WhatsSet Privacy Notice

1. Introduction

Welcome to WhatsSet.

WhatsSet is a product of ARBProjects, a business operating in Jamaica.

We respect your privacy and are committed to handling your personal information responsibly, transparently and securely.

This Privacy Notice explains how we collect, use, store, share and protect personal information when you visit our public website at https://whatsset.com or submit an application to participate in the WhatsSet pilot programme.

ARBProjects is responsible for determining how and why personal information collected for these purposes is processed.

This Notice does not cover the operation of the WhatsSet application platform, which will be subject to separate privacy information.

2. Information We Collect

When you apply to participate in the WhatsSet pilot, we may collect:

• Your name.
• Your business name, if applicable.
• Your email address.
• Your WhatsApp telephone number, if voluntarily provided.
• The type of business you operate.
• How you currently manage appointments or customer orders.
• The main challenges you experience in managing your business.
• Your acknowledgement of the Privacy Notice and agreement to be contacted about your application.

We may also receive technical information necessary for the operation and security of the website and application form, such as information used to detect automated or abusive submissions.

We do not intentionally request sensitive personal information through the pilot application form. Please avoid including unnecessary personal or sensitive information in your responses.

3. How We Use Your Information

We collect and process your information for the following purposes:

• To receive and review applications for the WhatsSet pilot.
• To assess applicants' suitability for participation.
• To contact applicants about their application status.
• To communicate with selected participants about joining and participating in the pilot.
• To understand the operational needs of prospective WhatsSet users.
• To maintain appropriate records of applications and consent.
• To protect the application process against misuse, fraud and unauthorised activity.
• To comply with applicable legal obligations.

Applications are reviewed manually. Submitting an application does not guarantee selection or automatically create a WhatsSet account.

We will not automatically subscribe applicants to promotional mailing lists or use their contact details for unrelated marketing.

4. Legal Basis for Processing

We process personal information in accordance with applicable Jamaican data protection legislation, including the Data Protection Act, 2020.

Where applicable, processing is based on:

• Your informed consent when you voluntarily submit an application and agree to be contacted regarding the pilot.
• Processing reasonably necessary to review and administer your requested participation.
• Our legitimate interests in maintaining the security and integrity of the application process, where permitted by law.
• Compliance with applicable legal obligations.

You may withdraw your consent to pilot-related communications by contacting us at privacy@whatsset.com.

Withdrawal will not affect processing lawfully carried out before the withdrawal. Certain information may need to be retained where permitted or required by law.

5. Use of Tally

We use Tally, an online form service operated by Tally BV in Belgium, to collect and manage WhatsSet pilot applications.

ARBProjects determines the purposes for which applicant information is collected and used. Tally processes submitted information on our behalf in providing its form services.

According to Tally's published documentation:

• Form submission data is stored in Europe.
• Form data is encrypted in transit and at rest.
• Tally uses authorised service providers to support hosting, security and other operations.
• Information may be processed by service providers in other countries, including the United States, depending on the services used.

You can learn more about Tally's practices at https://tally.so/help/privacy-policy (opens in a new tab).

6. International Processing and Transfers

Although ARBProjects operates in Jamaica, some personal information collected through the pilot application may be stored or processed outside Jamaica.

This includes processing within the European Union through Tally and, where applicable, processing by its authorised service providers in other jurisdictions.

We take reasonable steps to ensure that international processing arrangements are consistent with applicable data protection requirements, including requirements concerning the protection of personal information transferred outside Jamaica.

7. Sharing and Disclosure

We do not sell applicants' personal information.

We may disclose information to:

• Service providers acting on our behalf, including Tally and its authorised subprocessors.
• Other service providers where reasonably necessary for secure website operation or pilot administration.
• Competent public authorities, regulators or courts where disclosure is required by applicable law or a valid legal process.

Access to personal information is restricted to authorised persons and service providers who require access for the purposes described in this Notice.

We do not disclose applicant information to unrelated businesses for their independent marketing purposes.

8. How Long We Keep Your Information

We retain personal information only for as long as reasonably necessary for the purposes described in this Notice, subject to applicable legal obligations.

Our intended retention periods are:

Unsuccessful applicants:

Application information will be deleted within six months after the pilot selection process closes.

Successful applicants:

Pilot application information will ordinarily be retained for up to 24 months after the pilot programme ends.

Withdrawn applications:

Where an applicant withdraws or requests deletion, we will assess and process the request promptly, subject to applicable legal requirements and any lawful reason for retaining limited information.

Where information is no longer required, we will delete it or otherwise securely dispose of it.

Deletion from service-provider systems and backups may be subject to their technical retention and deletion procedures.

Information subsequently collected through the WhatsSet application platform will be governed by the applicable platform privacy arrangements.

9. Security of Personal Information

We take reasonable technical and organisational measures to protect personal information against unauthorised access, disclosure, alteration, loss and misuse.

These measures include, where appropriate:

• Restricting access to authorised persons.
• Using reputable service providers with appropriate security safeguards.
• Using secure connections for transmitting information.
• Maintaining appropriate account-access controls.
• Reviewing and deleting information when it is no longer required.

No method of electronic transmission or storage can be guaranteed to be completely secure. However, we aim to apply safeguards appropriate to the nature and sensitivity of the information collected.

10. Your Privacy Rights

Under Jamaica's Data Protection Act, 2020, you may have rights concerning personal information held about you, subject to applicable legal conditions and exceptions.

These may include the right to:

• Be informed about how your personal information is processed.
• Request access to personal information held about you.
• Request correction of inaccurate or incomplete information.
• Request deletion where applicable.
• Withdraw consent where processing relies on consent.
• Object to or request restrictions on certain processing where applicable.
• Exercise other rights provided by applicable data protection legislation.

To exercise your rights, contact privacy@whatsset.com.

We may request reasonable information to verify your identity before responding to a request.

We will handle requests in accordance with applicable legal requirements.

11. Website Analytics and Cookies

The WhatsSet public marketing website does not currently use advertising trackers or third-party analytics services.

We do not currently use cookies for behavioural advertising or marketing profiling.

The website and services used to operate it may process limited technical information necessary for security, reliable delivery and normal operation.

The Tally application form, which is embedded on our application page at https://whatsset.com/apply/, is operated by Tally and may use technologies necessary for its functionality and security. To display the embedded form, the application page also loads a script provided by Tally. Tally's own privacy documentation provides further information about its practices.

If we introduce analytics or other tracking technologies in the future, we will review and update this Notice and implement any required consent arrangements before doing so.

12. Automated Decision-Making

WhatsSet pilot applications are reviewed manually.

We do not use solely automated decision-making or profiling to determine whether an applicant is selected for the pilot.

13. Complaints

If you have concerns about how your personal information is handled, please contact us at privacy@whatsset.com so that we can review your concern.

You may also raise a complaint with Jamaica's Office of the Information Commissioner, the authority responsible for overseeing compliance with the Data Protection Act, 2020.

Website: https://oic.gov.jm (opens in a new tab)

14. Changes to This Privacy Notice

We may update this Privacy Notice to reflect changes in our services, information-handling practices or applicable legal requirements.

The current version will be made available on our website, together with its effective date.

Where changes materially affect how personal information is processed, we will take appropriate steps to inform affected individuals where required.

15. Contact Us

For questions, privacy requests or concerns about this Notice, contact: