WiSP Privacy Policy

Last Updated: 2/20/2025

1. About this Privacy Policy

This Privacy Policy (“Policy”) is designed to provide you with information about how WISP USA, Inc. and its subsidiaries and affiliates (collectively, “WiSP" or “we,” “us,” and similar pronouns) collects, processes, and discloses personal data. Please take a moment to carefully review this Policy.

This Policy applies to processing of personal data by WiSP when you visit our website at get-wisp.com (the “Sites); use a WiSPer or Console device (each a “Device”); use WiSP’s mobile application(s) (the “App”) or use other WiSP services (together with WiSP’s Site, Devices, and App, the “Services”). For the purposes of this Policy, “personal data” or “personal information” means information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, device, or household. It does not include data or information that has been de-identified.

2. What personal data does WiSP collect?

WiSP processes the following personal data categories when you use our Services:

• User information such as name, gender, date of birth, and your photograph, should you choose to provide one.

• Login information such as your email address and password.

• Billing information that you have provided in connection with your subscription, if any. 

• Contact information about notification contacts, including but not limited to those in your organization. 

• Affiliation information about your university, sorority, fraternity, club, or other organizations about which you are a part and that partner with WiSP.

• Device information such as IP address and location data about your mobile device and any Devices to which it is paired.

• User-provided event information such as the venue, location, and other details for events that you created, plan to attend, attend, or leave.

• Other user-provided information and feedback, including information about the drink samples you have tested.

• Measured data such as the test results from drinks that you have tested with your WiSPer Device.

 

Please note that the test results for drinks that you test with your Device(s) will be associated with your WiSP account even though they may not be drinks that you consumed, plan to consume, or possessed. You are expressly authorized to use your Device to test other individuals’ drinks.

 

Please also note that some of the personal data we process, including any data concerning your health and safety, may be considered special or sensitive personal data. Under applicable law, such data is processed only if you have given your consent for processing. For clarity, and as explained below in Section 3.2, by accepting this Policy and by providing sensitive personal data to WiSP, you consent to WiSP’s use of it to provide you with our Services.   If you access or use any of WiSP’s location-based Services, WiSP may process the location of your device while the service is active. WiSP does not process such location data without first obtaining your consent. You may disable such automated location processing at any time using your device's location permission settings. If you choose to disable access to location data via your device, please note that certain Services, features, or functionalities may no longer be accessible. Please note that you may also elect to provide WiSP information about your location, such as when you check in to an event. You may also configure the Services’ settings to enable WiSP to use your location information in a de-anonymized fashion, including to inform WiSP’s heatmap features.

3. Why does WiSP process your personal data?

The sections below explain the reasons we process your personal data. You will also find information on our legal basis for processing your data, and our data sources.

3.1 Processing Purposes

When you use WiSP’s Services, we collect and process your personal data for the following purposes:

To provide WiSP’s Services

We process personal data when you use our Services, such as to provision and provide access to your WiSP account and to enable you to test drinks with your Devices; create, learn about, and check-in or -out of events; and send notifications, including emergency notifications, to your contacts.

To provide customer service

We process personal data to provide customer service and manage our customer communications.

To improve our Services

We process personal data regarding your use of our Services to understand how you use our Services and how we can improve them. For example, we may process personal data to improve your user experience in the App. When feasible, we do this using data that has been processed in a manner to protect your privacy, such as by pseudonymization.

To perform analysis

We may process personal data about beverage consumption and event attendance to benefit our users and improve the insights we provide with our Services. When feasible, we do this using data that has been processed in a manner to protect your privacy.

To market our Services

We process marketing-related personal data to provide online advertising and other marketing communications on behalf of WiSP and our partners. For example, as explained more fully in Section 8 (Use of cookies), we use cookies and similar technologies on our website to create audiences for online advertisement. You can opt out of direct marketing communications from WiSP.

