This Privacy Policy was last modified on May 6 , 2023
We take your privacy as seriously as you do, and we are committed to protecting it. This Privacy Policy explains our practices regarding the collection, use, disclosure, transfer, storage, and protection of personal information that is collected through our products and services, as well as your choices regarding the same.
This Privacy Policy outlines how we gather, use, disclose, and protect the data gathered via our Service, as well as what choices you have regarding the collection and use of data.
WHEN is a brand of FrontGuard Bilisim Hizmetleri ve Ticaret Limited Sirketi. FrontGuard Bilisim Hizmetleri ve Ticaret Limited Sirketi ("FrontGuard Bilisim Hizmetleri ve Ticaret Limited Sirketi", "When", "Frontguard LTD", "Frontguard", “www.whenguard.com”, "we", "us" or "our", "company") provides this application, including any new features and related services, (collectively, the “Service” or “Services”) to you subject to the following Privacy Policy (as amended from time to time, the “Privacy”, “Agreement”). This Agreement applies to all visitors, users, and others who access or use the Service (“Users”). By accessing and using the Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Agreement. If you are accessing and/or using the Services on behalf of another individual, or as a consultant or agent of a third party, you represent and warrant that you have the authority to act on behalf of and bind such individual or third party principal to these Terms.
Before accessing or using our Products and/or Services, please make sure you understand this Policy.
I. INFORMATION WE COLLECT
A. Information We Collect when You Use or Interact with our Products and Services
B. Information Provided to Us by Third Parties
II. HOW WE COLLECT INFORMATION
A. Cookies and Similar Technologies
B. Analytics and Advertising Technologies
III. HOW WE USE YOUR INFORMATION
A. Registration Data
B. Covered Account Data
C. Sharing your Information
D. Commercial Communications
IV. DATA PROCESSING ON YOUR BEHALF
A. User Data
B. Your use of User Data
C. Service Configuration
D. Data Processor Obligations
E. Subcontracting
F. Data Removal
G. Warranties
H. Indemnity
X. CHANGES TO THIS PRIVACY POLICY
XI. CONTACT US IF YOU HAVE QUESTIONS OR CONCERNS
The information ‘When’ collects depends on what ‘When’ Products or Services you use and how you use them.
Note that failure to provide necessary information when requested may result in you not being able to fully utilize our Products and/or Services.
A. Information We Collect when You Use or Interact with our Products and Services
The Account Data and personal data about you or your Covered Accounts (hereinafter the "Data") that can be collected by us through the use of the Services or the Site are as follows:
To be able to send notifications from the mobile application.
Technical requirement for the app to work.
Technical requirement to understand which version users are on.
Requirement to be able to provide support in the correct language in customer service and to ensure that they can use the application in the correct language within the mobile application.
In order to provide subscribed users with in-app or subscription application services.
To increase the user experience by displaying the search history to the user again within the mobile application.
To improve the working health of the application by understanding why the application crashed.
Technical necessity for the app to work.
Technical necessity for the app to work.
Technical necessity for the app to work.
For correct operation, the application interacts with social networks. You will see this when you start using the functions of the application. We do not share your data with social networks.
What data can be obtained:
We collect and process personal data related to your Covered Accounts on your behalf as a core function of the Service. Our system requires SMS verified phone number to review the online times of Covered Accounts through registered devices and apps of Covered Accounts.
If you want to reach your number easily from your directory, you can optionally give directory permission. In this case, we will temporarily keep your selected phone number in the directory.
B. Information Provided to Us by Third Parties
We may receive information about you from other sources, including through third-party services that you connect to your ‘When’ account, or third-party services and organizations to supplement information provided by you. For example:
Please follow the links to the privacy policy of third-party service providers used by the Service to read more about the data that may be collected:
Google Analytics - https://policies.google.com/privacy
Firebase Analytics - https://firebase.google.com/policies/analytics
We use cookies and similar technology to collect aggregate (non-personal) information about Site usage by all of our visitors and to help us remember you and your preferences when you revisit the Site. These cookies may stay on your browser into the future until they expire or you delete them. We also use technology to remember your purchase selections in your shopping cart. These cookies usually are erased when you close your browser window. Further general information about cookies and how they work is available at www.allaboutcookies.org.
