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Last Updated: July 15, 2024
Summary of changes since last update (February 7, 2023 version):
This Privacy Policy (“Privacy Policy”) applies to you and anyone who uses Whoop Connect LLC d/b/a Whoop Connect (“Whoop Connect,” “we,” “us,” or “our”) Devices, Products, or Services (collectively, “Services”) under your account, except where we identify for you that separate terms and conditions apply. You are responsible for making sure all users under your account understand and agree to this Policy. You are responsible for making sure all users under your account understand and agree to this Policy.
Please take a moment to review the full terms of our Privacy Policy below, because by continuing to access or use our Services you accept and agree to be bound by all terms of the Privacy Policy. If you do not agree with any portion of it, then you must not access or use our Services. We may change this Privacy Policy from time to time, so check this policy regularly for updates.
This Privacy Policy is part of the Terms and Conditions and Agreement to Arbitrate Disputes and Judge or Jury Trial Waiver (“Terms and Conditions”) governing the use of our Services, https://www.whoopconnect.com/acp-terms-conditions/. To the extent that any provision or clause in our Terms and Conditions conflicts with any provision or clause in this Privacy Policy or a specific service plan offer, the terms of those more specific documents will govern.
“Call Detail Information” means any information that pertains to the transmission of specific telephone calls, including, for outbound calls, the number called, and the time, location, or duration of any call and, for inbound calls, the number from which the call was placed, and the time, location, or duration of any call.
“Device” means any phone, smartphone, tablet, accessory, or other device provided or sold to you by Whoop Connect or that you activate or use with our Services.
“Geolocation Data” means any data that is derived from a device and that is used or intended to be used to locate a consumer within a geographic area.
“Precise Geolocation” means any data that is derived from a device and that is used or intended to be used to locate a consumer within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet, except as prescribed by law or regulation.
“Personal Information” is information that identifies you or is reasonably capable of being associated with or linked, directly or indirectly, with you or your household. It does not include aggregate, de-identified, and/or anonymous information that is not reasonably capable of being associated with or linked, directly or indirectly, with you or your household.
“Services” means voice telephony (“talk”), text messaging (“text”), broadband Internet access services (“data”), and any other services provided to you by Whoop Connect, services and devices subject to Affordable Connectivity Program discounts, and prepaid wireless service.
“Underlying Carrier” means the wireless provider whose facilities we use to provide you wireless Services.
Depending on how you interact with us or our Services, we may collect the following categories of Personal Information from or about you, including, for example:
We may obtain Personal Information about you in the following ways:
We may combine the various types of Personal Information we receive from or about you, including information you provide to us, information we automatically collect, and information from other sources, and use it as described in this Privacy Policy.
Except as otherwise prohibited by law or regulation, and subject to applicable instructions from you to us, we may use your Personal Information for a variety of business and commercial purposes, including for:
We may use your Personal Information as otherwise disclosed and explained to you at the point of collection and with your consent, where necessary.
Except as otherwise prohibited by law or regulation, and subject to applicable instructions from you to us, we may share or allow access to your Personal Information for a variety of business and commercial purposes, including, for example:
We do not and will not sell or knowingly allow third parties unauthorized access to your Personal Information.
When using our Services, you may choose to install, access, or use services offered by third parties, such as websites, applications, and the networks of other carriers (such as when you are roaming). Please also refer to the Acceptable Use Policy inside our Terms and Conditions, available at https://www.whoopconnect.com/acp-terms-conditions/. In some cases, our Services may have links to websites operated by third parties, plugins for social media services, or third-party advertisements.
When you interact with third-party services, you may be consenting to those third parties accessing, collecting, using, or disclosing your Personal Information through our Services or directing us to share or allow access to your Personal Information by those third parties, such as your IP address, browsing activity, or location information. Those services operate independently of our Services, and your Personal Information will be governed by their terms and conditions, including their privacy policies, not this Privacy Policy. We encourage you to review the privacy policies of any third-party services that you use to better understand their privacy practices. You may be able to restrict or disable the use and disclosure of certain information, such as your location information, using settings available on your Device or through the third-party services.