To comply with legal obligations

In certain cases, we must process certain data when it is required by applicable laws, regulations, and legal processes. Such obligations may relate, for example, to accounting and tax requirements, legal claims, or compulsory legal processes. WiSP will oppose any request to provide legal authorities with access to personal data of identifiable WiSP users for surveillance, prosecution, or other law enforcement purposes. We will notify users if we receive any such request whenever legally permissible.

3.2 Legal basis for processing

Data protection law in the U.K. requires a "lawful basis" for collecting and retaining personal data. Our lawful bases for processing your data depend on the particular processing purposes, including:

Contract

When processing personal data for the purpose of providing our Services, we process personal data on the basis of a user contract, which is formed when you create your account and accept our Terms of Use.

Consent

We process your sensitive personal data only with your consent. You can provide your consent to us for processing your data through your actions, such as by inputting sensitive personal data to the App and by testing beverages with your Devices.

Legitimate interest

We process your personal data based on our legitimate interests when we process it for the purposes of marketing our Services and Sites, providing our customer service, and improving our Services. When choosing to use your personal data on the basis of our legitimate interests, we carefully weigh our own interests against your right to privacy, in compliance with applicable law.

Vital interests

Under certain limited circumstances we may process personal data to protect the vital interests of the data subject or of another natural person, e.g., in response to positive tests for harmful, controlled, or other undesirable substances in beverages.

Legal obligation

WiSP must process certain information to comply with statutory obligations which may vary in each country. For example, such obligations can relate to consumer protection or tax laws.

3.3 Data sources

In most cases, WiSP collects personal data directly from you, such as when you register for an account, provide information to our App, or use a Device. We may also process personal data that is produced from the information you provide to us, or that is provided to us about you, such as when an organization to which you belong, with which you are otherwise affiliated, or which you patronize, provides us with information about you. WiSP may also rely on trusted third-party processors to process data on our behalf, such as our cloud service providers.

Please also note that you may share limited personal data through the Services with other WiSP users and members of your organizations. The information you share may include events you create, register to attend, and check-in to and -out of, and you may also identify your contacts.

4. Jurisdictions with enhanced privacy requirements

4.1 U.S. consumers

This notice supplements the information contained in WiSP’s Privacy Policy and applies solely to all visitors, users, and others who reside in states within the U.S. with enhanced privacy notice requirements, such as California, and who access or use WiSP’s Services.

Collection, use, and sharing of information

When a customer interacts with WiSP’s Services, WiSP collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, device, or household.

Information about the categories of personal information we collect, the purposes for which your personal information is processed, and any sharing of your personal information can be found from relevant sections of this Policy:

• Processed data

• Data sources

• Processing purposes

• Data sharing

In the preceding twelve (12) months, WiSP has not sold personal data to third parties. We have collected and disclosed only the categories of personal data processed by WiSP under this Policy as described in the Data Sharing and Disclosures section.

U.S. consumer rights

If you are a resident of a state with enhanced rights related to the personal data WiSP may process about you, you have certain rights, including:

Right to know about the personal information we collect and share

U.S. state laws may give you the right to request that we disclose the personal information we have collected about you over the past 12 months, which we only provide after we receive and validate your request. Once we receive and confirm your verifiable request, we will disclose to you:

• The categories of personal information we collected about you;

• The categories of personal information we have disclosed about you (if any);

• The categories of sources for the personal information we collected about you;

• Our business or commercial purposes for collecting or selling that personal information;

• The categories of third parties with whom we share that personal information; and

• The specific pieces of personal information we collected about you.

Right of correction

You have the right to request correction of your personal information. After we receive and validate your request, we will correct your personal information, unless an exception applies. Please note that you can correct and update some of your basic information via our App and Site.

Right of deletion

You have the right to request erasure of your personal information, subject to certain exceptions, such as when we have a legal obligation to retain the data in question. After we receive and validate your request, we will delete your personal information, as well as direct our service providers to delete your personal information unless an exception applies.

How to make disclosure, access, correction, or deletion requests

If you reside in a state that provides for enhanced privacy rights, you can request disclosure, access to, correction, and/or deletion of your personal data as described above by submitting a verifiable consumer request to us by sending an e-mail to privacy@get-wisp.com, including the following information along with your request: your full name, organizational affiliation (if applicable), and e-mail address. We may request that you provide additional information if necessary to confirm your identity. This is for security purposes, and is required by law in some cases.

