iv) perform or permit reverse engineering, translate, modify, alter the language, compile, modify, reproduce, distribute, use, or otherwise dispose of the Platform in a manner that violates Whosup or third party rights; (v) use the Whosup domain to create links or shortcuts to be made available through unsolicited email (spam) or on third-party sites; (vi) use automated data collection and selection applications to carry out mass operations or for any purpose, or to collect and transfer any data that may be extracted from the Platform for unauthorized or unlawful purposes; (vii) use the tools and functionalities of the Platform to disseminate messages that are not in accordance with the Whosup vision, racist, political, religious, derogatory, defamatory and/or libelous of any person or social group; (viii) convey images of obscene, pornographic content and explicit violence; (ix) misuse CoachBot Pep; and (x) create profiles with false information.

As a community maintenance element, Whosup provides Members with tools: (i) denunciation and blocking of posts considered outside Whosup community's purposes and (ii) denunciation and blocking of other Members' profiles.

In the event of improper use of the Platform, including the listed above, Whosup may delete the Member profile, which causes the cancellation of balance in the eWallet.

In addition, if there are harmful consequences of any kind, the appropriate administrative, judicial and extrajudicial measures may be taken by Whosup in order to protect the integrity of the other Members of the Platform.

4. Access Account

In order to gain initial access to the Whosup Platform, the Member must create an account entering personal data, which will be stored and used for identification of the eWallet, emphasizing that the creation of each Access Account presupposes the express consent on collection, use, storage and treatment by Whosup and its trading partners.

Whosup may refuse, suspend or terminate a Member's Access Account whenever it suspects that the information provided is false, incomplete, outdated or inaccurate.

The Members, at the time of creation of their Access Accounts, determines to their Member name, Whosup ID and their access passwords. It is the sole responsibility of each Member to maintain the confidentiality of the Member name and/or access password.

5. Personal data, privacy and security

Whosup has a specific policy to regulate the collection, storage and use of personal data, as well as its security: Privacy Policy. This specific policy integrates these Terms and Conditions of Use inseparably, noting that the usage data of the Platform will be archived in accordance with the legislation in force.

6. Offer of services

Whosup will make available on its Platform, for each service or product for sale, a description, which will contain information pertinent to the offer, such as the period of validity, origin, availability, payment terms and total price offered by Whosup and/or its Commercial Partners.

7. Intellectual property

The marks, names, logos, domain names and other distinctive signs, as well as any content, design, art or layout published on this Platform (Web and App), are wholly owned by Whosup.

8. Coachbot Pep

Coachbot Pep is a personal relationship and lifestyle coach programmed and developed with artificial intelligence infrastructure, as well as information and studies shared by personal relationship experts. Through interaction with the Member, Coachbot Pep is able to learn and improve service and the Member experience.

As expressed in the Privacy Policy, any kind of data, sensitive or not, collected from the interaction with Coachbot Pep, are exclusive of the database of Whosup. If they are to be utilized in surveys and/or behavioral studies, they will be anonymized and or utilized in groups, therefore, not linked to the respective Member.

9. WUPs

eWallet is a service that guarantees Members the possibility of collecting points (WUPs) that can be used for payment of expenses and contracting services with Whosup and/or its Commercial Partners, such as event promoters and show tickets, restaurants, hotels, bars, travel/tourism, retailers and gas stations.

WUPs are the units of measure used by Whosup to account for the accumulation and redemption of benefits offered by Whosup and/or its Commercial Partners.

Any available points (WUPs) for accumulation and/or redemption in the loyalty network must be understood as the property of Whosup, and its use must be made in accordance with the terms of this regulation (Terms and Conditions of Use).

Validity of WUPs. The WUPs (points) will have no expiration date, unless the Member's balance is deleted due to misuse of the Platform.

Prohibition of WUPs Negotiation. Member's negotiation of its WUPs and/or the benefits offered by the Whosup Platform and/or its Commercial Partners in any form, including but not limited to the purchase, sale, or exchange of WUPs is expressly prohibited. Evidence of such practices will result in the immediate exclusion of the Member from the Whosup Platform and the cancellation of the WUPs, regardless of whether legal action is taken.

In the event of damage or loss to Whosup, due to the purchase, sale or exchange of WUPs and Platform benefits, the Member shall be responsible for all damages incurred.

WUPs assignment or donation to third parties (not a Member of the Whosup Platform) is expressly forbidden, under any title, including by succession or inheritance. In the event of the death of the Member holding the eWallet, it will be terminated and the balance of WUPs will be zeroed (ie the balance will be transferred to Whosup).

Conversion into cash. Under no circumstances will the WUPs be converted in whole or in part into cash, either in account credit and/or pecuniary.

Reimbursement of WUPs. WUPs can only be reimbursed in the event of an error in the Whosup Platform. The assumption of Member dissatisfaction and products/services problems do not lead to the refund of WUPs, any claim to this effect should be sent directly to the responsible Commercial Partner.

Accumulation of Wups. WUPs will be added to Member’s eWallet in the following ways: (i) direct purchases of WUPs on the Platform; (ii) transfer between Members via Platform; and (iii) rewards from Commercial Partners.

Charge of transfer fee of WUPs to/from Whosup’s Commercial Partners. In case of transfer to and from the Member and Whosup’s Commercial Partners, including respective loyalty programs, a percentage (or fixed amount) per transaction may be charged as a transfer fee.