We use these Tracking Technologies to collect usage and device information, such as:
We also use Analytics, Advertising, and Anti-Fraud technologies in our Products and Services. These technologies may utilize the same cookies or similar mechanisms as further described below.
A. Cookies and Similar Technologies
Cookies are pieces of code that allow for personalization of our website experience by saving your information such as user ID and other preferences – if your browser is set to accept cookies. A cookie is a small data file that we transfer to your device’s hard disk for record-keeping purposes.
Web beacons are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the member’s device, web beacons are typically embedded invisibly on web pages (or in an email).
B. Analytics and Advertising Technologies
We may collect analytics data, or use third-party analytics tools such as Google Analytics, which may use Tracking Technologies, to help us measure traffic and usage trends for our websites, Products and Services. They types of data that analytics technologies may capture are as follows:
We may use and disclose your information to service providers that provide, maintain, and improve our Products and Services to develop new products and features, to determine which new products or services may be of interest to you and to promote our Products and Services.
We retain the information we collect for as long as necessary to provide our Products and Services, and we may retain that information beyond that period if necessary for legal, operational, or other legitimate reasons.
We may also de-identify, anonymize, or aggregate the information we collect, or collect it in a way that does not directly identify you. We may use and share such information as necessary for our business purposes and as permitted by applicable law.
The specific purposes for our acquisition, retention, use, and processing of your information are described in this Section III (How We Use Your Information).
A. Registration Data
We are responsible for processing your Registration Data, which is used for communications with you and for the provision and management of your use of our Services. It is also used to measure and improve the Services and functionality and to provide customer service, send email notifications and (unless no longer in the distribution list) newsletters, or communications, in general, about the Services, products and novelties, and offers or promotions offered by us. We will use the Registration Data for these purposes and to comply with the Terms of Service applicable to your Services and other legal notices.
B. Covered Account Data
You and, if applicable, your registered Administrators and Users (collectively, your “Authorized Users”), will be sent notification and other reports concerning certain Covered Account Data monitored by the Services. Your Authorized Users will have access to all Covered Account Data in our possession for review and, if necessary, correction. Your Authorized Users may request access to such Covered Account Data by emailing our customer support at info@frontguard.co
C. Sharing your Information
We treat your Data with strict confidentiality in accordance with applicable law. However, we may reveal your Data or other information about you to unaffiliated third parties: (1) if you request or authorize it; (2) if the information is provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas (provided that we will notify you of any such communication of your Data to the extent legally permissible), to enforce our Terms of Service or other agreements, or to protect our rights, property or safety or the rights, property or safety of our users or others; (3) if the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Data may be one of the transferred assets); (4) if the information is provided to our agents, outside vendors or service providers to perform functions on our behalf (e.g., analyzing data, providing customer service, processing orders, etc.); or (5) as otherwise described in this Privacy Policy. We will only share your Data with a third-party as described in items 3 through 5 of the preceding sentence if such third-party is obligated to protect your Data to the same extent we protect it under the terms of this Privacy Policy. We will never sell or rent your Data to third parties or augment, extend or combine your Data with data received from third party sources. Your Data will never be publicly displayed in any way by ‘When’ or any person or entity acting on When’s behalf.
D. Commercial Communications
By filling in and sending your Registration Data to us, you expressly consent to receive electronic commercial communications regarding the subject matter of the Services, and other services including alerts and notices about your Covered Account(s), and, if you selected the “opt-in” mechanism, you may also receive newsletters, offers and promotions. If you do not wish to receive such information from us, you can expressly opt out by sending a notification to info@frontguard.co
A. User Data
Upon your registration for, and deployment of, the WHEN Services, we start collecting Data from the devices and applications associated with the Covered Account(s), which may include personal data relating to you, to your Covered Accounts or to third parties, including information about your devices used by Covered Accounts, websites and applications that your Covered Accounts use, and contacts, connections, payments, messages and other communications, posted and received by your Covered Accounts (collectively, “User Data”). In accordance with applicable privacy law, to the extent that it applies to the Services, you and your Dependents are the respective Data Controllers (or the Responsible Party/ies) of this User Data and you appoint us as a Data Processor of such User Data for the purpose of providing our Services. User Data is not our property or under our control and is only monitored by us for purposes of providing the Services. Any User Data that combines personally identifiable information with non-personally identifiable information will be treated as personally identifiable information. We will take reasonably appropriate steps to maintain the accuracy of any User Data we collect.
