Privacy Policy


Effective Date: May 1, 2021

This Website (Site) is operated by WHITESPACE, LTD (Whitespace); materials on the Site are owned, for the most part, by WHITESPACE. The Site may also include materials owned by third parties and posted on the Site by virtue of a license, grant or some other form of agreement between the third party and WHITESPACE.

WHITESPACE has created this Site for Your permitted purposes. However, You are only authorized to access this Site or to review the materials contained in the Site (regardless of whether Your access or use is intended) if You agree to abide by all applicable laws, and to these Terms of Use which constitute an Agreement between You and WHITESPACE. Please read these Terms of Use carefully and save them. If You do not agree with them, You should leave this Site immediately. Any questions or comments regarding, or problems with, this Site should be sent to the Site Administrator at

WHITESPACE reserves the right to modify or amend these Terms of Use without notice at any time. It is therefore important that You read this page regularly to ensure You are updated as to any changes. If You become aware of misuse of this Site or any violations of the Terms of Use by any person, please contact the Site Administrator with Your concerns. 


All materials contained in this Site are protected by United States federal and international trademark and copyright laws and must only be used for permitted purposes. You may only view or download material from this Site for Your own use, and You must keep all copyright and other proprietary notices attached to the downloaded material.

The reproduction, duplication, distribution (including by way of email, facsimile or any other electronic means), publication, modification, copying or transmission of material from this Site is STRICTLY PROHIBITED unless You have obtained the prior written consent of WHITESPACE or unless it is expressly permitted by this Site. The material covered by this prohibition includes, but is not limited to, any text, graphics, logos, photographs, audio or video material or stills from audiovisual material available on this Site. The use of materials from this Site on any other Website or networked computer environment is similarly prohibited.

Requests for permission to reproduce or distribute materials found on this Site can be made by contacting WHITESPACE in writing at

You are also strictly prohibited, without the prior written consent of WHITESPACE, from creating works or materials that derive from or are based on the materials contained in this Site including by way of example and without limitation, fonts, icons, link buttons, wallpaper, desktop themes, on-line postcards and greeting cards and unlicensed merchandise. This prohibition applies regardless of whether the derivative materials are sold, bartered or given away.

The Site may provide You with the opportunity to upload or provide messages, ideas, feedback, comments or other content (“Content”). If the Site does provide You with such an opportunity, You understand and agree that WHITESPACE has the right in its sole discretion, but is not obligated to, monitor, edit, and remove any posted Content, and assumes no liability for any such Content. You warrant that You own or otherwise control all of the rights to such Content, that it is accurate, and that its use does not violate these terms and will not injure any person or entity. You further agree not to upload, post or otherwise make available Content that is protected by a third party’s copyright, trademark or other proprietary right without the express permission of the third-party owner of the copyright, trademark or other proprietary right. All persons or groups authorized to provide Content to the Site shall be solely liable for any damage resulting from any infringements on third party rights resulting from Your submission of such Content.

You agree that any Content that You submit shall be considered non-proprietary and non-confidential. WHITESPACE shall have no obligations of any kind with respect to any Content and shall be free to reproduce, use, disclose and/or distribute any Content for any purpose whatsoever, without limitation. You also agree that WHITESPACE shall be free to use any ideas, concepts or techniques embodied in the Content for any purpose whatsoever, including, but not limited to, producing, developing, and marketing news stories, shows, content of any kind, products or services incorporating such ideas, concepts, or techniques, without attribution. In addition, You hereby waive all moral rights You may have in any materials uploaded or sent to us by You. You must be 14 years of age to become an authorized provider of Content.

Linked Sites

You may create a hypertext link to this Site, provided that You do not represent in any way, expressly or by implication, that You have received the endorsement, sponsorship or support of this Site or WHITESPACE, or that You are related to, represent or are affiliated in any way with WHITESPACE, including its respective employees, agents, directors, officers and shareholders, or this Site.