Customer Proprietary Network Information (CPNI) is information made available to us solely by virtue of our relationship with you that relates to the type, quantity, destination, technical configuration, geolocation data, and amount of use of the telecommunications services you purchase from us, as well as information related to the billing for those services.
CPNI does not include subscriber list information such as name, postal address, or telephone number. Under federal law, you have the right, and we have the duty, to protect the confidentiality of your CPNI. When we share your CPNI with our service providers or contractors, we require them to take reasonable measures to protect the confidentiality of that information.
We are permitted to use or disclose your CPNI for certain purposes without further notice or consent from you, including: to provide you with our Services; to market service offerings to you related to the services you purchase; to protect us, you, other subscribers, and other carriers from fraud, abuse, or unlawful use of the Services; and in an aggregate form. We also may use your CPNI, or share it with affiliates and third-party agents, for the purpose of offering you communications-related products and services, packages, discounts, and promotions that may be different from the types of services you have already purchased.
You have the right to opt out of use of your CPNI for marketing purposes and can submit an opt-out request by contacting us at www.whoopconnect.com or 1-888-200-1076. Opting out will not affect our provision of Services to you or our use of your CPNI for permitted purposes. If you choose to opt-out, your choice is valid until you choose to opt in. You may also contact us to correct your CPNI or request that we disclose your CPNI to you.
We will not disclose your CPNI except when provided with your password, and we may implement other authentication measures. If you do not provide a password, we may not release your CPNI to you except by sending it to your address of record or by calling you at your telephone number of record. Be sure to use a strong password with our Services and not one you use for other services. We may disclose your CPNI to any “authorized user” that you have designated to us in writing or to any person who is able to provide us with your password.
Google Analytics and Google AdWords. We may use Google Analytics on our Sites to help us analyze traffic and improve services. For more information on Google Analytics’ processing of Personal Information, please see http://www.google.com/policies/privacy/partners/. You may opt-out of the use of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Our Sites also use the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. This could be in the form of an advertisement on the Google search results page or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to our Sites. Any data we collect will be used in accordance with this Privacy Policy, and Google is responsible to abide by its own privacy policy. You can set your preferences for how Google advertises to you using the Google Ad Preferences page: https://adssettings.google.com.
You have certain choices and consent options related to the use and disclosure of your Personal Information for advertising purposes. Exercising these choices and options will not affect our provision of Services to you. Please note that these choices and options may not prevent you from receiving all advertising; you may continue to receive generic advertising from us or interest-based advertising from third parties, depending on how they operate.
Interest-Based Advertising. You have choices and options concerning interest-based advertising on our Services or across other websites and online services as follows:
Marketing Communications. In accordance with our Terms and Conditions, you provide consent for us to contact you via email, voice call or text, including manual, autodialed, and prerecorded calls and texts. You also provide consent for us to use CPNI for marketing purposes, as described in the Terms and Conditions. You may limit or revoke these authorizations as follows:
Your instructions to opt-out from these communications will be processed as soon as reasonably practicable. Please note that exercising a marketing opt-out will not affect the services you receive and will not affect Whoop Connect’s right to contact you about the services to which you subscribe, including notifications regarding compliance obligations related to those services (e.g., non-usage, de-enrollment, and collection notices).
Do Not Track. Because Do Not Track (“DNT”) and similar signals do not yet operate according to common, industry-accepted standards, our Services may not respond to DNT signals.
We maintain reasonable physical, technical, and procedural safeguards to help protect against loss, misuse, or unauthorized access, disclosure, alteration, or destruction of your Personal Information. We only retain your Personal Information for as long as reasonably necessary to fulfill the purposes for which we collected it, including for any legal, accounting, or reporting purposes, as well as to resolve disputes and enforce our agreements.