Your personal data may be processed in accordance with the Republic of Turkey Law No. 6698 on the Protection of Personal Data.
Privacy laws applicable in your country may give you the following rights:
Right to be informed: what personal data an organisation is processing and why (we provide this information to you in this Privacy Policy).
Right of access: you can request a copy of your data.
Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
Right to erasure: you have the right to have your data deleted in certain circumstances.
Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
Right to data portability: you can request a copy of certain data in a machine-readable form that can be transferred to another provider.
Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.
Rights related to automated decision-making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.
The particular rights which are applicable to you (which might include other rights not listed above) may vary depending on your country. You should make yourself aware of the rights you have under applicable privacy laws in your country.
B. Your use of User Data
As Data Controller, you warrant that you have the appropriate authority to collect and process the User Data and you agree to (i) process and use the User Data in accordance with this Privacy Policy, the applicable Terms of Service and applicable law (including any laws in the country where you reside or make beneficial use of the Service). You will not submit to the Services any personal data relating to any individual that has not authorized such processing. You will protect the confidentiality of any accessible User Data and prevent access by or disclosure to any unauthorized third person. You will inform us within 24 hours about any problem arising in relation with management of your WHEN account and/or User Data. You and your Users will be responsible for any illegal use of other person’s data (personal or not) through the Services, including any use contrary to applicable data protection laws and/or in violation this Privacy Policy (including the Federal Family Educational Rights and Privacy Act of 1974 (“FERPA”) and/or in violation this Privacy Policy. The parties acknowledge that (a) User Data may include personally identifiable information from education records that are subject to FERPA ("FERPA Records"); and (b) to the extent that User Data in our possession, custody or control includes FERPA Records, we will be considered a "School Official" (as that term is used in FERPA and its implementing regulations) and will comply with FERPA. We will not disclose FERPA Records as “Directory Information” under FERPA.
C. Service Configuration
The Services provide online monitoring services for Covered Accounts as described in this Privacy Policy and the applicable Terms of Service. As part of the same, significant amounts of User Data may be collected and transmitted by the Services to WHEN. You are responsible for setting the configuration of the Services that (i) controls the supervision and monitoring of activities, and (ii) determines the personal data to be monitored and collected. The setting of those configurations constitutes instructions by you for us to process User Data on your behalf as necessary to provide you the Services. The level and degree of such surveillance and monitoring is entirely under your control and we will not be liable for any such configuration and control carried out by you. All such User Data will be under your responsibility, with WHEN as data processor in accordance with this Privacy Policy.
D. Data Processor Obligations
To the extent that we are a Data Processor on your behalf, we shall (a) implement appropriate technical and organizational measures to safeguard any User Data against any unauthorized or unlawful access, loss, destruction, theft, use or disclosure; (b) limit access to User Data only to those employees who need to know it to enable us to perform the Services; (c) only process the User Data as specified by this Privacy Policy and in accordance with your instructions, and (d) will not use the User Data for any purposes other than those related to the performance of the Services or pursuant to your written instructions. Upon the expiry or termination of this Agreement by way of de-registration, or upon your request, we will cease any and all use of the User Data and will destroy it. Other than as described in this Privacy Policy or the applicable Terms of Service, we will not disclose User Data to any third party without your prior written consent or pursuant to court or administrative order.
E. Subcontracting
As a Data Processor we may provide access to any User Data to a subcontractor processor if we reasonably consider such access and processing necessary to the performance of the Services. In the event of such access and by a subcontractor or any other third-party, before the access takes place, we shall ensure that an agreement with the third party is in place which is sufficient to require it to treat personal data in accordance with the applicable provisions of this Privacy Policy. In particular, you authorize us to subcontract to the third parties mentioned in the following section on international transfers.
F. Data removal
We generally retain your User Data on an identifiable basis for 30 days, after which it is deleted. We may retain portions of your User Data indefinitely as needed for the purpose of providing reports to you concerning your Covered Account(s). If you wish to remove all the User Data in your ‘When’ app;
Click "Settings",
Click "Delete all my data"
Confirm.
