WHATSWHAT PRIME

Privacy Policy

Last Updated: [Insert Date – 2026]

WhatsWhat Global Ltd ("Company", "we", "us", "our") is committed to protecting and respecting your privacy in accordance with:

• General Data Protection Regulation (EU) 2016/679 ("GDPR")
• Irish Data Protection Acts
• ePrivacy Regulations
• Applicable EU digital services laws

This Privacy Policy explains how we collect, use, store, and protect your personal data when you use the WhatsWhat Prime platform ("Platform").

1. Data Controller

The Data Controller is:

WhatsWhat Global Ltd
[Registered Address]
Ireland
Email: [Insert Email]

If you have questions about this policy, contact us at the above email.

2. What Personal Data We Collect

We may collect and process the following categories of personal data:

A. Identity Data

• Full name
• Business name
• Job title
• Company registration details

B. Contact Data

• Email address
• Telephone number
• Business address

C. Account Data

• Login credentials
• Subscription details
• Plan type
• Payment status

D. Payment Data

• Billing address
• Transaction history

(Note: We do not store full card details; payments are processed by secure third-party providers.)

E. Profile & Visibility Data

• Business descriptions
• Uploaded content
• Assessment inputs
• Visibility Assessment results
• Ladder positioning
• Marketplace listings

F. Technical Data

• IP address
• Browser type
• Device information
• Cookies and tracking data
• Platform usage behaviour

G. Communication Data

• Emails
• Support requests
• Interview recordings (if applicable)
• Call notes

3. Lawful Basis for Processing

We process personal data under one or more of the following lawful bases:

Contractual Necessity

To provide services under a signed agreement.

Legitimate Interests

To operate, improve, and secure the Platform.

Consent

For marketing emails, newsletters, and promotional communications.

Legal Obligation

To comply with tax, accounting, and regulatory requirements.

4. How We Use Personal Data

We use personal data to:

• Provide Visibility Assessment™ services
• Administer Visibility Ladder™ positioning
• Maintain Visibility Index™ records
• Process payments
• Manage subscriptions
• Deliver Marketplace services
• Send Visibility Marketplace Digest (where subscribed)
• Provide customer support
• Improve platform functionality
• Ensure governance compliance
• Detect fraud or misuse

We do not sell personal data.

5. Automated Processing & AI Systems

The Platform may use automated systems, including AI-assisted tools, to:

• Structure visibility analysis
• Process assessment inputs
• Generate positioning reports

These systems support decision-making but do not make legally binding automated decisions without human oversight.

Users may request human review of significant automated outcomes.

6. Prime Authority & Public Data

Certain information submitted to the Platform may be:

• Published in Prime Magazine
• Displayed in business profiles
• Recorded in the Visibility Index™

Only business-related data intended for public visibility is published.

Sensitive personal data is not intentionally processed.

7. Data Sharing

We may share data with:

• Payment processors
• Hosting providers
• Technical service providers
• Legal or regulatory authorities (if required)
• Licensed partners (where applicable and contractually controlled)

All third-party processors are bound by data protection agreements.

We do not sell personal data to third parties.

8. International Transfers

If personal data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards such as:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions
• Contractual data protection measures

9. Data Retention

We retain personal data:

• For the duration of contractual relationships
• For up to 6 years for tax and accounting purposes
• As necessary to defend legal claims
• As required under Irish law

Inactive accounts may be anonymised after reasonable retention periods.

10. Your Rights Under GDPR

You have the right to:

• Access your personal data
• Rectify inaccurate data
• Erase data ("Right to be Forgotten")
• Restrict processing
• Object to processing
• Data portability
• Withdraw consent at any time
• Request human intervention in automated decisions

Requests may be made to: [Insert Email]

We may require identity verification before fulfilling requests.

11. Cookies & Tracking

We use cookies and similar technologies to:

• Operate the Platform
• Analyse traffic
• Improve user experience
• Measure performance

Users can manage cookie preferences via browser settings.

A separate Cookie Policy provides full details.

12. Data Security

We implement appropriate technical and organisational measures including:

• Secure hosting
• Access controls
• Encrypted data transmission
• Role-based access
• Audit logging

However, no system can guarantee absolute security.

13. Marketplace Transactions

Marketplace transactions occur between users.

We process limited data necessary to facilitate platform functionality.

We are not responsible for misuse of personal data by third-party sellers.

14. Licensing & Partner Processing

Licensed partners may process data when administering Visibility Assessments.

Such partners operate under formal data processing and compliance agreements.

They are independently responsible for their own compliance.

15. Complaints

If you believe your data protection rights have been violated, you have the right to lodge a complaint with:

The Data Protection Commission (Ireland)
www.dataprotection.ie

We encourage you to contact us first so we can resolve concerns.

16. Changes to This Policy

We may update this Privacy Policy periodically.

Material changes will be notified on the Platform.

Continued use of the Platform indicates acceptance.