Privacy policy

Updated Version : 1st April 2026

Whisperwhite Co., Ltd. and its subsidiaries (collectively, the “Company”, “we”, “us”, or “our”) takes protection of personal data as an important matter in our businesses. This Privacy Policy (“Privacy Policy”) describes how we collect, use and disclose your personal data (“you” or “your”) in connection with the terms and conditions on the online platform, (“WHISPERWHITE”), tells you about data protection rights and how we use such personal data.

Your Personal Data is collected, used and disclosed by us because we have an existing contractual relationship with you. For example, you purchases our products or services or otherwise communicates with us in relation to WHISPERWHITE by accessing, using or viewing the applicable website or any of the services, functions or contents (including transmitting, caching or storing of any such personal data). For the purpose of this Privacy Policy, “Personal Data” means “any information about an individual, whether recorded in a material form or not and whether true or not, who can be identified from that data (whether directly or indirectly), or from that data and other data to which we have or are likely to have.”

We reserve the right to modify this Privacy Notice from time to time, so please review it frequently to see when this Privacy Notice was last revised. Any changes to this Privacy Notice will become effective when we post the revised Privacy Notice on our website or application. We will provide additional notice of significant updates where required by law to do so. In case any modification deprives your rights of sensitiv data in relation to this Privacy Policy, the Company will first obtain your consent, except as otherwise required by law. If you do not agree, please cease use of the relevant website(s) and/or service(s) and DO NOT provide any Personal Data to us.

The Personal Data We Collect From You
1.1. During the course of your use of WHISPERWHITE and its services, we may collect personal data about you, as follows:
(i) Identity data, such as your name, gender, profile picture, and date of birth;
(ii) Contact data, such as billing address, delivery address, email address and phone numbers;
(iii) Biometric data, such as voice files when you use our voice search function, and facial and other bodily features and voice of yourself and/or another person featured in your video when you upload videos onto WHISPERWHITE;
(iv) Account data, such as bank account details, bank statements, credit card details and payment details (such account data may also be collected directly by our affiliates and/or third party payment service providers);
(v) Transaction data, such as details about orders and payments, and other details of products and Services related to you;
(vi) Technical data, such as Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, international mobile equipment identity, device identifier, cookies (where applicable) and other information and technology on the devices you use to access WHISPERWHITE;
(vii) Profile data, such as your username and password, orders related to you, your interests, preferences, feedback and survey responses;
(viii) Usage data, such as information on how you use WHISPERWHITE, products and services or view any content on WHISPERWHITE, including the time spent on WHISPERWHITE, items and data searched for on WHISPERWHITE, access times and dates, as well as websites you were visiting before you came to WHISPERWHITE and other similar statistics;
(ix) Location data, such as when you capture and share your location with us in the form of photographs or videos and upload such content to WHISPERWHITE;
(x) Marketing and communications data, such as your preferences in receiving marketing from us and our third parties, your communication preferences and your chat, email or call history on WHISPERWHITE or with third party customer service providers; and
(xi) Additional information we may request you to submit for due diligence checks as required for identity verification (such as copies of government issued identification, e.g. passport, ID cards, etc.) or if we believe you are violating our Privacy Policy or our Terms of Use.
How We Receive Your Personal Data
2.1. During the course of your use of WHISPERWHITE and our provision of the services, we may receive personal data from you in the situations, as follows:
(a) When you browse our website (both mobile and web versions);
(b) When you create an account with us;
(c) When you apply for, subscribe to or otherwise use any of the services;
(d) When you make a transaction regarding the products available on WHISPERWHITE;
(e) When you activate or use any payment-related functions available on WHISPERWHITE or provided by our third party service providers;
(f) When you use any of the features, functions, or mini-apps on WHISPERWHITE;
(g) When you record any user-generated content which is uploaded on WHISPERWHITE;
(h) When you use the chat function on WHISPERWHITE;
(i) When you subscribe to our publications or marketing collaterals;
(j) When you enter a competition, promotion or survey;
(k) When you participate in any activity or campaign on WHISPERWHITE;
(l) When you log in to your account on WHISPERWHITE or otherwise interact with us via an external service or application, such as Facebook or Google;
(m) When any other user of WHISPERWHITE posts any comments on the content you have uploaded on WHISPERWHITE or when you post any comments on other users’ content uploaded to WHISPERWHITE;
(n) When a third party lodges a complaint against you or the content you have posted on WHISPERWHITE; and
(o) When you interact with us offline, including when you interact with our outsourced customer service agents.

