Privacy Policy

1. Who we are

Whispera AI is operated by Comedy App Ltd. (company registered in the United Kingdom). In this policy, "Whispera AI", "we", "us" refers to Comedy App Ltd.

Controller contact details

Comedy App Ltd.
11 Mossfield, Cobham, KT11 1DF, United Kingdom
Email: [email protected]

If you have questions about this policy or want to exercise your rights, contact us using the details above.

2. Scope

This Privacy Policy explains how we collect, use, share, and protect personal data when you:

• Visit our websites (including https://Whispera.AI)
• Create an account or use the Whispera AI platform
• Contact us (e.g., support, sales enquiries)
• Receive marketing communications from us

3. The personal data we collect

We may collect the following categories of personal data (depending on how you use Whispera AI):

3.1 Data you provide to us

• Contact details: name, email address, phone number, job title, company name, business address
• Account data: username, password (stored using secure hashing), user preferences and settings
• Support and communications: messages you send to us, feedback, survey responses
• Content you upload or process: files, media, metadata, rights/contract information, and other information you choose to submit through the platform
• Billing data: billing contact details and invoicing information

3.2 Data we collect automatically

• Usage and device data: IP address, device identifiers, browser type, operating system, pages/screens viewed, timestamps, referral URLs
• Log and security data: authentication logs, audit logs, error reports, security events
• Cookies and similar technologies: see Section 12

3.3 Data from third parties

Where relevant, we may receive personal data from:

• Payment providers (e.g., confirmation of payment status)
• Service providers supporting hosting, analytics, security, and customer support
• Business partners where you have asked them to introduce you to us

4. How we use your personal data

We use personal data to:

• Provide and operate the platform (account creation, authentication, feature delivery)
• Process uploads and deliver outputs you request through the platform
• Provide customer support and respond to enquiries
• Improve and secure our services (testing, troubleshooting, analytics, fraud prevention)
• Manage billing and payments
• Comply with legal obligations and respond to lawful requests
• Send service messages (e.g., security notices, policy updates)
• Send marketing communications (where permitted by law and/or with your consent)

5. Legal bases for processing

We rely on the following legal bases, depending on the activity:

• Contract: to provide the services you request and manage your account
• Legitimate interests: to improve and secure our services, prevent fraud, and communicate with business contacts (you can object—see Section 13)
• Legal obligation: to meet regulatory, tax, accounting, and other legal requirements
• Consent: for certain marketing communications and non-essential cookies (you can withdraw consent at any time)

6. When we act as controller vs processor

Controller: We are the controller for personal data relating to our website visitors, prospects, customers' account administration, billing, and our own marketing.

Processor: When you upload or process content through Whispera AI that contains personal data, we typically act as a processor on your behalf (and you are the controller). In those cases, our processing is governed by our customer agreement and any data processing addendum (DPA) in place.

7. Data Processing Addendum

If you use Whispera AI to process personal data as part of your business activities, you may be required to enter into a Data Processing Addendum (DPA) with us.

Our DPA (where applicable) sets out:

• The subject matter and duration of processing
• The nature and purpose of processing
• The types of personal data and categories of data subjects
• Our obligations as a processor (including confidentiality, security measures, sub-processor controls, and assistance with data subject requests)
• International transfer safeguards (where relevant)

If you would like a copy of our DPA, please contact [email protected].

8. Sharing your personal data

We do not sell your personal data.

We may share personal data with:

• Service providers (processors) who help us run our business (e.g., hosting, cloud infrastructure, analytics, customer support tooling, security monitoring, payment processing). They are permitted to process personal data only under our instructions and subject to confidentiality and security obligations.
• Professional advisers (e.g., lawyers, accountants, insurers) where necessary.
• Authorities and regulators where required by law or to protect rights, safety, and security.
• Corporate transactions: if we are involved in a merger, acquisition, financing, reorganisation, or sale of assets, we may share information as part of that process. Where required, we will provide notice.

9. International data transfers

Your personal data may be transferred to, stored in, or accessed from countries outside the UK and/or EEA.

Where we transfer personal data internationally, we use appropriate safeguards such as:

• UK International Data Transfer Agreement (IDTA) and/or EU Standard Contractual Clauses (SCCs) (as applicable)
• Additional technical and organisational measures where needed

10. Security

We use appropriate technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure, or destruction.

No method of transmission or storage is 100% secure. You are responsible for keeping your account credentials confidential.

11. Data retention

We keep personal data only for as long as necessary for the purposes described in this policy, including:

• While your account is active
• As needed to provide services and support
• As required to comply with legal, tax, accounting, and regulatory obligations
• To establish, exercise, or defend legal claims

We may retain and use aggregated or anonymised data for analytics and service improvement.

12. Cookies and similar technologies

We use cookies and similar technologies for:

• Strictly necessary functionality (e.g., login sessions, security)
• Performance and analytics (under applicable consent rules)

You can manage cookie preferences through your browser settings and (where available) our cookie banner/preferences tool.

13. Your rights

Depending on your location and the nature of the processing, you may have the right to:

• Access your personal data
• Rectify inaccurate personal data
• Erase your personal data
• Restrict processing
• Object to processing (including direct marketing)
• Data portability
• Withdraw consent at any time (where processing is based on consent)

Complaints: You also have the right to lodge a complaint with your supervisory authority. In the UK, this is the Information Commissioner's Office (ICO).

14. Children

Whispera AI is not intended for children and we do not knowingly collect personal data from children.

15. Changes to this policy

We may update this Privacy Policy from time to time. If changes are significant, we will provide notice via email and/or within the platform.

16. Contact us

For privacy questions or requests, contact:

Email: [email protected]
Mail: Comedy App Ltd., 11 Mossfield, Cobham, KT11 1DF, United Kingdom