If WHITESPACE has provided links or pointers to other Websites, no inference or assumption should be made and no representation should be implied that WHITESPACE is connected with, affiliated with, operates or controls these Websites, or is operated or controlled in any manner by these Websites or their owners.

WHITESPACE is not responsible for the content or practices of third-party Websites that may be linked to this Site. This Site may also be linked to other Websites operated by companies affiliated or connected with WHITESPACE. When visiting other Websites, however, You should refer to each such Website’s individual “Terms of Use” and not rely on this Agreement.

Disclaimer of Liability and Warranties

While WHITESPACE does its best to ensure the optimal performance of the Site, You agree that You use this Site and rely on material contained in this Site at Your own risk.

The Site, and all materials in this Site, are provided “as is” and, to the fullest extent permitted by law, are provided without warranties of any kind either express or implied. This means, without limitation, that WHITESPACE DOES NOT WARRANT that the Site is fit for any particular purpose; that the functions contained in the materials in the Site will be uninterrupted; that defects will be corrected; that the Site is free of viruses and other harmful components or that the Site is accurate, error free or reliable.

You acknowledge that WHITESPACE and third-party content providers, their parents and affiliates together with their respective employees, agents, directors, officers and shareholders, ARE NOT LIABLE for any delays, inaccuracies, failures, errors, omissions, interruptions, deletions, defects, viruses, communication line failures or for the theft, destruction, damage or unauthorized access to Your computer system or network.

You acknowledge that WHITESPACE is not liable for any defamatory, offensive or illegal conduct or material found in connection with this Site, including such conduct or material transmitted by any means by any other person.

You acknowledge that WHITESPACE and third-party content providers are not liable for any damages, including, without limitation, direct, incidental, special, consequential or punitive damages, in connection with or arising from Your use or from Your inability to use the Site.

With respect to any Content provided by users or other submissions, WHITESPACE is merely an Internet Service Provider of such Content. WHITESPACE is not responsible for any Content submitted by users or other third parties, including their opinions, judgments, advice, statements, services or other information provided. WHITESPACE shall not be liable for any loss or damage caused by any reliance upon such information obtained through the Website. It is Your responsibility to evaluate the accuracy, completeness, or usefulness of any Content.


You agree to defend, indemnify and hold harmless WHITESPACE, its parents and affiliates together with their respective employees, agents, directors, officers and shareholders, from and against all the liabilities, claims, damages and expenses (including reasonable attorney’s fees and costs) arising out of Your use of this Site; Your failure to use the Site; Your breach or alleged breach of this Agreement or Your breach or alleged breach of the copyright, trademark, proprietary or other rights of third parties.

Copyright Infringement 

If You believe that any material contained in this Site infringes Your copyright, You should notify WHITESPACE of Your copyright infringement claim in accordance with the following procedure.

WHITESPACE will process notices of alleged infringement which it receives and will take appropriate action as required by the Digital Millennium Copyright Act (“DMCA”) and other applicable intellectual property laws. The DMCA requires that notifications of claimed copyright infringement should be sent to this Site’s Designated Agent: BE SURE THAT THE AGENT REGISTERS WITH THE US COPYRIGHT OFFICE at 

Christopher T. Craig, Esquire

Cook, Craig & Francuzenko
3050 Chain Bridge Road, Suite 200
Fairfax, VA 22030

To be effective, the notification must be in writing and contain the following information as required under the DMCA (17 U.S.C. §512(c)(3)):

  1. Physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed;
  2. Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works at a single online site are covered by a single notification, a representative list of such works at that site;
  3. Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit the service provider to locate the material;
  4. Information reasonably sufficient to permit the service provider to contact the complaining party, such as an address, telephone number, and, if available, an electronic mail address at which the complaining party may be contacted;
  5. A statement that the complaining party has a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law;
  6. A statement that the information in the notification is accurate, and under penalty of perjury, that the complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

Miscellaneous. These Terms of Use operate to the fullest extent permissible by law. If any provision of this Agreement is unlawful, void or unenforceable, that provision is deemed severable from this Agreement and does not affect the validity and enforceability of any remaining provisions.  This Agreement is governed by, and construed in accordance with, the laws of the Commonwealth of Virginia without giving effect to any principles of conflicts of law. You agree to submit to the exclusive jurisdiction of the courts of the Commonwealth of Virginia for resolution of any dispute, action or proceeding arising in connection with this Agreement or Your use or non-use of the Site, and You further irrevocably waive any right You may have to trial by jury in any such dispute, action or proceeding.


