Privacy Policy

1.Introduction

Welcome to WINKY® — The First Hello™.

WINKY® ("Winky," "we," "us," or "our") is a mobile application owned and operated by Life on Queen Inc. that helps adults discover and communicate with other people nearby.

At Winky, we believe meaningful connections often begin with a simple hello. We also believe that starting that hello should not require giving up your privacy.

This Privacy Policy explains what personal information we collect, why we collect it, how we use and protect it, when it may be shared, and the choices available to you.

By creating a Winky account or using Winky, you acknowledge the practices described in this Privacy Policy.

2.Our Approach to Privacy

Privacy is an important part of the Winky experience.

Two principles are particularly important:

Your exact location is not displayed to other Winky users.

Your private Winky chat messages are protected by end-to-end encryption.

Winky uses location information to provide its nearby-discovery functionality. Other users may be shown that you are within a selected proximity or discovery range, but Winky does not display your exact GPS coordinates, street address or precise physical location to other users.

Private Winky chat messages are protected by end-to-end encryption. This means that the readable content of an encrypted message is available only to the participants in the conversation.

Winky, Life on Queen Inc., our developers, programmers, service administrators and hosting providers do not possess the encryption keys necessary to read the content of your end-to-end encrypted private chat messages.

Winky may, however, process limited technical information associated with communications, such as sender and recipient account identifiers, timestamps, delivery information, IP addresses or other communications metadata when necessary to transmit messages, operate the Service, maintain security or troubleshoot technical issues.

End-to-end encryption protects the content of your private chat messages. It does not necessarily prevent Winky from processing technical information associated with those communications.

3.Eligibility and Age Requirement

Winky is intended exclusively for adults who are 18 years of age or older.

You may not create an account or use Winky if you are under 18 years of age.

We do not knowingly permit anyone under 18 to use Winky or knowingly collect personal information from anyone under 18.

If we learn that an account belongs to a person under 18, we may immediately suspend or terminate the account and delete the associated personal information.

If you believe that a person under 18 is using Winky, please contact us using the information provided at the end of this Privacy Policy.

4.Information We Collect

We collect information necessary to create and operate your Winky account, provide Winky's nearby-discovery and communication features, maintain the security of the Service and improve Winky.

Depending on how you use Winky, this may include the following categories of information.

Account and Profile Information

When you create or maintain a Winky account, we may collect information such as:

mobile telephone number;
display name;
username, if you choose to create one;
profile photograph;
bio;
age or age range;
gender;
sign-in or authentication information; and
other profile information you choose to provide.

Your telephone number may be used for registration, authentication, verification, account security and account recovery.

Your telephone number is not displayed publicly on your Winky profile.

Certain profile information that you choose to provide may be visible to other Winky users according to Winky's features and your applicable settings.

Please do not include information in your profile or bio that you do not want other Winky users to see.

If you use the in-app Contact us form, we collect the email address, topic and message you submit. Your request is sent to info@winky.com and stored in Winky's database so we can respond and keep a support record.

5.Location and Proximity Information

Location information is necessary for Winky's nearby-discovery functionality.

With your permission, Winky processes and stores information about your device's location so that the Service can determine which other Winky users are within the applicable discovery range.

We may use location and proximity information to:

identify Winky users within a selected discovery range;
determine approximate proximity between users;
determine whether users are within one another's selected discovery ranges;
provide nearby-discovery functionality;
operate visibility controls;
maintain and improve location-based features;
prevent fraud, abuse or misuse of the Service; and
diagnose technical problems.

Your Exact Location Is Not Displayed

Winky does not display your exact GPS coordinates, street address or precise geographic location to other Winky users.

Instead, Winky uses your location to determine proximity and whether other users fall within the discovery range you select.

Winky may provide discovery ranges such as:

Closest — 75 ft
Nearby — 300 ft
Walkable — 1,000 ft
Area — ½ mile

These settings determine the geographic range within which Winky may help you discover or become visible to other users. They do not disclose your exact location to those users.

Location Permissions

Your device controls the location permissions available to Winky.

Depending on the permission you select, Winky may receive and process your location:

while you are actively using Winky; or
while Winky is operating in the background, if you have granted the applicable permission.

You may change Winky's location permission through your device settings.

If you disable location access, some or all of Winky's nearby-discovery functionality may no longer operate correctly.

Because a user's current location may change as the user moves, Winky may update stored location information in order to provide its proximity-based features.

6.Private Chat Messages and End-to-End Encryption

Private Winky chat messages are protected by end-to-end encryption.

Winky voice and video calls also use end-to-end encryption.

End-to-end encryption is designed so that only the participants in an encrypted conversation possess the ability to read the content of their messages.

Winky does not possess the encryption keys required to decrypt and read the content of private encrypted chat messages.

This means Winky, Life on Queen Inc., our developers, programmers, administrators and hosting providers cannot read the content of your end-to-end encrypted private chat messages.

Communications Metadata

Although Winky cannot read encrypted private message content, our systems may process and retain technical information necessary to provide the messaging service.