2.2. We may collect personal data from you, third parties (including but not limited to agents, vendors, contractors, partners and any others who provide services to us, who collect your personal information and/or perform functions on our behalf, or with whom we collaborate, including but not limited to payment service providers, government sources of data, financial providers, credit bureaus, delivery, marketing and other service partners), our affiliates, or such data may be collected automatically when you use WHISPERWHITE or the services, as set out in this section. See also section 10 below on the collection of computer data.

2.3. Where we collect personal data from third parties and/or our affiliates, we will only collect your personal data, where permitted by law, for or in connection with the purposes for which those third parties or our affiliates are engaged, for the purposes of our collaboration with the third parties or affiliates, or for the requirement to carry out verification or due diligence checks. During the course of your use of WHISPERWHITE and our provision of the services, you agree that you have provided your consent (whether to us, the third party or our affiliates) to the transfer of your personal data from third parties and/or our affiliates to Whisperwhite Co., Ltd. for the purposes set out in this Privacy Policy or any other terms.

2.4. You must only submit personal data which is accurate and not misleading and you must keep it up to date and inform us of any changes to the personal data you have provided to us. We shall have the right to request for documentation and carry out the necessary checks to verify the personal data provided by you as part of our user verification processes or as required under law.

2.5. We will only be able to collect certain categories of personal data if you voluntarily provide the personal data to us or as otherwise provided for under this Privacy Policy. If you choose not to provide your personal data to us or subsequently withdraw your consent to our use of your personal data, we may not be able to provide you with certain features or functionality on the services or access to WHISPERWHITE.

2.6. If you provide personal data of any third party to us, you represent and warrant that you have obtained the necessary consent, license and permissions from that third party to share and transfer his/her personal data to us, and for us to collect, store, use and disclose that data in accordance with this Privacy Policy.
Use and Disclosure of Your Personal Data
3.1. The personal data we collect from you or via third parties may be used for certain purposes, as follows:
(i) Processing your order for products

To process orders you submit through WHISPERWHITE;
To deliver the products you have purchased through WHISPERWHITE. We may pass your personal information on to a third party (e.g. our logistics partner) or relevant regulatory authority (e.g. customs) in order to make delivery of the product to you;
To update you on the delivery of the products;
To provide customer support for your orders; and
To verify and carry out payment transactions (including any credit card payments, bank transfers, offline payments, remittances, or e-wallet transactions) in relation to payments related to you and/or services used by you. In order to verify and carry out such payment transactions, payment information, which may include personal data, will be transferred to third parties such as our payment service providers.

(ii) Providing Services

To facilitate your use of the services or access to WHISPERWHITE;
To administer your account (if any) with us;
To display your name, username or profile on WHISPERWHITE (including on any reviews you may post);
To facilitate the use of the mini-apps available on WHISPERWHITE and purchases made via these mini-apps; and
To respond to your queries, feedback, claims or disputes, whether directly or through our third party service providers.

(iii) Marketing and advertising

To provide you with information we think you may find useful or which you have requested from us (provided you have opted to receive such information);
To send you marketing or promotional information about our or third-party sellers’ products and services on our Platform from time to time (provided you have opted to receive such information);
To help us conduct marketing and advertising; and
To promote the services and use information that you give to us, such as user-generated content (including video content) that you can choose to upload or broadcast on WHISPERWHITE and will be accessible on the Internet and may be shared by the public (the latter of which is not within our control), as part of our advertising and marketing campaigns to promote WHISPERWHITE.
To ensure your consent is verifiable, we use a double opt-in process. After you sign up, we will send a confirmation email to the address you provided. You will not be added to our mailing list until you click the confirmation link in that email.

(iv) Legal and operational purposes

To ascertain your identity in connection with fraud detection purposes;
To compare information, and verify with third parties in order to ensure that the information is accurate;
To process any complaints, feedback, enforcement action and take-down requests in relation to any content you have uploaded to WHISPERWHITE;
To produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
To store, host, back up your personal data;
To prevent or investigate any actual or suspected violations of our Terms of Use, Privacy Policy, fraud, unlawful activity, omission or misconduct, whether relating to your use of our services or any other matter arising from your relationship with us;
To perform due diligence checks;
To comply with legal and regulatory requirements (including, where applicable, the display of your name, contact details and company details), including any law enforcement requests, in connection with any legal proceedings, or otherwise deemed necessary by us; and
Where necessary to prevent a threat to life, health or safety.