The WHITESPACE name and logo are trademarks of Whitespace, Ltd., and all other trademarks, service marks and trade names used on the Site are the property of their respective owners, and all of the above trademarks may not be copied, downloaded or otherwise exploited without the permission of WHITESPACE or the owner of such trademark, service mark or trade name, except as explicitly permitted in these Terms of Use.


Effective Date: May 1, 2021

Whitespace, Ltd. (WHITESPACE, We or Our) is the owner and operator of  In this Privacy Policy (Policy), We describe the information that We collect about You as You use Our Website and Our products and services contained in Our Website (collectively, Our Services). This Policy applies to information that We collect online and offline.

We are operated entirely within the United States. If You are located outside of the United States, please note that any information – including personal data – that We collect about You will be transferred to and processed in the United States. You hereby consent to these transfers.

PLEASE NOTE: if You are a resident of a European Union (EU) nation, We have adopted a specific set of policies for collecting data from EU residents while they are in the EU country only, designed to comply with the General Data Protection Rules, May 25, 2018, as amended.  These policies, which can be found at Section XI below, supersede and replace any other policies herein that conflict with Section XI as they relate to EU residents.



A. Personally Identifiable Information We Collect from and About You

You are always empowered to choose whether to disclose personally identifiable information (PII) to us. If you elect not to do so, we reserve the right not to register you as a user or provide you with any products or services. 

“Personally Identifiable Information” or “PII” is information that identifies or may be used to identify a particular individual, including, without limitation, name, address, email address, social security number, telephone number, financial account number, and/or government-issued identifier.

In addition, Whitespace may have the occasion to collect non-personal anonymous demographic information, such as age, gender, household income, political affiliation, race and religion, as well as the type of browser you are using, IP address, or type of operating system, which will assist us in providing and maintaining superior quality service.  PII that We may collect includes, but is not limited to:

  • name
  • e-mail address
  • Physical address
  • date of birth
  • zip code
  • credit or debit card information
  • username
  • password

We may collect some or all of this information if You: 

  • visit the Website, make inquiries through the Website or offline;
  • use Our Website;
  • share Your e-mail address to contact us;
  • register for Our Services;
  • provide tips, comments or questions to us;
  • contact us for customer service or other purposes;
  • provide it to us when contacting us about this Policy. 

Other Information Collected

Data Pandemos Information Collection

Our contact metrics used on the Data Pandemos dashboard are created by collecting location data via mobile device applications. For this project we partnered with X-Mode Social. Please see X-Mode’s website with questions regarding their Privacy Policy. 

Virtual Bubble Information Collection

Our mobile application Virtual Bubble collects user location and health information. For this project we partnered with Radar Labs to obtain location reporting that is central to the user experience. Please see Radar’s website with questions regarding their Privacy Policy. Additionally, we have partnered with Nudge Coach Inc. to ensure that Virtual Bubble is HIPAA compliant. If you would like more information about how they ensure HIPPA compliance, visit this link. The “Health Insurance Portability and Accountability Act of 1996” can be found here.

B. Information Collected Automatically When Using Our Services

We and Our third-party service providers collect information automatically through the use of electronic tools such as Web beacons, “cookies,” Flash, clickstream data, and other automated devices that are deployed on the Website. We and Our third-party service providers may collect the following information about Your use of Our Website via these technologies: Your IP address; Your browser type and operating system; Web pages You view; links You click; Your interaction with Our Website; length of time You visit our Website; and Websites visited before Our Website.