This may include:

sender and recipient account identifiers;
timestamps;
delivery status;
IP addresses;
device or application information;
technical routing information; and
other limited communications metadata necessary to operate, secure or troubleshoot the Service.

User Reports

If you report another user, you may voluntarily provide information, screenshots or other materials relating to that report.

Information voluntarily submitted to Winky as part of a report may be reviewed by us for safety, investigation, enforcement and support purposes.

Submitting information in a report does not give Winky general access to your other end-to-end encrypted conversations.

7.Photos, Camera and Media

With your permission, Winky may access your device's camera or photo library when necessary to allow you to:

create or change your profile photograph;
take photographs using supported Winky features;
select photographs or supported media from your device; or
share supported media through Winky.

Winky will request the applicable device permission where required.

You may change camera and photo permissions through your device settings.

8.Device, Usage and Technical Information

When you use Winky, we may automatically collect limited technical information necessary to operate, secure, diagnose and improve the Service.

This information may include:

device type;
operating system and version;
Winky application version;
Internet Protocol (IP) address;
unique or pseudonymous device identifiers;
language and regional settings;
application activity;
crash and diagnostic information;
security events;
date and time of access; and
information concerning the operation and performance of Winky features.

We may use this information to maintain the Service, correct errors, prevent abuse, protect security, understand application performance and improve Winky.

9.How We Use Personal Information

We may use personal information to:

create and administer your Winky account;
authenticate and verify your account;
provide nearby-discovery functionality;
determine proximity between users;
apply your visibility and discovery preferences;
allow users to communicate;
transmit end-to-end encrypted messages;
provide voice or video communication features where available;
display profile information you choose to make available;
provide customer support;
respond to reports, complaints and safety concerns;
enforce our Terms of Service;
detect, investigate and prevent fraud, abuse and security threats;
prevent previously banned users from creating new accounts or circumventing enforcement actions;
troubleshoot technical problems;
analyze and improve Winky's performance;
develop and improve Winky features;
comply with applicable legal obligations; and
protect Winky, our users and the public.

We will not use personal information for materially different purposes without providing appropriate notice and obtaining consent where required by applicable law.

10.Visibility and Your Choices

Winky provides controls that allow you to manage aspects of your visibility and profile.

Depending on the features available in your version of Winky, you may be able to control:

whether you are visible to nearby users;
your discovery distance or range;
your display name or username;
your profile photograph;
your bio;
other profile information; and
other privacy or visibility preferences.

Changing a visibility setting affects how Winky presents you to other users. It does not necessarily prevent Winky from processing information required to maintain your account, protect the Service or provide features you have enabled.

11.Service Providers

Winky uses third-party technology and service providers to help operate, maintain, secure and improve the Service.

Depending on the feature being used, these providers currently include services supplied by:

Amazon Web Services (AWS);
Amazon S3;
Amazon Simple Email Service (SES);
MongoDB Atlas;
Twilio;
Firebase Crashlytics;
Firebase Analytics;
Google Ads on-device conversion;
Google Sign-In; and
Apple.

These services may provide functions such as cloud infrastructure, data storage, communications, account authentication, analytics, crash reporting, advertising measurement and other technical services.

Third-party providers may process information necessary to perform their services for Winky and may have their own privacy and security obligations.

The use of third-party infrastructure does not provide those service providers with the encryption keys necessary to read the content of Winky's end-to-end encrypted private chat messages.

12.When We May Share Information

We do not sell the content of your private Winky communications.

We may disclose personal information as described in this Privacy Policy, with your consent, or where permitted or required by law.

Other Winky Users

Information that you choose to make visible through your Winky profile may be displayed to other Winky users.

Your exact GPS coordinates, street address and precise geographic location are not displayed to other Winky users.

Service Providers

We may provide information to third-party service providers when reasonably necessary for them to perform services on our behalf.

We expect service providers handling personal information on our behalf to use appropriate privacy and security safeguards and to process the information for the purposes for which it was provided.

Business Transactions

If Life on Queen Inc. is involved in a merger, acquisition, financing, restructuring, sale of assets or similar corporate transaction, information may be transferred as permitted by applicable law and subject to appropriate confidentiality and privacy protections.

13.Legal Requests and Protection of Users

We may preserve, use or disclose information when we reasonably believe that doing so is necessary or permitted to:

comply with applicable law, regulation, court order or lawful legal process;
respond to lawful requests from government or law-enforcement authorities;
investigate violations of our Terms of Service;
detect or prevent fraud, abuse or security threats;
protect the rights or property of Life on Queen Inc.;
protect the safety of Winky users or the public; or
establish, exercise or defend legal claims.

However, because private Winky chat messages are end-to-end encrypted, we cannot provide readable message content that we do not possess the encryption keys necessary to decrypt.

We may nevertheless be able or required to provide other account or technical information that is available to us when legally required.

14.We Do Not Sell Personal Information

Winky does not sell users' personal information in exchange for money.

We do not sell the content of private Winky communications.

If our practices materially change regarding how personal information is collected, used or disclosed, we will update this Privacy Policy and provide any additional notice or choices required by applicable law.