(v) Analytics, research, business and development

To understand your user experience with the services and WHISPERWHITE;
To improve the layout or content of the pages of WHISPERWHITE and customize them for users;
To identify visitors on WHISPERWHITE;
To conduct surveys, including carrying out research on our users’ demographics and behavior;
To improve our current technology (e.g. voice recognition tech, etc) via machine learning or other means;
To derive further attributes relating to you based on personal data provided by you (whether to us or third parties), in order to provide you with more targeted and/or relevant information;
To conduct data analysis, testing and research, monitoring and analyzing usage and activity trends;
To further develop our products and services; and
To know our buyers better.

(vi) Other

Any other purpose to which your consent has been obtained; and
To conduct automated decision-making processes in accordance with any of the above purposes.

9.1. We may share (or permit the sharing of) your personal data with and/or transfer your personal data to third parties and/or our affiliates for the above-mentioned purposes. These third parties and affiliates, which may be located inside or outside your jurisdiction, include but are not limited to:
(i) Service providers (such as agents, vendors, contractors and partners) in areas such as payment services, logistics and shipping, marketing, data analytics, market or consumer research, survey, social media, customer service, installation services, information technology and website hosting;
(ii) Their service providers and related companies; and
(iii) Other users of WHISPERWHITE or services.

9.2. In disclosing your personal data to them, we endeavour to ensure that the third parties and our affiliates keep your personal data secure from unauthorised access, collection, use, disclosure, processing or similar risks and retain your personal data only for as long as your personal data is needed to achieve the above-mentioned purposes.

9.3. We may also share personal data in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we satisfy the requirements of applicable data protection law when disclosing your personal data.

9.4. We may transfer or permit the transfer of your personal data outside of your jurisdiction for any of the purposes set out in this Privacy Policy. However, we will not transfer or permit any of your personal data to be transferred outside of such jurisdiction unless the transfer is in compliance with applicable laws.

9.5. We may share your personal data with our third party service providers or affiliates (e.g. payment service providers) in order for them to offer services to you other than those related to your use of WHISPERWHITE or our services. Your acceptance and use of the third party service provider’s or our affiliate’s services shall be subject to terms and conditions as may be agreed between you and the third party service provider or our affiliate. Upon your acceptance of the third party service provider’s or our affiliate’s service offering, the collection, use, disclosure, storage, transfer and processing of your data (including your personal data and any data disclosed by us to such third party service provider or affiliate) shall be subject to the applicable privacy policy of the third party service provider or our affiliate, which shall be the data controller of such data. You agree that any queries or complaints relating to your acceptance or use of the third party service provider’s or our affiliate’s services shall be directed to the party named in the applicable privacy policy.
Withdrawal of Consent to Continued Use, Disclosure, Storing and/or Processing of Personal Data
10.1. You may communicate the withdrawal of your consent to the continued use, disclosure, storing and/or processing of your personal data by contacting us using the contact details below, subject to the conditions and/or limitations imposed by applicable laws or regulations.

10.2. Please note that if you communicate your withdrawal of your consent to our use, disclosure, storing or processing of your personal data for the purposes and in the manner as stated above or exercise your other rights as available under applicable local laws, we may not be in a position to continue to provide the services to you or perform any contract we have with you, and we will not be liable in the event that we do not continue to provide the Services to, or perform our contract with you. Our legal rights and remedies are expressly reserved in such an event.

10.3. You may unsubscribe from receiving marketing information at any time in our mobile application settings or by using the unsubscribe function within the electronic marketing material. We may use your contact information to send newsletters from us and from our related companies.
Updating Your Personal Data
11.1. It is important that the personal data you provide to us is accurate and complete for you to continue using WHISPERWHITE and for us to provide the services. You are responsible for informing us of changes to your personal data, or in the event you believe that the personal data we have about you is inaccurate, incomplete, misleading or out of date.