We will keep your Personal Information as long as necessary to provide your Services, or as otherwise required by federal or state law, subpoena, or court order.
FCC regulations require us to keep:
The Personal Information we collect from or about you is stored on servers which we take commercially reasonable efforts to secure in the United States, subject to the laws of the United States. Electronic access to the databases and physical access to the servers on which this Personal Information is stored are restricted to those employees, agents, contractors, service providers, and other third parties who have a business need for such access. They will only access and use your Personal Information based on our instructions and they are required to keep your Personal Information confidential. While we take reasonable steps to help ensure the integrity and security of our network and servers, we cannot guarantee their security, nor can we guarantee that your communications and information will not be intercepted while being transmitted over our underlying carrier’s network or the Internet.
Our Services are solely intended for individuals located within the United States (“U.S.”) and its territories and are subject to U.S. law. If you are located outside of the United States and its territories, please do not use the Services.
We may transfer the Personal Information we collect about you to countries other than the country in which the information was originally collected, for the purposes outlined in the How We Share or Allow Access to Your Personal Information section above. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Policy.
Our Services are not directed toward children, and we do not knowingly collect Personal Information from children under the age of 13 (or under the age of 16 in California).
While you may have supplied information about children under age 13 (or age 16 in California), such as school enrollment or school breakfast/lunch program documentation to qualify for the Affordable Connectivity Program, we do not control or possess that information; that information is held and controlled by the Universal Service Administrative Company (USAC).
If you are a minor, please do not provide us any Personal Information or use or access the Services without receiving your parent’s or guardian’s permission. If we learn that we have collected any Personal Information from a child under the age of 13 (or under the age of 16 in California), we will take steps to delete the information as soon as possible. If you believe that we might have any Personal Information from a child under 13 (or under the age of 16 in California), or if you are a parent or guardian of a child under 13 (or under the age of 16 in California) that has provided us with Personal Information without your consent, please contact us via one of the methods in the Our Contact Information section below to request deletion of the child’s information.
Whoop Connect is not subject to the defined scope of many state privacy laws, such as the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”) or the Connecticut Data Privacy Act (“CDPA”), and therefore the specific rights and obligations identified in these laws do not currently apply to Whoop Connect. However, residents of these states may refer to these Privacy Policy provisions regarding our current data practices and may contact us regarding data inquiries or further information requests via the Our Contact Information section below. We also recognize that privacy laws continue to evolve rapidly, so we are undertaking reasonable means to monitor developments in these laws and update our polices accordingly.
Individuals residing in California on a permanent basis (California residents) have certain rights described below.
Under California’s “Shine the Light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of Personal Information, such as name, e-mail, mailing address, and type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties.
To request this information, please contact us at customersupport@whoopconnect.com or 1-888-200-1076.
This section applies only to California residents to the extent Whoop Connect is subject to the California Consumer Privacy Act (“CCPA”) and any effective amendments thereto. If you would like to learn whether Whoop Connect is subject to the requirements of the CCPA, you may contact us via the Our Contact Information section below.
This section provides additional information for California residents under the CCPA and any effective amendments thereto. The terms used in this section have the same meaning as those used in CCPA. This section does not apply to information that is not considered “Personal Information” under CCPA such as anonymous, deidentified, aggregated, or public information. The CCPA defines these terms as:
“Aggregate consumer information” means information that relates to a group or category of consumers, from which individual consumer identities have been removed, that is not linked or reasonably linkable to any consumer or household, including via a device. “Aggregate consumer information” does not mean one or more individual consumer records that have been deidentified.