Only you, or a person registered with the appropriate mechanism associated with your state of residency that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

You have the right to make a free request up to two times in any 12-month period. We will respond to all validated requests within 45 days of receiving your request, unless we request an extension. In the event that we reasonably require an extension in order to respond to your request, we will notify you of any such extension within the initial 45-day period.

Non-discrimination

WiSP does not discriminate against users who request to exercise their privacy rights. Unless an exception applies, this includes our promise not to:

• Deny you goods or services;

• Charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties;

• Provide you a different level or quality of goods or services; or

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

4.2 U.K. and EU consumers

This notice supplements the information contained in WiSP’s Privacy Policy and applies solely to all data subjects within the United Kingdom or European Union, and who access or use WiSP’s Sites, Apps, Devices, or Services.

UK and EU consumer rights

Whenever WiSP processes your personal data, you have certain rights that enable you to control how your personal data is being processed. This section provides you with information about each of those rights. If you wish to exercise your rights as a data subject, please contact dataprotection@get-wisp.com with your request to do so.

Right to access data

You have the right to know what personal data is processed about you. You may contact us to request access to the personal data we have collected about you, and we will confirm whether we are processing your data and provide you with information about the personal data we have collected and processed.

Right to erasure

You have the right to request the deletion of your personal data in certain circumstances. We will comply with such requests unless we have a valid legal basis not to do so, or a legal obligation to preserve the data.

Right to rectification (of inaccurate data)

You have the right to request correction of any incorrect or incomplete personal data we have stored about you. Please note that you can correct and update some of your basic information directly within our Services.

Right to data portability

You have the right to request receipt of the personal data you have provided to us in a structured and commonly used format. The right to data portability only applies when we process your personal data for certain reasons, such as by contract or by your consent.

Right to object to processing

You have the right to object to the processing of your personal data under certain circumstances. In the event that we do not have legitimate grounds to continue processing such personal data, we will no longer process your personal data after we have received and verified your objection. You also have the right to object to the processing of your personal data for direct marketing purposes at any time.

Right to restrict processing

You have the right to request that we restrict processing some types of personal data under certain circumstances. 

Right to withdraw consent

If we have requested your consent in order to process your personal data, you have the right to withdraw your consent for such processing at any time where this right is provided by local law. It should be noted, however, that withdrawing your consent may lead to issues or restrictions on your ability to fully utilize the Services. Please note that you can always unsubscribe from receiving our newsletter and other marketing emails by using the ‘Unsubscribe' link provided in the emails you receive from us.

Other concerns

We strive to address your privacy concerns. If you have contacted WiSP about your issue and are still unhappy with our response, subject to applicable law, you may contact your local supervisory authority regarding your issue. However, we urge you to first contact us at privacy@get-wisp.com so that we can more quickly resolve your issue before escalating the issue.

You may also contact DataRep, our UK Representative, with concerns. They can be reached by:

• Sending an email to DataRep at datarequest@datarep.com  quoting <Wisp USA, Inc.> in the subject line,

• Contacting DataRep via their online webform at www.datarep.com/data-request, or

• Mailing your inquiry to: DataRep, 107-111 Fleet Street, London, EC4A 22AB, United Kingdom (please ensure your request is addressed to DataRep and not WiSP).

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If you have a question or complaint about our handling of your personal information under the Data Privacy Frameworks, please contact us at privacy@get-wisp.com.

5. Data sharing

5.1 How we may share your personal data

We may share your personal data with the following types of entities:

Other WiSP users in connection with the Services

Part of the WiSP Services involve sharing beverage testing results, event attendance information, and notifications (including emergency notifications) among WiSP users and organizations. 

Service providers

Including web hosting providers, payment processors, vendors who advertise our Services, cybersecurity consultants, other technology and communications providers, and analytics providers.

