Privacy Policy
Our Commitment To You
At Wiingr, we prioritize your privacy above all else. It forms the foundation of our service and product development, ensuring that you can trust our offerings completely and concentrate on forging meaningful connections.
We value the trust you place in us when sharing your information, and we take this responsibility seriously.
Our dedication to safeguarding your privacy. Our approach to product and service design is centered around your privacy. We engage experts from diverse fields such as legal, security, engineering, and product design to ensure that every decision we make is grounded in the highest regard for your privacy.
Our pledge to transparency. We understand the frustrations commonly associated with privacy policies, often filled with insufficient information and overly complex language. In contrast, we are committed to transparency and clarity. Our Privacy Policy and related documents are written in plain language, aiming for simplicity and comprehension. We genuinely encourage you to read and understand our privacy practices.
Our dedication to ensuring security. Dedicated teams are committed to safeguarding your data, continuously updating our security protocols and investing in ongoing efforts to fortify the protection of your information.
Welcome to our Privacy Policy. Thank you for taking the time to read it.
If you reside in California, please refer to our California Privacy Statement, which complements this Privacy Policy.
We value the trust you place in us by sharing your information, and we are committed to maintaining that trust. Our commitment begins with ensuring that you comprehend the information we collect, the reasons behind its collection, how it's utilized, and your options regarding your information. This Policy articulates our privacy practices using clear and straightforward language, minimizing legal and technical terminology.
This Privacy Policy takes effect on April 1, 2024.
California Consumers
To understand your California privacy rights, please refer to our California Privacy Statement.
1. Who We Are
If you reside in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, the entity accountable for your information in accordance with this Privacy Policy (referred to as the “data controller”) is:
2. Where This Privacy Policy Applies
This Privacy Policy pertains to the websites, applications, events, and other services operated under the Wiingr brand. For simplicity, we collectively refer to these as our "services" in this Privacy Policy. To ensure clarity, we have included links to this Privacy Policy on all applicable services.
Certain services may necessitate their own distinct privacy policy. If a service has its own privacy policy, the terms outlined in that policy—rather than this Privacy Policy—will govern its use.
3. Information We Collect
It's evident that in order to facilitate meaningful connections, we require certain information about you, including basic profile details and your preferences regarding the types of individuals you'd like to meet. Please note that some of the information you provided can be updated at any time through the app settings. The more comprehensive your profile, the better our system can generate accurate matches and connections for you. To maintain authenticity and ensure user safety, we require your name and date of birth during onboarding and cannot be updated later. We appreciate your cooperation as we work towards creating a trusted and enjoyable experience for all users. For further elaboration, we provide more detailed information below.
Information you give us
When utilizing our services, you have the option to provide us with specific information. This may include:
- Upon creating an account, you furnish us with at least your phone number and email address, along with essential details required for the service's functionality. These include your gender, date of birth, and preferences regarding the individuals you wish to connect with.
- When you finalize your profile, you're presented with the choice to disclose your sexual orientation. By providing such details, you consent to our utilization of this information for the specified purposes outlined in this Privacy Policy. Additionally, you have the option to furnish us with additional information, including details about your bio, interests, as well as content such as photos and videos. For certain content types, such as pictures, you may grant us access to your camera or photo album.
- Participation in surveys, focus groups, or market studies involves providing insights into our products and services, responding to our inquiries, and offering testimonials.
- When you subscribe to a paid service or make a direct purchase from us (excluding transactions through platforms like iOS or Android), you provide us with information related to your purchases. This may include your debit or credit card number and other financial details, which are processed by our payment processors.
- If you share information about other individuals with us (e.g., using a friend's contact details for a specific feature), we process this data on your behalf to fulfill your request.
- Interactions with our customer care team result in the collection of information disclosed during the exchange.
- Furthermore, we process your conversations with other members and the content you publish to facilitate the operation and security of our services, ensuring the safety of our community.
We highly recommend and encourage you, as well as all our members, to thoughtfully consider the information you choose to share about yourself. We advise against including email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, driver's license details, or any other sensitive information that could be subject to abuse or misuse on your profile.
