Privacy Policy

Winkly — Privacy Policy

Last updated: 7 June 2026

Winkly Technologies UG (haftungsbeschränkt) (“we”, “us”, “Winkly”) respects your privacy. This Privacy Policy explains what personal data we collect, how we use it, and your rights. It applies to the Winkly mobile application and related services (“Service”).

If you are in the European Economic Area (EEA) or the United Kingdom, we process your data in accordance with the General Data Protection Regulation (GDPR) and UK GDPR. We also consider applicable international standards.

1. Data controller and contact

Data controller:
Winkly Technologies UG (haftungsbeschränkt)
[Registered street address — update legal-entity.json before launch]
[PLZ] [City], Germany

Contact:
For privacy requests and questions: use General settings → Support & legal → Contact Support in the app, or email customer-care@mywinkly.de (or the address shown in the app).

2. What personal data we collect

2.1 Account and identity

• Email address — When you sign up or use “Sign in with” (e.g. Google, Apple, Facebook).
• User ID — A unique identifier for your account (UUID).
• Account type — Personal or Business, as chosen at sign-up.
• Subscription status — Whether you use free or paid features (e.g. Super, Premium).

2.2 Profile information

Depending on your account type and which parts of the app you use:

• Personal profiles: Name, gender, date of birth, city, education, occupation, languages, bio, photos, interests, lifestyle and preference details (e.g. for Romance, Friends, or Business mode), and optional links such as Instagram.
• Business profiles: Business name, location, bio, tags, website, social links (e.g. Instagram, LinkedIn), and logo.

You choose what to add; we store what you provide to show your profile to other users and to power features (e.g. discovery, matching, AI suggestions).

2.3 Communications and content

• Messages — Text, images, and other content you send in chats (direct, group, event).
• Planner data — Titles, descriptions, dates, locations, and participants for your plans (dates, meetups, meetings, events).
• Events — Event details you create or join (title, description, location, participants, RSVPs).

2.4 Technical and usage data

• Session and auth data — Stored so you stay logged in (e.g. on your device and on our servers).
• Analytics — We use analytics (e.g. PostHog) to understand how the app is used. We do not send your name, email, or message content. We may send a user ID, account type, screen paths, and event names (e.g. “discover_open”, “recommendation_like”) to improve the product. You can use the app with analytics disabled if we offer that option, or we may rely on legitimate interest where the law allows.
• AI usage — When you use Winkly AI, we send only allowlisted information (e.g. mode, city, date range, activity hints, and a short summary of your and your partner’s profile for suggestions). We do not use your full chat history to train external AI models. We may store that you used a feature (e.g. user ID, mode, task type) for security and product improvement.

2.5 Device and permissions

• Location — If you grant permission, we use it for features such as city/discovery and event locations. Your location is approximated before it is stored (your precise GPS position is never saved), and you can choose Approximate or Precise precision in Privacy & Safety → Location precision. Other users only ever see a rounded distance, never your coordinates. You can revoke permission in your device settings.
• Photos / camera — Used only when you choose to add or change profile or event photos.
• Contacts — Only if you choose to use “find contacts on Winkly” and grant permission. Your contacts are hashed on your device (SHA-256 of email/phone) before anything is sent; we use only those hashed identifiers to find existing Winkly users and we do not store your contact list.

We do not sell your personal data.

3. Why we use your data (purposes and legal basis)

Where we rely on legitimate interest, we have balanced our interests against your rights. You can object where applicable (see “Your rights” below). Where local law requires consent for certain processing (e.g. analytics or marketing), we will obtain it before doing so.

4. Who we share data with

• Other users — Your profile and content are visible according to the settings and mode (Romance, Friends, Business, Events) you use.
• Service providers — We use providers that help us run the Service (e.g. hosting, auth, analytics, AI, payments). They process data only on our instructions and for the purposes we specify. We choose providers that meet applicable data protection requirements.
• Legal — We may disclose data if required by law, court order, or to protect our or others’ rights and safety.
• We do not sell your personal data to third parties.

5. International transfers

Our main systems may be in the European Union or in other countries (e.g. United States). When we transfer data outside the EEA or UK, we ensure appropriate safeguards are in place, such as:

• Commission adequacy decisions, or
• Standard Contractual Clauses (SCCs) or equivalent mechanisms approved by the relevant authorities.

Details of transfer mechanisms are available on request (contact details in section 1).

6. How long we keep your data

• Active account — We keep your data while your account is active and as long as needed to provide the Service and comply with law.
• After account deletion — When you ask us to delete your account, we will delete or anonymise your personal data within a reasonable period (e.g. 30 days), except where we must keep it for legal, safety, or dispute-resolution reasons.
• Messages and content — Generally deleted or anonymised with the account; in some cases we may retain limited data for a longer period if required by law or for legitimate purposes (e.g. abuse reports).

7. Security

We use technical and organisational measures to protect your data, including:

• Access control (e.g. Row Level Security so you can only access your own data),
• Encrypted connections (HTTPS/TLS),
• Secure storage of authentication and sensitive data,
• Restricting access to personal data to those who need it to operate the Service.

No system is completely secure; we will notify you and the relevant authorities if a breach is likely to affect your rights, as required by law.

8. Your rights

If you are in the EEA or UK, you have the following rights in relation to your personal data:

To exercise these rights, contact us using the details in section 1. We will respond within the time required by applicable law (e.g. one month under GDPR). You can also delete your account via the app (e.g. General settings → Account) to request deletion of your data, subject to our retention obligations.

If you are in California or another jurisdiction with similar rights: we do not sell personal data. You may have the right to know, delete, or correct your data and to non-discrimination; contact us to exercise these rights.

9. Children

The Service is not intended for users under 18 (or under the age of majority in your country). We do not knowingly collect data from children. If you believe we have collected data from a child, please contact us so we can delete it.

10. Changes to this policy

We may update this Privacy Policy from time to time. We will post the updated version (e.g. on our website or in the app) and update the “Last updated” date. If changes are significant, we will provide additional notice (e.g. in-app or by email) where practicable. We encourage you to review this policy periodically.

11. Cookies and similar technologies

Winkly is primarily a mobile app. We do not use advertising cookies and we do not sell your personal data.

11.1 What we use

11.2 Your choices

• On first use, you can accept or decline non-essential analytics as described in our cookie notice in the app.
• You can review Privacy Policy, Cookies, and related settings at any time under General settings → Support & legal → Legal.
• You may withdraw consent for analytics by contacting us or, where available, through in-app privacy settings.

11.3 Website

If you visit mywinkly.de, our hosting provider may process standard server logs (e.g. IP address, browser type) for security and operation. We do not use third-party advertising trackers on our legal pages.

For more on analytics data, see section 2.4 above. For legal entity details, see our Imprint.

12. Contact

For any privacy-related questions or to exercise your rights:

• In the app: General settings → Support & legal → Contact Support
• Email: customer-care@mywinkly.de (or the address shown in the app)

By using Winkly, you confirm that you have read and understood this Privacy Policy. For the terms governing your use of the Service, see our Terms of Service.