Advertising partners

Including those that may collect information on our Site through cookies and other automated technologies, including for the interest-based advertising purposes. We do not share your sensitive personal data with advertising partners.

Professional advisors

Such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services they render to us.

Legal authorities

Including law enforcement, government authorities, and private parties we believe in good faith to be necessary or appropriate to comply with the law or legal process. You may also be interested in knowing that WiSP may share de-identified information with law enforcement, government authorities, and/or private parties (such as harm reduction organizations) to further WiSP’s mission of promoting safe consumption.

Business transferees

Such as acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, WiSP or our subsidiaries or affiliates (including, in connection with a bankruptcy or similar proceedings).

Affiliates or subsidiaries of WiSP.

We may engage in intra-company transfers of personal data.

We also reserve the right to disclose personal data under certain specific circumstances, including when we have your express consent to do so; when it is reasonably necessary for our legitimate interests in conducting our business, such as in the event a merger, acquisition, or sale; to protect WiSP’s legal rights and property; and to comply with valid legal requirements.

5.2 Sale of personal data

WiSP does not sell or rent your personal data. As we explain in this Privacy Policy, we use cookies and other tracking technologies to analyze Site and App traffic and use, and to facilitate advertising. To limit use of cookies and other tracking technologies, please review the instructions provided in the “Online tracking opt-outs” section. 

6. Legal frameworks for international transfers

WiSP is a global company with servers around the world, and your personal data may at times be processed on servers located outside of the country where you live. Although data protection laws vary among countries, regardless of where your personal data is processed, we apply the same protections described in this Policy. The controller of your personal information is WISP USA, Inc., which is a U.S.-based entity. As explained herein, WiSP may transfer personal data to processors or affiliates located in other jurisdictions, and will do so in compliance with applicable laws governing the international transfer of personal data. 

7. Safeguarding your data

WiSP uses technical and organizational safeguards to keep your data safe and secure. When appropriate, these safeguards include measures such as anonymization or pseudonymization of personal data and the use of encryption to protect the data we process.

Online services that we provide via our Site, App, and Devices protect your personal data in-transit using encryption and other security measures. However, no information system or method of electronic storage or transmission is 100% secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the online stores over networks that we do not control, including the Internet and wireless networks.

8. Use of cookies

This section  applies to your use of our Site and our App. Throughout our Site and App we may link to or embed content and features from other websites owned and operated by third parties who may also use cookies or similar technologies in accordance with their own separate privacy and cookie policies. We do not control these third-party websites and associated cookies. We encourage you to read the privacy notices of these sites to understand their privacy practices and your options. WiSP is not responsible for the content on other websites.

8.1 About cookies

A cookie is a small file that is placed onto your device (e.g., computer, smartphone, or other electronic device) that stores information when you visit a website. Pixel tags are a similar technology that consists of small images or snippets of code that allow the website to function and can help the website owners learn how you interact with websites and emails. We may also use web beacons, clear GIFS, Javascript, software development kits (SDKs), or other similar technologies on our Site and in our App. For the purposes of this Privacy Policy, we refer to all of these technologies as “cookies.”

8.2 Our use of cookies and other tracking technologies

We use cookies to collect and store analytics and other information when customers use our Site and our App, as well as for personalization and advertising purposes. The cookies we use include both first-party and third-party cookies.

WiSP uses cookies and related technologies on our Site to enhance your experience, improve our site, and to deliver content and ads that are relevant to you. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. We may use cookies to:

• Recognize you whenever you visit the Site;

• Support security and authentication features;

• Obtain information about your preferences and use of our Site and App;

• Carry out research and statistical analysis to help improve our content, products, and services, and to help us better understand our users’ requirements;

• Improve the speed and performance of our Site, App, and Services; and

• Make your online experience more enjoyable and efficient, and to keep our advertising relevant to your interests.

8.3. Types of Cookies

Cookies are typically classified as either “session cookies,” which do not stay on your device after you close your browser, or “persistent cookies,” which will usually remain on your device until you delete them from your cache or they expire. Sometimes cookies are placed by us (“first-party cookies”) and sometimes they are placed by others (“third-party cookies”).