When you post information about yourself or utilize the messaging function to interact with other users, the extent of personal information you choose to share is at your own discretion and risk. For more details regarding who can access the content you post on Wiingr, please refer to Section 5 below.
Information we receive from others
In addition to the information you directly provide to us, we may also receive information about you from other sources, including:
- Members: Members may provide information about you as they utilize our services, such as through interactions with you or by submitting reports involving you.
- Social Media: You may choose to share information with us by providing your social media account link, such as updating your social tab in the app settings (Facebook, Instagram, Snapchat, or TikTok), or by adding your playlist link from audio streaming apps (e.g., Apple Music or Spotify).
Information generated or automatically collected when you use our services
When you utilize our services, it generates technical data regarding the features you've accessed, how you've interacted with them, and the devices you've used to access our services. Please refer below for more detailed information.
- Usage Information: Using the services generates data about your activity, including how you utilize them (such as when you log in, the actions you take, and the information displayed to you) and your interactions with other members (such as members you connect and interact with, and when you match and exchange messages with them).
- Device information: We collect information from and about the device(s) you use to access our services, including hardware and software information such as IP address, device type or other technologies that may uniquely identify a device or browser.
- Precise geolocation data: If you give us your consent, we can collect your precise geolocation (latitude and longitude) from your device. The collection of your geolocation occurs when you enable it during onboarding or reset it in the app settings. This information helps us identify your physical location and personalize the app, making it easier for you to interact with other users. By enabling the display of general locality information to users viewing your profile and showing you profiles of other users who are near you. If you decline permission for us to collect your precise geolocation, we will not collect it, and certain services that rely on precise geolocation may not be available to you.
- Other information: We may collect additional information with your permission, including photos, especially if you choose to share media content.
• Other information with your consent:
4. How We Use Information
The primary purpose of utilizing your information is to deliver and enhance our services. Furthermore, we employ your data to ensure the safety of both you and our community. Below, you'll find a more detailed explanation of the various reasons for which we utilize your information, accompanied by practical examples.
To manage your account and deliver our services to you
- Establish and oversee your account.
- Offer customer support and address your inquiries.
- Keep you informed about our services.
- Tailor pricing, extend discounts and promotions, and finalize your transactions.
Facilitate connections with other users
- Suggest you to other members and suggest other members to you.
- Display profiles of members to each other
- Facilitate member searches and connections
Enhance our services and innovate new offerings.
- Conduct focus groups, market studies, and surveys
- Analyze interactions with customer care teams to enhance our service quality
- Gain insights into members' typical usage patterns to enhance services. This may involve modifying the look, feel, or features based on member feedback and reactions.
- Innovate new features and services, such as expanding an interests-based feature based on member requests
To safeguard against, identify, and combat fraud as well as other illegal or unauthorized activities
- Identify and resolve ongoing, suspected, or alleged violations of our Terms of Use, particularly by reviewing reports and member interactions
- Enhance comprehension and formulate strategies to counter violations of our Terms of Use
- Maintain data concerning violations of our Terms of Use to address the infraction and mitigate against future occurrences
- Implement or assert our rights, such as those outlined in our Terms of Use
- Provide communication to individuals who submit a report, detailing the actions taken in response to their submission
Guarantee adherence to legal requirements
- Adhere to legal obligations
- Provide assistance to law enforcement authorities
- To deliver our service to you: We process your information for purposes 1, 2, and 3 mentioned above to fulfill the contract you have with us. For example, as you utilize our service to establish meaningful connections, we utilize your information to manage your account and profile, display it to other members, suggest other members to you, and provide our free and paid features to you and other members
- Legitimate interests: We process your information for purposes 4 and 5 above, relying on our legitimate interest. For example, we process information to ensure the safety of our members and to enforce our rights, provide assistance to law enforcement, and enable us to defend ourselves in legal proceedings when necessary
- To comply with applicable laws and regulations: We process your information for purpose 5 above when it is necessary for us to adhere to relevant laws and regulations and to demonstrate our compliance with them. For instance, we retain transactional data to fulfill our accounting, tax, and other legal data retention obligations, and to respond to lawful requests from law enforcement. Additionally, we maintain records of consents provided by members and decisions they have made to opt-out of certain features or processing
- Consent: If you decide to provide us with information that may be classified as "special" or "sensitive" in certain jurisdictions, such as your sexual orientation, you are giving your consent to our processing of that information in accordance with this Privacy Policy. Occasionally, we may request your consent to collect specific information, like your precise geolocation or to use your information for particular reasons. In some instances, you can withdraw your consent by adjusting your settings (for example, concerning the collection of precise geolocation) or by deleting your content (for instance, if you provided sensitive information in your profile). However, regardless, you have the right to withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy
To learn more about how we handle personal information through profiling and automated decision-making, please refer to our [privacy policy/terms of service/other relevant document]. FAQ.