Web Beacons. A Web beacon is a type of picture file used on the Internet. Web beacons are used in combination with cookies to help monitor traffic at Our Site and understand the ways in which users interact with content on the Website. Among other uses, We may use Web beacons to count visitors to Our Website or to monitor how Our users navigate Our Website. We may include Web beacons in email messages to count how many of the messages that We sent Were opened, acted upon, and forwarded. We use Web beacons to compile aggregate statistics about Our Services and Our marketing campaigns.

Cookies. Cookies help provide a customized user experience. We and Our third-party service providers may use cookies to, among other things, better serve You with tailored information and facilitate Your ongoing access to and use of Our Services. There are two types of cookies: session-based and persistent cookies. We also allow third party vendors to use cookies on Our Site and Application.

  • Session Cookies. Session cookies exist only during an online session. They disappear from Your computer when You close Your browser or turn off Your computer. We use session cookies to allow Our systems to uniquely identify You during a session or while You are logged into Our Services.
  • Persistent cookies. Persistent cookies remain on Your computer after You have closed Your browser or turned off Your computer. We use persistent cookies to track aggregate and statistical information about user activity, which may be combined with other user information.

Disabling Cookies. You may choose not to provide such information by adjusting Your Internet browser security settings to refuse cookies. Most Web browsers automatically accept cookies, but if You prefer You can edit Your browser options to block them in future. The Help portion of the toolbar on most browsers will tell You how to prevent Your computer from accepting new cookies, how to have the browser notify You when You receive a new cookie, or how to disable cookies altogether. If You disable Your Web browser’s ability to accept cookies, You will be able to browse Our Website, but certain pages and features may be limited.

ClickStream Data – We may use third-party software to analyze the Web pages that Your computer visits while using Our Services. This information, called “clickstream data,” is associated with Your computer’s Internet protocol (IP) address and/or device ID, and includes other information such as the type of browser Your computer/device uses to access the Internet. We may collect clickstream data to optimize search engine results and may also use clickstream data to analyze which portions of Our Website draw the most traffic so We can improve performance of Our Services. This clickstream data may be shared with third party advertisers and marketing companies.

Local Storage Objects – We and Our third-party service providers may use Flash Local Storage Objects (“Flash LSOs”) to store Your Website and Application preferences, to personalize Your visit or to display content based upon what You view on Our Website and Application. Flash LSOs are different from browser cookies because of the amount and type of data stored. In addition, You cannot control, delete or disable the acceptance of Flash LSOs through Your browser. For more information on Flash LSOs, or to learn how to manage Your settings for Flash cookies, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions. To see the Flash LSOs currently on Your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if You choose, to delete any specific Flash LSO.

Analytics. We and Our third-party service providers conduct analytics of Our Services to help us track and understand how visitors use Our Services, using the technologies described in this section. For example, We use a variety of third-party Web analytics, to help us improve the performance and user experience of Our Website and Application.  Our primary service provider for Web analytics is Google Analytics.  We do not respond to “do not track” signals or other mechanisms that provide consumers with the ability to exercise choice regarding the collection of personally identifiable information and about the individual’s consumer’s on-line activities over time. If You feel that We are not abiding by this privacy policy, You should contact us immediately via email at


We use Your information, including the personally identifiable information that We collect about You (collectively, “information”), for various reasons, including:

  • to fulfill our legitimate business interest in improving our services and product
  • to customize our products and services according to your needs
  • to deliver content that You have requested from Our Services;
  • to send e-mails that You have requested to receive from WHITESPACE;
  • to provide You with information, including via email or phone, about services, products, and features that may be of interest to You, including products and services offered by third parties, as Well as emails about Our own Services;
  • for customer service purposes, such as in response to inquiries that You initiate with us about any aspect of Our Website, to provide information about Our Services, or any other customer service purpose; and
  • to understand how people use Our Services, for research purposes, and to improve Our Services.

The data we collect from you will be stored no longer than necessary. The length of time we retain said information will be determined based upon the following criteria:

  • The length of time your personal information remains relevant;
  • The length of time it is reasonable to keep records to demonstrate that we have fulfilled out duties and obligations;
  • Any limitation periods within which claims might be made;
  • Any retention periods prescribed by law or recommended by regulations;
  • The type of contract we have with you;
  • The existence of your consent;
  • Our legitimate interest in keeping such information as stated in this Policy.


We may share personally identifiable information with others, such as:

  • Third Party Service Providers that provide services on Our behalf. Examples of these services include, but are not limited to: technical support for the operation of Our Services; Website evaluation and statistics; and fulfilling Your orders for products and services made available through Our Site;
  • Law enforcement authorities, government agencies, courts, or other entities, when: 
    • We believe in good faith that the law requires it;
    • We deem it necessary or appropriate to provide such information;
    • To otherwise protect Our rights, other persons, or other users of Our Services;
    • Another entity, in the course of a sale to or merger of all or a part of Our business with another entity.
  • A court, another business, or other interested party in the event of a bankruptcy proceeding, in which case the information about You would be among the many assets shared or transferred.
  • Third-party merchants with from whom You choose to make a purchase through Our Services;
  • Other non-affiliated third parties. We may share Your information, including personally identifiable information, with non-affiliated third parties for their own marketing purposes. If You are a California resident, please see the special notice to You below about how You can obtain additional information about this sharing.
  • We also may disclose aggregate user statistics to third parties for a variety of purposes, including research, analytics, and marketing.


You can always choose not to submit any personally identifiable information to WHITESPACE.

We will include an opt-out link or reply address in each such e-mail. Please allow us up to 10 business days to process Your request. After unsubscribing, You may still receive messages about the status of Your account, to resolve technical issues, to confirm a new registration with us, and for other customer services purposes.


We may provide links to content or advertisements created, offered, sponsored, or available at third party Websites. Your interactions with these third-party Websites are not governed by this Privacy Policy, but rather the privacy policies posted on those linked Websites. We are not responsible for Your access to and use of these Websites or any information You share with them.


To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of the personally identifiable information We collect, We have implemented physical, electronic, and administrative procedures. These measures are based on commercially reasonable standards that similar companies use. NO DATA TRANSMITTED OVER THE INTERNET CAN BE GUARANTEED TO BE 100% SECURE AT ALL TIMES. Although We have implemented security measures to protect Your personally identifiable information, We cannot and do not guarantee the security of such information.

Whitespace has been entrusted by our clients and users with original sensitive, private data to include PII, through the services and products it provides. 

Although We have implemented security measures to protect Your PII, We cannot and do not guarantee the security of such information.  Whitespace will promptly and thoroughly investigate and resolve all allegations of unauthorized access to, use or disclosure of or alteration or destruction of Data (Security Breach). Whitespace will notify applicable parties of any Security Breach in writing without undue delay, no later than twenty-four (24) hours after discovery of the Security Breach and comply with applicable Privacy Laws, including (for example) the root cause of the breach, information about the affected individuals and the possible consequences.

Unsubscribe or Opt-Out

All users have the option to discontinue the collection of data or other PII at any time. To discontinue or unsubscribe, please contact us using the information below. By discontinuing or unsubscribing please be aware that you may no longer have access to Whitespace products and services. Whitespace will continue to adhere to this Policy with respect to any personal information previously collected.

For Data Pandemos, our metrics utilize data collected by X-Mode Social. To fully unsubscribe or opt-out, please visit X-Mode’s Privacy Policy page or the NAI Opt-Out Page.

For Virtual Bubble on Apple, please follow these instructions. Open the Virtual Bubble application, choose “Settings,” select your profile name, open “Update Location Tracking,” and click the “Open Location Settings” button. This will take you to your phone’s settings where you can open “Location” and select if you want Virtual Bubble to collect your information “never,” “while using the app,” or “always.” You can select “never” to opt-out, or you can simply uninstall Virtual Bubble from your mobile device.