The cookies that we place on your device may include:

Essential cookies

These cookies are essential for you to be able to navigate our Site and use its features. Without these cookies, the services you have asked for could not be provided.

Analytics cookies

These cookies collect information about how you use our Site or App, for example, which pages you go to most often. Much of the information collected by these cookies is aggregated and anonymous, and is only used to improve how our Site and App work.

Functionality cookies

These cookies enhance your experience using our Services, and allow us to remember the choices you make (such as your user name, language, last action, and search preferences) and to provide enhanced, more personal features.

Marketing cookies

Also known as advertising cookies, these cookies are used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement on our Site and help measure the effectiveness of the advertising campaign. In some cases, our partners may use cookies to provide us with information about your interactions with their services. These cookies remember that you have visited a website, and this information is shared with other organizations such as advertisers. All third-party cookies are subject to the third-party service’s policies.

8.4. Cookies we use

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8.5. Consent to use cookies

Depending on your jurisdiction, the first time you visit our Site a cookie notice may be displayed describing our use of cookies. If you use the Site after this notification has been displayed to you, we will assume that you consent to our use of cookies for the purposes described in this policy. By using our Site, you agree that we can place cookies and similar tracking technologies on your device. You have the ability to manage your cookies and similar tracking technologies preference.

8.6 Managing Cookies

Depending on your jurisdiction, you may be able to opt-out of all non-Essential cookies by clicking on the “Deny All” button on the cookie banner at the bottom of the Site homepage. In addition, your browser may give you the ability to control some types of cookies. If you want to customize the kinds of cookies you can control, you can change your browser settings so that certain types of cookies are not accepted. Please be aware that the cookie selections you make for this Site may override your browser or any adblocker settings.

If you turn off any cookies, please be aware that you may lose some of the functionality of this Site. For more information about cookies and how to disable them please check the following resource: https://allaboutcookies.org

You can opt-out of online behavioral advertising cookies and similar technologies by using the Digital Advertising Alliance’s Consumer Choice Tool available here, or if located in the European Union you can make your choices here. Please note you may continue to receive generic ads.

For more information about targeted advertisements and/or to learn how to opt out of advertising cookies, please visit the below independent associations. You can visit these independent associations’ websites to opt out of all cookies served by their members. These independent websites are not sponsored by or affiliated with WiSP.

• Network Advertising Initiative (NAI)

• Digital Advertising Alliance (DAA)

• European Interactive Digital Advertising Alliance (EDAA)

When opting out, a cookie will be set to let advertisers know not to use your data for targeted advertising purposes. You will still see advertisements, but they will not be tailored to your interests. If you opt-out of these targeted advertising cookies, your opt-out will be specific to the web browser or mobile device from which you accessed the opt-out. If you use multiple devices or browsers, you will need to opt-out each browser or device that you use.

9. Data retention

We will retain your personal data as long as your WiSP account is considered to be active or in accordance with applicable law and regulatory obligations.

10. Personal data of children

If you are under the age to consent to data sharing, as applicable based on your jurisdiction, please do not attempt to register for the Services or send any personal data about yourself to us. This includes children under the age of 13 in any jurisdiction. If you are under the age of 18 and are located in the United States, you may use the Services with your parents’ permission. If we learn that we have collected personal data from a child under the age to consent to data sharing, as applicable based on jurisdiction, we will delete that information as quickly as possible. If you believe that a child under the age to consent to data sharing, as applicable based on your jurisdiction, may have provided us personal data, please contact us at privacy@get-wisp.com.

11. Controller contact information

WISP USA, Inc. is the data controller of user personal data processed in connection with the Services. You can contact our Data Protection Officer at privacy@get-wisp.com.

12. Changes to this Privacy Policy

We reserve the right to update this Policy from time to time at our sole discretion. We strive to let you know about any material changes by notifying you on our Site or by sending you an email or push notification. If you keep using our Sites, Apps, Devices, or Services after a change to this Policy, your continued use means that you accept any such changes.