Privacy Policy

This Privacy Policy describes how Or Shemesh, an individual operating under the trade name "Winq" ("Winq", "we", "us", or "our"), collects, uses, and protects your personal information when you use the Winq mobile application (the "Service").

By using the Service, you agree to the practices described in this Privacy Policy.

About Winq

Winq is an AI-powered mobile application that helps users improve their dating conversations by analyzing chat screenshots and generating suggested replies, opening lines, and conversation insights.

Summary of Key Points

• We collect information you provide directly (name, email, profile data, uploaded chat screenshots) and information collected automatically (device data, usage logs, approximate location from IP).
• We use AI services (Google Gemini) to analyze the conversations you share with us to generate replies and insights.
• We share information with service providers who help us operate the Service, including Apple, Google, Supabase, RevenueCat, and Resend.
• We do not sell your personal information.
• We retain your information for as long as you have an account with us.
• You have rights regarding your data, including access, correction, and deletion.

1. Information We Collect

1.1 Information You Provide Directly

When you create an account or use the Service, you provide us with:

• Name — your display name in your profile
• Email address — for authentication and communication
• Password — securely hashed; we never see your plaintext password
• Date of birth or age — to verify you are 18 or older
• Gender — your self-identified gender
• Dating preferences — including who you are interested in chatting with
• Dating goal — what you are looking for (relationship, casual, etc.)
• City or location — your general location
• Interests, hobbies, or other profile details — if you choose to provide them
• Chat screenshots — images you upload for analysis, which contain conversation content between you and another person

1.2 Information Collected from Other Sources

If you sign in using Google, we receive the following from Google:

• Email address
• Name
• Profile picture (if available)
• A unique Google account identifier

1.3 Information Collected Automatically

When you use the Service, we automatically collect:

• Log and usage data — IP address, app activity, timestamps, error reports, performance data
• Device data — device model, operating system version, unique device identifiers, app version
• Approximate location — derived from your IP address (city or region level, not GPS)

1.4 Sensitive Personal Information

Some of the information you provide is considered sensitive under privacy laws:

• Account login credentials
• Sexual orientation or dating preferences
• Contents of messages — within the chat screenshots you upload

We process this information only to provide the Service to you and treat it with additional care.

1.5 Mobile Device Permissions

The Service may request access to certain features of your device:

• Camera — to capture screenshots directly
• Photo library — to select existing screenshots from your device

You can revoke these permissions at any time through your device settings.

2. How We Use Your Information

We use your personal information to:

• Provide and operate the Service, including generating AI-powered replies and conversation analysis
• Create and manage your account
• Process subscription payments and fulfill orders
• Personalize content and recommendations based on your profile
• Respond to your inquiries and provide customer support
• Send administrative communications (password resets, service updates, account notifications)
• Send marketing and promotional communications (you may opt out at any time)
• Identify usage trends and improve the Service
• Detect, prevent, and respond to fraud, abuse, security incidents, and illegal activity
• Comply with legal obligations

Inferences

We may use your personal information to make inferences and personalize your experience, such as determining what tone or style of reply suggestions are most relevant for you. We do not use these inferences to make automated decisions that have legal or significant effects on you.

3. Legal Bases for Processing (EU/UK Users)

If you are in the European Economic Area, the United Kingdom, or Switzerland, we rely on the following legal bases under the GDPR:

• Performance of a contract — to deliver the Service you have subscribed to
• Consent — for marketing communications and certain uses of sensitive data
• Legitimate interests — to improve the Service, prevent fraud, and respond to inquiries
• Legal obligation — to comply with applicable laws

You may withdraw consent at any time where we rely on consent.

4. How We Share Your Information

We do not sell your personal information. We share information only with the following categories of third parties to operate the Service:

• Cloud hosting and computing providers — to host the Service infrastructure
• Data storage providers — to store account and profile data
• AI platforms — to process chat screenshots and generate AI responses
• Payment processors — to handle subscription billing through the Apple App Store
• Email service providers — to deliver transactional and marketing emails
• User authentication services — to support sign-in via Google and email/password authentication

We have data processing agreements in place with these providers that include Standard Contractual Clauses (SCCs) for international data transfers where applicable.

We may also disclose your information if required by law, legal process, or to protect the rights, safety, or property of Winq, our users, or others.

In the event of a merger, acquisition, sale of assets, or similar business transfer, your personal information may be transferred to the acquiring entity.

5. International Data Transfers

The Service is operated from Israel, with infrastructure hosted in the Netherlands, Ireland, and the United States. Our service providers are located primarily in the United States.

If you are in the EU, UK, or another region with data transfer restrictions, your personal information may be transferred to and processed in countries that may not provide the same level of data protection as your home country. We rely on the European Commission's Standard Contractual Clauses (SCCs) and equivalent safeguards to protect your information during international transfers.