“Deidentified” means information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular consumer, provided that a business that uses deidentified information:
“Personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following:
“Personal information” does not include publicly available information. For these purposes, “publicly available” means information that is lawfully made available from federal, state, or local government records, if any conditions associated with such information. “Publicly available” does not mean biometric information collected by a business about a consumer without the consumer’s knowledge. Information is not “publicly available” if that data is used for a purpose that is not compatible with the purpose for which the data is maintained and made available in the government records or for which it is publicly maintained. “Publicly available” does not include consumer information that is deidentified or aggregate consumer information.
“Sell,” “selling,” “sale,” or “sold,” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.
The CCPA states that a business does not sell personal information when:
Personal Information Notices. For purposes of compliance with the CCPA, in addition to other details described in this Privacy Policy, we provide the following notices:
We only retain your Personal Information for as long as reasonably necessary to fulfill the purposes for which we collected it, including for any legal, accounting, or reporting purposes, as well as to resolve disputes and enforce our agreements. We outline specific retention periods in the How We Store, Retain, Protect Personal Information We Collect About You, and How Long We Keep Your Personal Information section above.
We use (and used during the 12-month period prior to the effective date of this Privacy Policy) your Personal Information for the business and commercial purposes described in the How We Use Personal Information We Collect About You and How We Share or Allow Access to Your Personal Information sections above.
We note that under the CCPA, use of your Personal Information for these purposes is not subject to consumer’s Right to Delete, as described below and under California law.
We do not sell or share your Personal Information in exchange for monetary consideration.
However, the definitions of Personal Information, ‘share,’ and ‘sale’ under CCPA are broad. The CCPA defines “sharing” as “communicating orally, in writing, or by electronic or other means, a consumer’s personal information” to “a third party for cross-context behavioral advertising, whether or not for money or other valuable consideration”. We may share your Personal Information with a third party to help serve personalized content or ads that may be more relevant to your interests, and to perform other advertising-related services such as enabling our partners to serve such personalized content.
We do not knowingly sell or share personal information related to children under 16 years of age.
During the 12-month period prior to the effective date of this Privacy Policy, we have shared the following categories of Personal Information as follows:
| Category of Personal Information that May Be Shared | Third Parties with Which Personal Information May Be Shared | Purpose for Sharing Personal Information |
|---|---|---|
|
Identifiers, Internet or Other Similar Network Activity We shared device identifiers and internet and electronic network activity to facilitate online advertising. This means that a unique, resettable number that identifies your device was linked to online activity and shared with others who use that data for advertising and analytics purposes (like advertising networks, data analytics providers, and social media platforms). |
Third-party advertising companies that collect information about your visit to our Site and apps using cookies and other web technologies
Third-party advertising and social media companies to help them better target our advertising on their sites and apps or display our ads to other potential customers using interest segments they create from your activities across non-affiliated sites and apps. |
Targeted advertising/Cross contextual advertising |
We do not use or disclose sensitive personal information about you except as necessary to provide you with our Services, including processing and fulfilling orders and verifying your information, to prevent fraudulent or illegal actions, and for other purposes that are not for the purpose of inferring characteristics about you.
For purposes of this Section, “sensitive personal information” is defined as:
Personal information that reveals:
California Consumer Privacy Rights
You have the right to request the following about the Personal Information we have collected about you in the past 12 months:
To submit a request under your Right to Know, contact us using the information provided below in Exercising Your CCPA Rights. Please note that under California Law, that we are only required to respond to such requests from you twice in a twelve-month period.
Right to Correct Inaccurate Information
Beginning on January 1, 2023, you will have the right to correct inaccuracies in your Personal Information that we have collected, subject to exceptions within the CCPA.
To submit a request under your Right to Correct, contact us using the information provided below in Exercising Your CCPA Rights.
Right to Delete
You have the right to request the deletion of your Personal Information collected or maintained by us, subject to limitations established by federal law, including federal subsidy program enrollment and verification data.
Right to Opt-Out: You have the right to opt-out of the sale or sharing of Personal Information as described in Sale and Sharing of Personal Information above.
