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Whirlwind EU Data Policy

Last Updated: May 28, 2025

We are committed to handling your information responsibly, respectfully, and in full compliance with the General Data Protection Regulation (GDPR).

This page explains how Whirlwind, owned and operated by Bearish FH INC, handles personal data for users located in the European Union, European Economic Area, and United Kingdom.

1. Who We Are

Bearish FH INC
95 3rd Street,
San Francisco CA 94013

Email: privacy@bearishfh.com

Data Controller: Bearish FH INC (USA)

2. Why We Collect Your Data

We collect and use data to:

  • Let you sign in and use the Whirlwind app
  • Save your reading progress and bookmarks
  • Show you books and audio content in your language
  • Improve the quality of stories through anonymous analytics
  • Fulfill legal and operational requirements

3. What We Collect

a. Account Information

  • Name and email address (from Apple or Google sign-in)
  • Authentication token (used to keep you logged in)

b. Reading Progress

  • Books and chapters read
  • Bookmark placement and streaks
  • Completion and performance stats

c. Anonymized Analytics

We track anonymous usage patterns (not tied to your name or email):

  • Book covers clicked
  • Time spent reading each page
  • Which books are finished or abandoned
  • Session length and behavior flow

All of this is collected to improve the reading experience and refine content delivery.

4. Your Rights Under the GDPR

You have the right to:

  • Access the data we have about you
  • Correct any inaccurate data
  • Delete your data ("right to be forgotten")
  • Object to how we process your data
  • Export your data ("data portability")
  • Withdraw consent at any time (where applicable)

To make a request, email: privacy@bearishfh.com
We will respond within 30 days.

5. Legal Basis for Processing

We process your personal data based on:

  • Contractual necessity (to provide the app/service)
  • Legitimate interests (to improve the experience, fix bugs, understand content performance)
  • Consent (where required, such as when collecting analytics or localization preferences)

6. International Data Transfers

Your data is stored on servers located in the United States. To ensure your privacy rights are respected:

  • We use Standard Contractual Clauses (SCCs) approved by the European Commission
  • We apply appropriate safeguards like encryption and restricted access

7. How Long We Keep Your Data

We keep your data only as long as needed to:

  • Provide the service
  • Comply with applicable laws

When you delete your account, your personal data is removed. Aggregated anonymous analytics may be retained for platform insights, but cannot be traced back to you.

8. Third Parties

We use a small number of GDPR-compliant service providers:

  • Apple / Google for authentication
  • PostHog for anonymous product analytics

These providers only receive the minimum data necessary to perform their services and are bound by data processing agreements.

9. Complaints

If you believe your data rights have been violated, you can contact your local Data Protection Authority (DPA). You also have the right to lodge a complaint directly with us at privacy@bearishfh.com

10. Contact

For any privacy-related questions or requests:

Bearish FH INC
95 3rd Street,
San Francisco CA 94013

📧 Email: privacy@whirlwind.com