Redemption. Members with WUPs accumulated in eWallet may redeem their WUPs, converting them into Whosup paid services (Premium or VIP plans) and/or benefits offered by the Platform Commercial Partners, which may include services, products, promotions and/or rewards of other loyalty programs.

WUP accounting. Each redemption or transfer carried out must count the WUPs accumulated in the eWallet by a single Member, being forbidden the sum of WUPs of different Members, so that the accounting is transparent for each transaction.

Costs/charges of redemption: The redemption of WUPs by the Members may involve possible costs and/or encumbrances, according to the type of the redeemed benefit and the Commercial Partner channel used. The Members should consult the information about such costs in the channels made available by the Commercial Partners on the Whosup Platform.

Responsibility for the redeemed benefit. All Whosup Platform redeemable benefits, including services, products, promotions, and rewards from loyalty programs, are independently managed by Commercial Partners without any intervention or participation by Whosup. In that sense, Whosup does not have any direct, indirect, subsidiary or joint liability for such benefits, so that any defect or vice shall be claimed directly with the Commercial Partner.

10. Responsibility

Limitation. Whosup is not liable for any of the following, including: (i) damages and losses that Member may experience due to the unavailability or partial operation of the Platform and/or all or some of its services, information, content, functionality, Coachbot Pep and/or tools, as well as for the inaccuracy, limitation or inexactitude of any of these elements; (ii) damages and losses that the Member may experience on internet sites accessible through links included in the Platform; (iii) damages and loses that the Member may experience as a result of using the Platform (Web and App) in violation of these Terms and Conditions of Use or the Privacy Policy; (iv) damages and loses that the Member may experience as a result of the use of the Platform (Web and App) in disregard of the law, customs or public order; (v) damages that the Member may experience as a result of failures in the Platform (Web and App), including arising from system, server or network connection failures, or from malicious interactions such as viruses, software that may damage the equipment or access information of the Member's equipment; (vi) damages and losses that the Member may experience due to distortions that the images of the offers made available by the Commercial Partners may present, emphasizing the merely illustrative character of such images; among others.

11. Links to other websites

The Whosup Platform may contain links that direct the Member to Commercial Partners and/or third-party sites. The inclusion of such links does not imply any link, monitoring or liability of Whosup on those sites, as well as their contents or owners.

12. General provisions

Whosup Platform partners. Whosup reserves the right, at any time and independently of Members' prior consent, to include, exclude or modify the participation of Commercial Partners from WUPs’ accumulation or redemption.

Omission. Any situation not foreseen in these Terms and Conditions of Use, as well as eventual cases not covered, will be decided exclusively by Whosup.

Renunciation or novation. It shall not constitute a waiver, ineffectiveness or novation of obligation, nor shall it affect Whosup's right to require compliance with the provisions of these Terms and Conditions of Use, the following assumptions, but not limited to: (i) Whosup's omission to require enforcement of any provision of the Terms and Conditions of Use; (ii) Whosup's tolerance related to noncompliance with any provision herein.

Fortuitous case and force majeure. Whosup will not be considered in default or delinquent if the reason for noncompliance arises from a fortuitous event or force majeure, in the form established by the United States Civil Code.

Applicable law and venue. This Terms and Conditions of Use shall be governed by and construed in accordance with the law of the State of California. Members agree that any legal action or proceeding under or with respect to this Terms and Conditions of Use will be brought in the Supreme Court of the State of California sitting in the county of San Francisco and/or the United States District Court sitting in San Francisco, and for the purpose of any such legal action or proceeding, Members hereby submits to the jurisdiction of such courts. Members hereby agree not to raise, and waives any objection it may have to or any defense it may have based upon the venue of such courts or based upon an inconvenient forum. Members also agree not to bring any legal action or proceeding under or with respect to this Terms and Conditions of Use outside the Supreme Court of the State of California sitting in the county of San Francisco and/or the United States District Court sitting in San Francisco. The parties to this Terms and Conditions of Use hereby voluntarily, knowingly and irrevocably waive any constitutional or other right each may have to a trial by jury in the event of litigation related to or concerning this Terms and Conditions of Use.

Should any litigation, arbitration, meditation or other legal proceeding be commenced concerning this agreement, the Whosup Inc. shall be entitled, in addition to such other relief as may be granted, to reimbursement of Whosup Inc.'s actual attorneys' fees and costs incurred in connection with such proceeding. ''Actual attorneys' fees'' means the full and actual cost of any legal services actually performed in connection with the matter for which such fees are sought calculated on the basis of the usual fees charged by the attorneys performing such services, and shall not be limited to ''reasonable attorneys' fees'' as that term may be defined in statutory or decisional authority.

Entire Terms and Conditions of Use. This Terms and Conditions of Use, dated November 12, 2018, contains the entire Terms and Conditions of Use between Members and the Whosup Inc. with respect to the engagement relationship between Members and the Whosup Platform and supersedes all prior Terms and Conditions of Use, undertakings and commitments, whether oral or written. No amendments to this Terms and Conditions of Use shall be effective, except by written Terms and Conditions of Use signed by both each Member and the Whosup Inc.

Invalid provisions. The invalidity or unenforceability of any paragraph or provision of this Terms and Conditions of Use shall not affect the validity or enforceability of the remainder of this Terms and Conditions of Use, or the remainder of any paragraph or provision. This Terms and Conditions of Use shall be construed in all respects as if any invalid or unenforceable paragraph or provision were omitted.