15.Data Security

The security of your information is important to us.

We use reasonable administrative, technical and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration or disclosure.

These safeguards may include encryption, access controls, authentication, cryptographic hashing and other technical measures designed to protect information and help prevent fraud, abuse and unauthorized access.

Private Winky chat messages receive the additional protection of end-to-end encryption.

However, no Internet service, electronic transmission or information-storage system can be guaranteed to be completely secure.

You are also responsible for taking reasonable steps to protect your device and Winky account from unauthorized access.

16.Data Retention

Winky retains personal information for as long as reasonably necessary to provide the Service, maintain your account, operate Winky's features, protect security, resolve disputes, enforce our agreements and comply with applicable legal obligations.

Because location is used to provide Winky's real-time proximity functionality, stored location information may be updated as a user's current location changes.

Different categories of technical and operational information may be retained for different periods according to the purpose for which the information is required.

When personal information is no longer reasonably required, we may delete, destroy or anonymize it, subject to applicable legal requirements and the limited security and enforcement exception described below.

17.Account Deletion and Ban-Prevention Information

You may delete your Winky account in the app by opening Profile, selecting Settings and tapping Delete account. Removing the app from your device alone does not delete your account.

When you delete your account, Winky deletes your account, profile, name, telephone number, email address, photograph and stored location history from its active systems. Messages and records of calls already sent to other users may remain in their conversation histories and appear as coming from a deleted user. Winky may retain a limited anonymous record to count accounts created and deleted and, for previously banned users, the ban-prevention identifier described below. Winky does not maintain an archive or backup copy of the deleted account data.

Previously Banned Accounts

If an account has previously been banned or permanently restricted for violating Winky's Terms of Service, safety rules or other applicable policies, Winky may retain a hashed identifier derived from the telephone number previously associated with that account.

The telephone number itself is not retained in readable form for this purpose. Instead, Winky's system uses a cryptographic process involving a secret key to generate a hashed identifier.

The retained hashed identifier is used solely for security, abuse prevention and enforcement purposes, including helping Winky identify attempts by previously banned users to create new accounts or circumvent a ban.

Winky does not use this retained hashed identifier to restore the deleted account or for marketing purposes.

Information that another person has independently saved outside of Winky—for example, a screenshot saved on another person's device—is outside Winky's control and cannot be deleted by Winky.

We may also retain information if and only to the extent retention is required by applicable law or a binding legal obligation.

18.Your Privacy Rights

Depending on where you live, applicable privacy laws may provide rights concerning your personal information.

These may include the right to:

request access to personal information we hold about you;
request correction of inaccurate information;
withdraw consent to certain collection, use or disclosure, subject to applicable legal or contractual restrictions;
request deletion of personal information where applicable;
ask questions about our privacy practices; and
make a complaint regarding our handling of personal information.

We may need to verify your identity before fulfilling certain privacy requests.

19.Consent and Device Permissions

Certain Winky features require access to information or device functionality.

For example, nearby discovery requires location information.

Where required, Winky will request the appropriate device permission or consent before accessing information.

Depending on your device and operating system, permissions may include:

location;
camera;
photographs or media;
microphone;
notifications; and
other permissions required by features you choose to use.

You may change device permissions through your device settings.

Withdrawing a permission may cause Winky features that depend on that permission to stop functioning.

20.International Processing and Storage

Winky uses third-party service providers and technical infrastructure that may process or store information in Canada, the United States or other jurisdictions.

As a result, personal information may be processed or stored outside the province, state or country where you live.

Information processed in another jurisdiction may be subject to the laws of that jurisdiction and may be accessible to courts, law-enforcement agencies or governmental authorities in accordance with applicable law.

We take reasonable steps designed to ensure that personal information processed on our behalf receives appropriate privacy and security protection.

21.Third-Party Services

Winky may contain links to or integrate with third-party services.

Those third parties may have their own privacy policies and information-handling practices.

This Privacy Policy applies to information processed by Winky and Life on Queen Inc. It does not govern the independent practices of third parties when they process information for their own purposes.

We encourage users to review the privacy policies of third-party services they choose to use.

22.Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to Winky, our information practices, technology, legal requirements or other circumstances.

When we update this Privacy Policy, we will revise the Last Updated date at the beginning of the Policy.

If a change materially affects how we collect, use or disclose personal information, we will provide additional notice and obtain consent where required by applicable law.

We encourage you to review this Privacy Policy periodically.

23.Privacy Accountability

Life on Queen Inc. is responsible for personal information under its control and for maintaining appropriate privacy practices concerning Winky.

Questions, requests or complaints regarding Winky's handling of personal information may be directed to our Privacy Officer using the contact information below.

24.Contact Us

If you have questions about this Privacy Policy, Winky's privacy practices or personal information associated with your account, please contact:

Life on Queen Inc.
WINKY® — The First Hello™
Toronto, Ontario, Canada

Privacy Officer
Email: info@winky.com

You may also contact us to request access to or correction of personal information, exercise an applicable privacy right, or raise a concern about Winky's privacy practices.