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For Virtual Bubble on Google, please follow these instructions. Open the Virtual Bubble application, choose “Settings,” select your profile name, open “Update Location Tracking,” and click the “Open Location Settings” button. This will take you to your phone’s location permissions where you can select if you want Virtual Bubble to collect your information “all the time,” “while using the app,” or if you’d like the app to request your permission “every time.” You can select “deny” to opt-out, or you can simply uninstall Virtual Bubble from your mobile device.


Disclosure of Information

Whitespace will not give, sell, or rent your information to third parties without your express consent. The only time Whitespace may use or disclose the information provided by you occurs under the following circumstances:


This Website is not directed to children. We do not knowingly collect or solicit personally identifiable information from or about children under 14, except as permitted by law. If We discover that We have received any personally identifiable information from a child under 14, We will delete such information from Our servers and records promptly.


We reserve the right to change this Privacy Policy at any time. Please check this page periodically for changes. We will post a notice on this Website if and when this policy changes to alert visitors that a new policy is in place.

Material or important changes to the way We use or disclose personally identifiable information will apply on a going-forward basis, unless We have Your express consent to change the way We use or disclose the personally identifiable information We collected when the earlier version of this Privacy Policy was in effect.


California residents may request a list of all third parties to which WHITESPACE has disclosed certain personally identifiable information about You for marketing purposes. You may make one request per calendar year. In Your request, please attest to the fact that You are a California resident and provide a current California address for Your response. You may request this information in writing by contacting us at: or Privacy Request, Whitespace, Ltd,  California residents under the age of eighteen (18) may retract their consent and have their data removed from Our records at any time.  Specifically, if after having provided data a resident under age 18 desires to have his or her data removed entirely, she or he may send a request to us at


This policy is applicable to all users, including European Union (EU) residents while accessing Our Website in an EU country.  If the policy described above conflicts in any way with the policy in this Section XI, and You are an EU consumer (user), this Section XI shall control.  

Legal Basis for Data Processing: We process Personal Data for the purposes set out in this Privacy Policy.  Our legal basis to process Personal Data includes processing that is: necessary for the performance of any contract between You and us; necessary to comply with legal requirements; necessary for Our legitimate interests (for example, to improve the Site and Our Services); and based on consent by Our customers which may subsequently be withdrawn at any time (by emailing us at without affecting the lawfulness of processing based on consent before its withdrawal. In some instances, You may be required to provide us with Personal Data for processing as described above so We can provide You all of Our Services, and for You to use all the features of Our Website. You may lodge a complaint with a supervisory authority if You consider that Our processing of Your Personal Data infringes applicable law.

WHITESPACE is the data controller for processing of information defined as Personal Data under applicable data protection law.

EU residents shall not be subject to the ‘opt-out’ rules described above, but rather shall be directed to a separate processing Web portal wherein they must choose to ‘opt-in’ to signify their explicit, freely given, informed, and unambiguous consent, to the use of their data (“Right to Consent”) and other transactions.  In addition, EU residents will be provided easy ability to retract such consent and have their data removed from Our records (“Right to Access” and “Right to be Forgotten”).  Specifically, prior to collecting Your data We provide a separate ‘opt-in’ alternative for data related to e-mail, telephone contact, direct mail and receipt of newsletters.  If, after having provided such data, You desire to have Your data removed entirely, You may send Your request to us at (“Right to be Forgotten”)  In the event of a data breach, We shall send notification to the EU Information Commissioners Office (ICO) within 72 hours of becoming aware of the breach and We will send You notification without undue delay if it is likely to result in risk to Your rights and freedoms. Finally, you have the right to transfer Your data from us to another controller of data, on request, in a suitable format.


Questions and comments regarding this Privacy Policy, or to review and/or correct Your personal information gathered by WHITESPACE, or to inform WHITESPACE that You do not want Your information shared, should be directed to

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