To handle your information as outlined in this Privacy Policy, we depend on the following legal bases:
5. How We Share Information
As our aim is to facilitate meaningful connections for you, the primary sharing of members' information is naturally with other members. Additionally, in some instances, with legal authorities. Continue reading for further insights into how your information is shared with others
With other members
You share information with other members when you willingly disclose information on the service, including your public profile. It's important to be cautious with your information and ensure that the content you share is something you're comfortable being visible to others
If you decide to restrict the audience for all or specific parts of your profile, as well as certain content or information about you, it will only be visible in accordance with your chosen settings
If someone submits a report involving you, such as a claim that you violated ourTerms of Use), we may communicate to the reporter any actions we have taken, if applicable, as a result of their report
With our service providers
We utilize vendors to aid in operating and enhancing our services, including tasks such as data hosting and maintenance, customer care, payment processing, and security operations
Before engaging any vendor or partnering with any entity, we adhere to a rigorous vetting process. Our vendors and partners are required to agree to stringent confidentiality obligations
For corporate transactions
We may transfer your information in the event of our involvement, whether wholly or partially, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or any other change of ownership or control
With law enforcement / when required by law
We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena, or search warrant, government/law enforcement investigation, or other legal requirements; (ii) to aid in the prevention or detection of crime (subject to applicable law in each case); or (iii) to safeguard the safety of any person.
To enforce legal rights
We may also share information: (i) if disclosure would help reduce our liability in an actual or potential lawsuit; (ii) as necessary to safeguard our legal rights and the legal rights of our members, business partners, or other relevant parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or address illegal activity, suspected fraud, or other wrongdoing
With your consent or at your request
We may request your consent to share your information with third parties. If we do so, we will clearly explain the reasons why we wish to share the information
We may utilize and disclose non-personal information (defined as information that does not personally identify you, such as device information, general demographics, general behavioral data, and de-identified location), as well as personal information in hashed, non-human readable form, in any of the situations mentioned above
6. Your Rights and Choices
- Access / Update tools in the service. Tools and account settings are available to help you access, correct, or delete information you provided to us that's linked to your account directly within the service. Should you have any inquiries about these tools and settings, please reach out to us via the help tab in your account settings.
