Privacy Policy

Privacy Policy of Wingmawo™

This Privacy Policy (“Policy”) explains how Affinity Grid Private Limited, a company incorporated under the Companies Act, 2013 (“Affinity Grid”, “we”, “us”, “our”), collects, uses, stores, discloses, and protects personal data of individuals (“you”, “user”) who access or use the Wingmawo™ mobile application and any services directly connected to the application (“Service”).

Wingmawo™ is a digital product wholly owned, operated, and legally governed by Affinity Grid Private Limited. Your use of Wingmawo™ constitutes consent to the data practices described in this Policy.

This Policy is compliant with the Digital Personal Data Protection Act, 2023 (DPDPA) of India, and, where applicable, the General Data Protection Regulation (GDPR) for users in the European Economic Area.

If you do not agree to this Policy, you must discontinue use of the Service.

1. Definitions & Scope

2. Legal Bases & Processing Principles

We process Personal Data under the following legal bases:

• Consent (especially for sensitive data)
• Performance of a contract (to deliver the Service)
• Legal obligation
• Legitimate interest (e.g., fraud detection, safety, analytics)

We adhere to the principles of:

• Lawfulness, fairness, transparency
• Purpose limitation
• Data minimization
• Accuracy
• Security & confidentiality
• Accountability
• Non-discrimination in algorithmic outputs

3. Data We Collect

A. Account & Identity Data

Name, email, phone number, date of birth, gender, login credentials, identity verification data (e.g., government ID, selfie).

B. Profile & Preference Data

Photos, videos, bio, interests, match preferences, discovery settings, sensitive attributes (e.g., sexual orientation) — only with explicit consent.

C. Behavioral & Usage Data

Swipes, likes, skips, match interactions, search filters, preference patterns, safety-related signals and report history.

D. Device & Technical Data

IP address, device identifiers, OS, app version, crash logs, diagnostics, performance metrics, anti-spam and anti-fraud indicators.

E. Location Data

GPS data (if permitted), approximate location derived from IP.

F. Communications & Media

Messages, voice notes, images, video features, reports and complaint submissions, moderation outcomes.

G. Payment Data

Transaction IDs, payment method, billing information for subscription features.

H. Support & Correspondence

Customer support tickets, emails, requests, and feedback.

I. Marketing & Landing Page Data

Emails collected through the Wingmawo landing page are processed via Zoho Campaigns, in compliance with their privacy standards. Marketing preferences, campaign engagement.

J. Authentication & OTP Data

Phone numbers submitted for login and verification. OTP messages are delivered through TRAI- and DLT-approved routes. The ONLY official sender ID used by Wingmawo™ is AFGRPV. Any message received from any other sender ID is not affiliated with Wingmawo™.

K. Third-Party Data (Optional)

Social login information (Apple, Google, Facebook), contact import (only if explicitly authorized).

We do not sell Personal Data.

4. How We Use Your Data

• Create and manage user accounts
• Enable matching, discovery, and communication
• Personalize recommendations using behavioral insights
• Enhance safety and prevent misuse
• Moderate content and resolve user reports
• Verify identity and detect fraudulent accounts
• Send service updates, notifications, and marketing (with consent)
• Process subscriptions and payments
• Improve algorithms, performance, and user experience
• Comply with legal obligations and assist law enforcement
• Maintain platform integrity and security

5. Consent & User Controls

Users may:

• Withdraw consent for sensitive data at any time
• Disable location access
• Control visibility settings and match preferences
• Opt out of certain types of personalized recommendations
• Object to processing under legitimate interests, where applicable
• Request human intervention for automated moderation decisions
• Disable marketing emails (via Zoho unsubscribe tools)

6. Sharing & Disclosure

We may share Personal Data with:

• Service providers and processors for messaging, hosting, analytics, identity verification
• Payment processors
• Safety and moderation partners for flagged content review
• Law enforcement or government authorities, when required by law
• Successor entities in a merger, acquisition, or restructuring (with notice)

Cross-border data transfers follow legal safeguards such as Standard Contractual Clauses. We never disclose your Personal Data to advertisers without your explicit consent.

7. Data Retention, Account Deletion & Data Erasure

7.1 General Principles

We retain personal data only for as long as necessary. Once the purpose has been fulfilled, personal data is securely deleted or irreversibly anonymized.

7.2 Right to Delete Your Account

Wingmawo provides users with the ability to permanently delete their account and associated personal data at any time through an in-app mechanism. Account deletion is permanent, irreversible, and inclusive of personal data stored in active production systems.

7.3 In-App Account Deletion

Users may delete their account directly inside the Wingmawo mobile application:

1. Open the Wingmawo app
2. Navigate to Settings > Account > Delete Account
3. Review the deletion notice
4. Confirm identity if prompted
5. Select “Permanently Delete My Account”

7.5 Scope of Data Deleted

• Profile information (name, age, gender, preferences, biography, interests)
• Uploaded photos and media
• Match history and interaction records
• Chat conversations, including AI-assisted chat data
• Location data associated with the account
• Device identifiers linked to the account
• Push notification tokens
• Activity logs attributable to the account

Deleted data cannot be restored.

7.6 Backup Retention

Encrypted backups may retain data for up to 30 days. Backup data is not processed, accessed for advertising, or restored except for disaster recovery purposes.

7.7 Lawful Retention Exceptions

Limited data may be retained strictly where required for:

• Taxation or accounting obligations
• Law enforcement requests and court orders
• Regulatory compliance and ongoing legal disputes
• Enforcement of community guidelines
• Prevention of repeated harmful conduct
• Safety investigations

7.10 Subscriptions and External Accounts

Deleting a Wingmawo account does not automatically cancel subscriptions purchased via Apple App Store or Google Play Store. Users must cancel subscriptions directly via the respective app store platform.

7.11 Alternative Deletion Request

If access to the app is unavailable, deletion may be requested by emailing support@wingmawo.com with subject line: “Account Deletion Request – Wingmawo”. Requests are processed within 7 business days.

8. Your Rights

You have the right to:

• Access your Personal Data
• Request correction of inaccurate data
• Request deletion
• Withdraw consent at any time
• Request data portability
• Request human review of automated decisions
• Object to processing (where permitted)
• Lodge a complaint with the appropriate data protection authority

Requests may be sent to: support@wingmawo.com

9. Security Measures

We employ industry-standard administrative, technical, and organizational security measures designed to protect Personal Data against unauthorized access, alteration, disclosure, or destruction. Such measures may include encryption in transit, role-based access controls, and secure cloud infrastructure. Breach notification is provided as required by applicable law.

10. Admin Dashboard Access, Limitations & Safeguards

Wingmawo™ employs strict, multi-layered administrative controls to ensure user privacy and prevent unauthorized access.

• Role-Based Limited Access: Admins only see limited profile overviews required for moderation or technical support.
• Sensitive Data Masking: Private photos, chats, or content cannot be browsed freely.
• No Message Content Access: Affinity Grid does not monitor, read, store, or access the content of private messages at any time.
• Access Authorization: Detailed profile access requires prior approval from senior management or compliance officers.

11. Trademark & Brand Protection

Wingmawo™ and the Wing™ logo are trademarks of Affinity Grid Private Limited. Only notifications from the official header “AFGRPV” are valid and recognized.

13. Children & Age Restrictions

Wingmawo™ is strictly for users 18 years or older. Profiles identified as belonging to minors will be permanently removed.

14. Changes to this Policy

We may amend this Policy to comply with legal or operational updates. Significant changes will be notified via email, push notification, or in-app notice.

15. Contact & Data Protection Officer