11.2. You can update your personal data anytime by accessing your account on WHISPERWHITE.

11.3. We take steps to share the updates to your personal data with third parties and our affiliates with whom we have shared your personal data if your personal data is still necessary for the above-stated purposes.
Accessing and Correcting Your Personal Data
12.1. You may request information about your personal data which we have collected, or enquire about the ways in which your personal data may have been used, disclosed, stored or processed by us via the personal account information setting on WHISPERWHITE or by contacting us using the contact details below. You may also request correction of any error or omission in your personal data which we have collected in the same way. In order to facilitate processing of your request, it may be necessary for us to request further information relating to your request. Where permissible under law, we may refuse such correction requests if deemed vexatious or unreasonable.

12.2. Where permitted by applicable data protection laws, we reserve the right to charge a reasonable administrative fee for retrieving your personal data records. If so, we will inform you of the fee before processing your request.
Security of Your Personal Data
13.1. To safeguard your personal data from unauthorised access, collection, use, disclosure, processing, copying, modification, disposal, loss, misuse, modification or similar risks, we have introduced appropriate administrative, physical and technical measures such as:
(a) Restricting access to personal data to individuals who require access;
(b) Maintaining technology products to prevent unauthorised computer access;
(c) Using encryption technology when processing your financial details; and/or
(d) implementing other security measures as required by applicable law.

13.2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
Customer Data Retention & AnonymisationTo ensure the security of our community and remain compliant with the Personal Data Protection Act (PDPA), Whisperwhite Co., Ltd. maintains a proactive data minimisation policy. We do not retain personal identifiable information (PII) longer than is necessary for our operational and legal requirements.

14.1. We implement a scheduled data review and erasure process for inactive accounts. Personal data is typically retained for a period of 24 to 30 months (2 to 2.5 years) following your last recorded purchase or account activity.

14.2. Twice per year, we review our database and action the following for accounts that have remained inactive for longer than 24 months:

(a) Accounts with No Purchase History: These accounts, including all associated personal data (Name, Email, saved Addresses), will be deleted in full.
(b) Accounts with Purchase History: To comply with Thai Tax and Accounting regulations (which require a 10-year record of financial transactions), your personal identity will be anonymised. While the transaction details (items purchased and amount) remain in our financial records, they will no longer be associated with your name, email, or specific address.
Minors
15.1. Whisperwhite Co., Ltd. does not sell products to minors (which is to be determined based on the applicable law), nor does it intend to provide any of the services or the use of WHISPERWHITE to minors. We do not knowingly collect any personal data relating to minors.

15.2. You hereby confirm and warrant that you are above the age of minority and you are capable of understanding and accepting the terms of this Privacy Policy. If you are a minor, you may use WHISPERWHITE only with the involvement of a parent or legal guardian.

15.3. As a parent or legal guardian, please do not allow minors under your care to submit personal data to our website. In the event that such personal data of a minor is disclosed to Whisperwhite, you hereby consent to the processing of the minor’s personal data and accept and agree to be bound by this Privacy Policy and take responsibility for his or her actions.

15.4. We will not be responsible for any unauthorised use of the Services on WHISPERWHITE by yourself, users who act on your behalf or any unauthorised users. It is your responsibility to make your own informed decisions about the use of the Services on WHISPERWHITE and take necessary steps to prevent any misuse of the Services on WHISPERWHITE.
Collection of Computer Data
16.1. We or our authorised service providers may use cookies, web beacons, and other similar technologies in connection with your use of the Services or access of WHISPERWHITE.

16.2. When you visit WHISPERWHITE through your computer, mobile device, or any other device with Internet connectivity, our company servers will automatically record data that your browser sends whenever you visit a website, such as the technical data and usage data outlined in Section 2 above.

16.3. This data is collected for analysis and evaluation in order to help us improve our website and the services and products we provide, as well as to help us to personalise the content to match your preferred interests more quickly. The data is also collected to make the Services and WHISPERWHITE more convenient and useful to you, and to provide more relevant advertising related to market products, services and features to you.

16.4. Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. They allow us to recognise a particular device or browser. Web beacons are small graphic images that may be included on our Services and WHISPERWHITE. They allow us to count users who have viewed these pages so that we can better understand your preference and interests.

16.5. You may be able to manage and delete cookies through your browser or device settings. However, certain cookies are required to enable core functionality (such as adding items to your shopping basket), so please note that changing and deleting cookies may affect the functionality available on WHISPERWHITE or through our Services.
Contact Us
For any inquiries regarding our privacy policy, please send an email to info@whisperwhite.co
Governing Law
This Policy is governed by the laws of Thailand. You agree to submit to the exclusive jurisdiction of the Courts of Thailand in any dispute relating to this Privacy Policy.

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