Policies for the treatment and protection of personal data


WHW Spa is a private company, domiciled in Chile and subject to Chilean laws. This document seeks to inform our users on the use of personal data that we could collect and process either through our systems and applications or that of our partners. Its purpose is to inform and publicize the procedures and means that we have arranged to protect the rights of the person about the information that concerns you.

Although our company is governed in this matter by the provisions of article 19 N ° 4 of the Political Constitution of the Republic and the Law 19.628, on the protection of private life, we have adjusted our processes to the requirements of the General Protection Regulation of the European Union (GDPR) and the COPPA (Children's Online Privacy Protection Act) of the United States.

Keep in mind that the right to data protection is recognized only with respect to natural persons, therefore if you. You are the representative of a legal person, this document does not apply to you.

If you are a client or user who uses our application, keep in mind that you declare that you have full legal capacity to enter into acts and contracts. If this is not the case, we ask you not to download the application or install it.

The contributing user is responsible for the legality associated with capturing images and videos. The user will be responsible for damages and losses that are caused to WHW Spa or to third parties on the occasion of claims that we may be the subject of such captures in the context of the use of our application and / or platform.

1.- What we do

Our company performs analysis of the mobility of people in cities and proposes an analytical model that allows improving them to do make our cities more sustainable.

We achieve this thanks to the fact that our users download the application and make videos of the areas through which they move and provide them to us. At that same moment we anonymize the information that could lead to the identity of the people who appear in the videos and we carry out analyzes regarding the type of transport and mobility behavior.

2.- Data processing that we carry out

We have personal data of our users or contributors: their identity and email. COMPANY will apply security measures in the creation of users, adopting double-entry authentication techniques. In the event of a security violation within the processing of personal data and that such violation may represent a risk to the rights and freedoms of the user, the person or area responsible will immediately report said event, in such a way that the interested party can take the corresponding precautions, in observance and in accordance with the contingency plan designed by THE COMPANY to attend to the security incidents that arise.

We do not process personal data of people who move through public or private places for which recordings are recorded. Therefore, our company does not process nominated personal data. In our processes, in the act of collecting information, the information is anonymised immediately. Therefore our systems do not carry out a data treatment different from that of data collection and dissociation, or anonymization. However, we offer people the possibility of exercising the right of access in order to verify that these processes have been carried out correctly.

The purpose for which we process information is the following:

  1. Analysis related to the segmentation and study of means of transport and mobility systems, in order to improve the transport system in efficiency and sustainability in a reference community.

  2. Information analysis through video analytics where the content related to the segmentation and study of means of transport and mobility is processed.

  3. Comply with information requirements of public and private entities in the workplace and social security, in the case of workers and contractors.

  4. Prepare reports of population behavior and mobility of people and their response to stimuli in the environment, either in open or closed spaces.

THE COMPANY will anonymize the faces and encrypt all the images that are processed through its application and / or platform, even for users who provide such data and content.

The information related to mobility videos is not nominated, therefore it is not subject to temporality rules in its storage. However, by applying the principle of minimization, we will endeavor to maintain it as long as necessary to fulfill the purpose stated above.

THE COMPANY will always keep a backup copy of all the content provided by users, without prejudice to the deletion of the content that each user makes in their personal account.

3. Your rights

In accordance with current regulations, the owner of the information has the following rights:

  1. Right of access, which consists of the possibility for the person to indicate the day and time in which it could be recorded and request us to register to verify their captured image. This right includes the possibility of receiving a copy of the video from the company on the day and time that the person presumably could have been captured. Keep in mind that for this we need the information of the day and time in which your image could have been captured, and it is not possible to respond to generic requirements.

  2. In the case of registered users, know, update and rectify their personal data according to what is in our records.

  3. Request information about the recipients of the information that concerns you and the purpose for which your data was processed.

  4. Request the cancellation or deletion of your personal data, in the event that your status as a user of the system ceases or that they lack a legal basis for their treatment.

4.- Responsible for data processing and communication channel

Our users or third parties who have questions regarding the data processing carried out by our company can direct their inquiries and exercise their rights through our responsible area, according to the following data:

Name of the person or area responsible: Customer Area Email: clientes@whw.cl

Please note that once your request is received, our company has two business days to reply.

5. Authorization to process personal data

Users, when registering and downloading our application, authorize the processing of their personal data, which is used for the sole purpose of managing their accounts in our services. After your first login, if it is a secure device, our system will save your data in such a way that when you re-enter through that device, you can access it through an easily accessible route, without the need to repeat persistent your username and password.

In the WHW user registration process, a box is made available to users that allows them to express their consent by means of an affirmative act. For these purposes, once the user has clicked on the box provided for that purpose, their expression of will will materialize freely, specifically, informed and unequivocally to accept the processing of their personal data. It will also be understood as a manifestation of will, in the sense just described, any statement or conduct made by the user that unequivocally indicates that they have accepted these privacy policies.

Regarding the people who may be captured by the videos provided, applying an anonymization procedure at the entrance, it is not appropriate to request this consent, without prejudice that through this policy the community is informed about the procedures and means that we use so that your rights are not affected by our activity.

6. Sensitive data processing.

WHW, does not allow the identification of a person or treat sensitive data. Our application is specially designed and implemented to anonymize or blur the images at the entrance.


7. Treatment of personal data of children and adolescents.

WHW captures images of people in motion and does not classify them as adults or children. We do not collect information on the identity of individuals. We do not collect information from children or adolescents. Our users are over 15 years old. We use mechanisms to verify the age of the people who download our application and become users.

8. Delivery of information by request of authority.

Keep in mind that WHW could be required by judicial or administrative authority to give access and deliver the videos that our contributing users give us, as well as the aggregated information to which they give rise, in addition to the results of our analyzes. Likewise, we could be required to know the identity of our contributing users, as well as the videos that they have been able to upload to our platform.


9. Validity.

This information treatment policy comes into effect as of August 19, 2020 and the databases will be valid for the period that the purpose of the treatment is maintained.

Any modification or change implemented to the information treatment policies will be duly informed to the users of our applications and platforms through their accounts. It is the responsibility of each user to review said changes, giving their express authorization at any time that is required.

10. Jurisdiction

Any difference or controversy that occurs between the parties due to the application, interpretation, duration, validity or execution of this contract, its annexes or any other cause will be submitted to the jurisdiction of the ordinary courts of justice, for which the parties set their domicile in the city of Santiago de Chile.

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