Right to Limit Use and Disclosure of Sensitive Personal Information: You may request specific limitations on further sharing, use, or disclosure of your Sensitive Personal Information that is collected or processed for “the purpose of inferring characteristics about a consumer.” However, as described in Use and Disclosure of Sensitive Personal Information above, we do not collect or process Sensitive Personal Information for this purpose.
To opt out of the sale or sharing of your personal information or otherwise take advantage of the foregoing rights, please visit and complete our Do Not Sell or Share My Personal Information/Data Request Form or contact us at:
General Process If you submit a request to access, correct, or delete Personal Information, we will need to verify your identity and confirm your request before processing it. When you make such a request, you can expect the following:
Denials In certain cases, a request to access, correct, or delete may be denied. For example, if we cannot verify your identity, the law requires that we maintain the information, or if we need the information for internal purposes such as providing Services or completing an order.
We may also deny a request for deletion if it is necessary for us or a service provider or contractor to maintain your Personal Information in order to:
If we deny any of your requests, we will explain why we denied it. If there is a portion of your request that we can comply with, for example deleting some of the requested information, then we will do so.
You have a right not to receive discriminatory treatment by us for exercising any of your privacy rights conferred by the CCPA. We will not discriminate against any California consumer because such person exercised any of the consumer’s rights under CCPA, including, but not limited to:
We may, however, charge a different price or rate, or provide a different level or quality of goods or services, if that difference is related to the value provided by your data.
You may designate an authorized agent to make a request under the CCPA on your behalf, using the contact information above. Such requests will still undergo a verification process, and we will deny requests from agents who do not submit proof of authorization from you. To verify that an authorized agent has authority to act for you, we may require a copy of a power of attorney or require that you provide the authorized agent with written permission and verify your own identity with us.
We comply with applicable requirements of the Nevada privacy law (Nevada Revised Statutes Chapter 603A), which in some instances provides Nevada residents with choices regarding how we use and share your personal information.
Nevada Personal Information (“Nevada PI”) includes personally identifiable information about a Nevada consumer collected online, such as an identifier that allows the specific individual to be contacted. Nevada PI also includes any other information about a Nevada consumer collected online that can be combined with an identifier to identify the specific individual.
We may collect your telephone number in addition to the categories information we outline in the Types of Personal Information We Collect About You section above (which include the Nevada PI categories of first and last name; physical address; email address; and username).
We may share such Personal Information with categories of third parties including federal and state regulators, subsidy program administrators, compliance and service support entities, and marketing entities.
Unaffiliated third parties outside of our control may collect covered information about your online activities over time and across different Internet websites or online services (via , e.g., “cookies”) when you use our Services.
You have the right to request that we not sell your Personal Information. Although we do not currently sell Personal Information, you may submit a request directing us to not sell Personal Information if our practices change in the future. To exercise this right, you may contact us customersupport@whoopconnect.com or at 1-888-200-1076.
We reserve the right to modify this Privacy Policy at any time. When we do, we will post the changes on this page. We will give you notice of any materially adverse changes to this privacy policy and may give you notice of all other changes but reserve the right to make such modifications immediately if required. It is your responsibility to regularly check this page to determine if there have been changes to the Privacy Policy and to review such changes.
The most current version of this Privacy Policy can be viewed by visiting our website and clicking on “Privacy Policy” located at the bottom of the pages. Any changes will take effect immediately. The effective date of this Privacy Policy is stated below. Continued access or use of our Services following the effective date of any changes shall indicate your acceptance of such changes. If you do not agree to the modified provisions of this Privacy Policy, you must discontinue your access and use of the Services.
If you have any questions or concerns about this Privacy Policy or how we treat your Personal Information, please contact us using the following information:
Email: customersupport@whoopconnect.com
Phone: 1-888-200-1076 or 611 from your Whoop Connect Device during normal business hours: Sunday to Saturday from 9 AM to 9 PM EST.
You are enroll with us as a child. So you cannot do new enrollment.