Privacy policy

This privacy policy applies between you, the User of this Website or App and WhiteTown , the owner and provider of (a) the WhiteTown mobile application (the App), and (b) the website (the Website). White Town takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website. Please read this privacy policy carefully.

Definitions and interpretation
  • 01. In this privacy policy, the following definitions are used:
    • Data
      collectively all information that you submit to White Town via the App or Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
    • Cookies
      a small text file placed on your computer by this Website when you visit certain parts of the App or Website and/or when you use certain features of the App or Website. Details of the cookies used by this Website are set out in the clause below ( Cookies);
    • Data Protection Laws
      any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;
    • GDPR
      the General Data Protection Regulation (EU) 2016/679;
    • White Town
      White Town , a company incorporated in Slovakia.
    • UK and EU Cookie Law
      the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
    • User or you
      any third party that accesses the App or Website and is not either (i) employed by White Town and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to White Town and accessing the App or Website in connection with the provision of such services;
    • Website
      the Website that you are using,, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
    • App
      the mobile phone application you are using, on the Android or iOS operating system
  • 02. In this privacy policy, unless the context requires a different interpretation:
    • the singular includes the plural and vice versa;
    • references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
    • a reference to a person includes firms, companies, government entities, trusts and partnerships;
    • "including" is understood to mean "including without limitation";
    • reference to any statutory provision includes any modification or amendment of it;
    • the headings and sub-headings do not form part of this privacy policy.
Scope of this privacy policy
  • 03. This privacy policy applies only to the actions of White Town and Users with respect to this Website or App. It does not extend to any websites or apps that can be accessed from this Website or App including, but not limited to, any links we may provide to social media websites.
  • 04. For purposes of the applicable Data Protection Laws, White Town is the "data controller". This means that White Town determines the purposes for which, and the manner in which, your Data is processed.
Data collected
  • 05. We may collect the following Data, which includes personal Data, from you:
    • name;
    • contact Information such as email addresses and telephone numbers;
    • IP address (automatically collected);
    • web browser type and version (automatically collected);
    • mobile browser, device and version (automatically collected)
    • operating system (automatically collected);
    • a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);
    • photos, files and messages you share with other users;
    • your location for location based services (LBS);

    in each case, in accordance with this privacy policy.

How we collect Data
  • 06. We collect Data in the following ways:
    • when you contact us through the App or Website, by telephone, post, e-mail or through any other means
    • when you register with us and set up an account to receive our services
    • when you make payments to us, through our Website, App or otherwise
    • when you use our services
    • we automatically collect some information about your visit to the App or Website. This information helps us to make improvements to our content and navigation, and includes your IP address, the date, times and frequency with which you access the App or Website and the way you use and interact with its content.
    • we will collect your Data automatically via cookies, in line with the cookie settings on your browser.
Our use of Data
  • 07. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our App or Website. Specifically, Data may be used by us for the following reasons:
    • internal record keeping
    • improvement of our services
    • contact for market research purposes which may be done using email, telephone, mobile app or email. Such information may be used to customise or update the App or Website to you and we will never sell or share your personal information to other third parties for their marketing purposes
Who we share Data with
  • 08. We may share your Data with the following groups of people for the following reasons:
    • our employees, agents and/or professional advisors - to understand and improve our service via internal analysis and professional advice
    • third party service providers who provide services to us which require the processing of personal data - to help third party service providers in receipt of any shared data to perform functions on our behalf to help ensure services we provide via the App or Website run smoothly;
    • third party payment providers who process payments made over the App or Website - to enable third party payment providers to process user payments and refunds;
    • relevant authorities - to comply with national law and to facilitate the detection of crime;
Keeping Data secure
  • 09. We will use technical and organisational measures to safeguard your Data, for example:
    • access to your account is controlled with login credentials that are unique to your account.
    • we store your Data on secure servers.
    • payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology.
    • relevant authorities - to comply with national law and to facilitate the detection of crime;
  • 10. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address:
Data retention
  • 11. Unless a longer retention period is required by law, we will only hold your Data on our systems for 3 years or until you request that the Data be deleted, whichever is sooner.
  • 12. Even if we delete your Data, it may persist on backup or archival media where required for legal, tax or regulatory purposes.
  • 13. You have the following rights in relation to your Data:
    • Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
    • Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
    • Right to erase - the right to request that we delete or remove your Data from our systems.
    • Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
    • Right to data portability - the right to request that we move, copy or transfer your Data.
    • Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.
  • 14. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address:
Links to other websites
  • 15. Our Website and App may, from time to time, provide links to other websites or apps. We have no control over such websites or apps and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites and apps prior to using them. Changes of business ownership and control
  • 16. White Town may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of White Town . Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
  • 17. We may also disclose Data to a prospective purchaser of our business or any part of it.
  • 18. In the above instances, we will take steps with the aim of ensuring your privacy is protected.
  • 19. Our Website may place and access certain Cookies on your computer. White Town uses Cookies to improve your experience of using our App or Website and to improve our range of services. White Town has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
  • 20. All Cookies used by our Website are used in accordance with current EU Cookie Law.
  • 21. Before the App or Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling White Town to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the App or Website may not function fully or as intended.
  • 22. You can find a list of Cookies that we use in the Cookies Schedule.
  • 23. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
  • 24. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the App or Website more quickly and efficiently including, but not limited to, personalisation settings.
  • 25. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
  • 26. For more information generally on cookies, including how to disable them, please refer to You will also find details on how to delete cookies from your computer.
  • 27. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
  • 28. White Town reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the App or Website and you are deemed to have accepted the terms of the privacy policy on your first use of the App or Website following the alterations.