6. Data Retention

We retain your personal information for as long as you maintain an account with us. When you delete your account, we permanently remove your personal data, except where we are required to retain certain information by law.

The same retention period applies to:

• Personal identifiers (email, name)
• Inferences and profile data
• Purchase history (subject to legal retention requirements for tax and accounting)
• Chat screenshots and analysis results

7. Your Rights and Choices

Depending on where you live, you may have the following rights regarding your personal information:

• Access — request a copy of the information we hold about you
• Correction — update inaccurate or incomplete information
• Deletion — request that we delete your personal information
• Portability — receive your data in a structured, commonly used format
• Restriction — limit how we process your information
• Objection — object to certain processing activities
• Withdraw consent — where processing is based on consent
• Appeal — appeal our decision regarding your rights request
• Opt out of marketing — unsubscribe from marketing emails at any time

How to Exercise Your Rights

You can exercise most rights directly within the Service:

• Update profile: edit your information in the Profile section
• Delete account: use the "Delete Account" option in the Profile menu
• Unsubscribe from marketing: click the unsubscribe link in any marketing email

For other requests, contact us at:

Email: info@winqai.app

In-app: Use the "Contact Support" option in the Profile menu

We will respond within the time required by applicable law.

Right to Appeal

If we deny your request, you may appeal by replying to our response or contacting us again at info@winqai.app.

8. California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

• Right to know what personal information we collect, use, and disclose
• Right to delete your personal information
• Right to correct inaccurate information
• Right to opt out of the sale or sharing of your personal information (we do not sell or share for cross-context behavioral advertising)
• Right to limit use of sensitive personal information
• Right to non-discrimination for exercising your rights

Categories of Information Collected (Last 12 Months)

We have collected the following categories of personal information in the last 12 months:

• Identifiers (name, email)
• Personal records (account login)
• Commercial information (subscription purchase history)
• Internet activity (app usage data)
• Geolocation data (approximate, from IP)
• Sensory data (uploaded screenshots)
• Inferences (drawn from profile and usage)

"Shine the Light" (California)

California residents may request information about disclosures of personal information to third parties for direct marketing. Contact us at info@winqai.app.

9. Other US State Privacy Laws

We honor privacy rights granted under the following state laws where applicable: Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), Florida (FDBR), Montana (MCDPA), Delaware (DPDPA), Iowa (ICDPA), Indiana (ICDPA), Tennessee (TIPA), New Hampshire (NHPA), New Jersey (NJDPA), Kentucky (KCDPA), Maryland (MODPA), Minnesota (MCDPA), Nebraska (NDPA), and Rhode Island (RIDTPPA).

Residents of these states have rights similar to those described above, including access, correction, deletion, portability, and the right to opt out of sale or targeted advertising. We do not sell personal information or use it for targeted advertising.

10. Canadian Privacy Rights

If you are in Canada, including Quebec, you have rights under PIPEDA and Quebec's Law 25, including the right to access, correct, and request deletion of your personal information. We process Canadian users' information in accordance with these laws.

11. AI-Based Services

The Service uses artificial intelligence to provide its core functionality. Specifically, we use Google Cloud AI (Gemini) to analyze the chat screenshots you upload and generate text-based replies, opening lines, and conversation insights.

The AI processing occurs on our service providers' servers. Your uploaded content and profile data are sent to the AI service for processing, with the response returned to you within the Service.

We do not use your data to train AI models. Google's API terms specify that data sent through their API is not used for training their models.

12. Children's Privacy

The Service is not intended for users under 18 years of age. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected information from a person under 18, we will promptly delete it. If you believe a child under 18 has provided us with personal information, please contact us at info@winqai.app.

13. Security

We use reasonable technical and organizational measures to protect your personal information, including:

• Encrypted data transmission (HTTPS/TLS)
• Encrypted storage at rest
• Secure authentication systems
• Access controls limiting who can view personal data

However, no system is 100% secure. We cannot guarantee absolute security of your information. If we become aware of a security incident that affects your personal information, we will notify you in accordance with applicable law.

14. Marketing Communications

We may send you marketing emails about new features, promotions, or related services. You can unsubscribe at any time by clicking the unsubscribe link at the bottom of any marketing email. Unsubscribing from marketing does not affect transactional emails (such as password resets or account notifications).

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top reflects the most recent revision. If we make material changes, we will provide notice through the Service or by email. Continued use of the Service after changes constitutes acceptance of the updated Policy.

16. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal information, contact us:

Email: info@winqai.app

In-app: Use the "Contact Support" option in the Profile menu

Operator: Or Shemesh (d/b/a Winq)

Location: Israel