- Device permissions. Mobile platforms often feature permission systems for various types of device data and notifications, including phone contacts, pictures, location services, push notifications, and advertising identifiers. You have the option to adjust your device settings to either consent to or decline the collection or processing of the relevant information or the display of notifications. However, please be aware that modifying these settings may result in certain services losing functionality
- Uninstall You can cease all information collection by an app by uninstalling it through the standard uninstall process for your device. It's important to note that uninstalling an app does not deactivate your account. To close your account, please utilize the corresponding functionality provided within the service
- Account closure. You can close your account by using the appropriate functionality directly within the service
- Access/know. You may have the right to request a copy of the information we retain about you, and under certain circumstances, to receive it in a portable format. You can exercise your right to access this information directly within the service by submitting a request
- Delete/erase. You have the right to request that we delete the personal information we hold about you. You can exercise your right to deletion by submitting a request
- Correct/rectify/update. You can update most of the information you provided to us by editing your profile directly within the service. If you believe that the information we have about you is inaccurate, you may contact us to correct it
- Object/restrict. You may also have the right to object to or request that we restrict certain processing of your personal information. To exercise this right, please contact us
We also want you to be informed about your privacy rights. Depending on your location, you may have the right to:
For your security and that of all our members, we may require you to provide proof of identity before we can fulfill the above requests. Please note that we may reject requests if we are unable to verify your identity, if the request is unlawful or invalid, or if it might violate trade secrets, intellectual property, or the privacy or rights of others. If you seek information regarding another member, such as copies of messages received from them through our service, that member must contact us to provide written consent before the information is released. We may also request proof of identity from them before processing the request. Additionally, there may be certain requests to object to or restrict the processing of personal information that we cannot accommodate, particularly if fulfilling them would prevent us from providing our service to you. For example, we cannot provide our service without your date of birth, as we cannot ensure that you are 18 years of age or older
If you reside in Virginia, Colorado, or Connecticut, USA, and your privacy request is denied, you have the option to appeal by contacting us and explicitly mentioning "Privacy Request Appeal." If you are dissatisfied with the outcome of your appeal, you can reach out to the attorney general in your state. Additionally, it's important to note that we do not engage in the "selling" of your personal data or utilize it for "targeted advertising" or "profiling" that could significantly impact legal matters, as defined by relevant state laws. Therefore, no opt-out choice is required
In specific countries, such as those within the European Economic Area and the United Kingdom, you possess the right to file a complaint with the relevant data protection authority if you have apprehensions regarding the manner in which we handle your personal data. Information regarding your data protection regulator within the European Economic Area can be found here, and within the United Kingdom here. The data protection authority to which you can submit a complaint may correspond to your usual place of residence, your workplace, or where an alleged violation occurred
7. How Long We Retain Your Information
- In order to safeguard the safety and security of our members, we institute a safety retention period lasting three months after an account closure, or one year following an account ban. Throughout this duration, we retain your information in case it becomes essential for investigating unlawful or harmful behaviors. The decision to retain information during this safety retention period is founded on our legitimate interest as well as that of potential third-party victims
- After the safety retention window expires, we proceed to delete your data entirely, retaining only minimal information for specific purposes as outlined below:
- We retain a limited amount of data to fulfill legal data retention obligations. Specifically, transaction data is kept for a period of 10 years to adhere to tax and accounting legal requirements. Credit card information remains stored for the duration in which a user may contest a transaction
- We maintain limited information based on our legitimate interests. Customer care records and associated data, as well as imprecise location details of downloads/purchases, are retained for five years to support our customer care decisions, protect our rights, and enable defense against potential claims. Information regarding past accounts and subscriptions is kept for three years after the closure of your last account to ensure accurate financial forecasting and reporting. Profile data is retained for one year in anticipation of potential litigation, for the establishment, exercise, or defense of legal claims. Additionally, data necessary to prevent banned members from opening new accounts is maintained for as long as necessary to ensure the safety and vital interests of our members.
- Lastly, we retain information based on our legitimate interest in situations where there is an ongoing or potential issue, claim, or dispute that necessitates the retention of information. This includes instances where we receive a valid legal subpoena or request to preserve data, in which case we are obligated to retain the data to comply with legal requirements. Additionally, data may be kept if it is deemed necessary for legal proceedings or would otherwise serve a legal purpose
8. No Children Allowed
Our services are exclusively available to individuals who are 18 years of age or older. We strictly prohibit individuals under the age of 18 from accessing our platform. If you suspect that a member is under the age of 18, we encourage you to utilize the reporting mechanism provided on the service
10. Privacy Policy Changes
As we continually seek new and innovative methods to assist you in forming meaningful connections and ensure that our explanations regarding data practices remain current, this policy may undergo changes over time. Prior to the implementation of any significant changes, we will notify you to allow ample time for review
11. How to Contact Us
If you have questions about this Privacy Policy, you can send us a request here
Effective Date
This Privacy Policy was last updated on: TBD