We will delete;
Phone Number
Contacts
In App Actions
Search History
Crash Logs
Diagnostics
Device ID
Or please copy your UUID from settings, uninstall ‘When’ from your devices, and send an email to info@frontguard.co. Once we confirm, we will immediately remove all of your Data from our active systems and back-ups within fifteen (15) days from confirmation of identity (except as indicated below). Each Covered Account’s User Data is controlled by the Covered Account and/or you as a Data Controller. We do not control any User Data and can not and will not provide access in response to any Covered Account’s request to review or correct errors in his/her User Data. We will forward any such requests received by us to you and you will be responsible for responding to any such requests.
G. Warranties
You, as the party responsible for User Data that we process on your behalf as Data Processor for the provision of the Services, represent and warrant to us that:
H. Indemnity
You agree to indemnify and keep us harmless from all claims, damages and losses we may suffer relating to or arising out of the processing of User Data and other third party personal data submitted to our systems during the course of your use and our provision of the Services.
We have adopted technical and organizational measures to preserve and protect your Data (including User Data) that we monitor from unauthorized use or access and from being altered, lost or misused, taking into account the technological state of art, the features of the information stored and the risks to which information is exposed, including without limitation encryption of all Data at rest and in transit. Further, we engage a third party to audit our security policies, procedures and standards on an annual basis. However, due to the nature of the information and related technology, we cannot ensure or guarantee the security of your Data and expressly disclaim any such obligation. If we learn of a security breach, then we will attempt to notify you electronically as soon as reasonably possible so that you can take appropriate steps. You have a role in the security of your information and you are responsible to make sure your log-in information is kept from other people. If your log-in information is lost or stolen, you can change your email/user name or password on the Account page of the Site. If we receive instructions using your log-in information we will consider that you have authorized the instructions.
You have the right to access, rectify, erase, block and oppose any processing of your personal data that we may have. You can update, amend or delete your contact information at any time by visiting the Settings page on the Site. You can update or change your billing and payment information on the My Account page on your own Phone. You can choose not to receive promotional emails from us by “unsubscribing” using the instructions in any promotional email you receive from us. This will not stop us from sending emails about your account or your transactions with us. You can choose to delete or block cookies by setting your browser to either reject all cookies or to allow cookies only from selected sites. If you block cookies performance of the Site may be impaired and certain features may not function at all. Moreover, you may at any time withdraw your consent to the processing of your personal data and information. This withdrawal will not have retroactive effects but may prevent us from providing the Services. The above is without prejudice to applicable law enabling conservation of your data for the purpose of defending our responsibility and complying with mandatory legal obligations. The aforementioned rights may be exercised by contacting us at info@frontguard.co or by mailing us at Frontguard Bilişim Hizmetleri ve Ticaret Limited Şirketi. We will assist you in accordance with the functionalities of the Services and this Privacy Policy to address any Covered Account request with regard to the processing of their personal data.
By registering for the Services and creating an account, you declare to have read and accepted the terms of this Privacy Policy. Without prejudice to the generality of the foregoing, you expressly and unequivocally consent to.
We may permit others to link to this Site or to post a link to their site on ours. We do not endorse these sites and are not responsible for other sites or their privacy practices. Please read their privacy policies before submitting information.
The Site and Services are designed to be a tool for parents and others to use to facilitate safe online interactions for Dependents. Only those over the age of 18, may subscribe to our Services. This Site is not designed nor intended to be attractive to children under the age of 13. While our Services include analysis of online interactions by children, we do not knowingly collect data from children under the age of 13 without first receiving verified consent. If you are under 13 please do not submit any information to us.
As we grow and change we may amend this Privacy Policy. The Policy in effect at the time you use the Site governs how we may use your information. If we make material changes we will post the revised Policy and the revised effective date on this Site and inform you of the change upon your next use of the Services. Please check back here from time to time to review any changes.
If you have any questions about our privacy practices, this Privacy Policy, our Products, or Services, please contact us at info@frontguard.co or call +902124001168 or write to us at FRONTGUARD BİLİŞİM HİZMETLERİ VE TİCARET LİMİTED ŞİRKETİ, Asmalı Mescit Mah. Asmalı Mescit Cad. Şahin Han No: 21 İç Kapı No: 55 Beyoğlu/İstanbul - Türkiye