WivMe — Privacy Policy

Last updated: 13 September 2026

Policy version: 13 September 2026

1 Introduction

This Privacy Policy is provided by WivMe Limited, a company registered in England and Wales under company number 17381225 with registered office at 124 City Road, London, United Kingdom, EC1V 2NX ('we', 'our' or 'us') for the use of our products and services, which include our platform, user profiles, direct messaging, and group chats (Services).

References to our Services include our website, web app and mobile applications for iOS and Android.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).

It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

2 What this policy applies to

This privacy policy relates to your use of the Services only.

The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.

3 Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:

Category of data	In more detail
Identity and account data you input into the Services Registration is mandatory in order to use the Services	The following personal information will be collected and stored securely:; Full name; Email address; Password (secured through encryption); Date of birth; Account preferences and settings; Where you choose Google Sign-In, the name, email address and profile image made available by Google
Data collected when you use specific functions in the Services	Data you store online with us using the Services including:; Profile Data; Profile photograph; Biography; Interests; Gender (if provided); Location information you choose or enter; User preferences; Activity Data; Activities you post; Applications to activities; Check-ins; Participation records; Activity-related content; Communications and Safety Data; Direct messages; Group chat messages; Safety and moderation reports, flags and related decisions; Communications with support; Verification Data; Your mobile telephone number and an age-estimation selfie/face image are provided directly to our verification provider, Didit, for verification and age-estimation purposes; WivMe receives and retains verification session identifiers, status/decision information, verified/age-pass flags and a salted reference derived from the mobile telephone number; WivMe does not retain the readable mobile telephone number or age-estimation selfie; Credit and Payment Data; Credit purchases, balances, earned credits and credit usage history; Credit restoration requests; Payment, store and transaction references and purchase records, including Stripe references for web purchases and RevenueCat/Google Play purchase identifiers for Android purchases; WivMe does not receive or store your full payment card details; Marketing Website Form Data; Name, email address and any other information you choose to submit through forms on our marketing website
Other data the Services collects automatically when you use it	Your activities on, and use of, the Services which reveal your preferences, interests or manner of use of the Services and the times of use.; Technical and device information may also be processed when you use the Services, including IP address, browser/device information, push notification tokens and security or anti-bot signals.

If you do not provide personal data we ask for where it is required, it may prevent us from providing services and/or the Services to you.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

4 Sensitive Data

Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.

Please note that we do not knowingly or intentionally collect sensitive personal data or information about criminal convictions from individuals and that you should not submit sensitive data to us.

If, however you do submit sensitive data to us, such as if you make this sensitive data available to other users of the Services (such as by publishing it through any forum feature we may make available from time to time) we will assume that you have purposefully made any such sensitive data manifestly public.

5 How your personal data is collected

We collect personal data from you directly when you sign up to the Services, contact us directly or reach out to us via social media, make submissions through the Services, submit forms on our marketing website, or otherwise interact with the Services. We also receive or process personal data through service providers that support the Services, including sign-in, verification and age-estimation, payment and app-store purchases, content moderation, security, notifications and place-search functionality. For example, if you choose Google Sign-In, Google provides relevant account details to us; if you complete verification, Didit processes the information you provide through its hosted verification flow and returns verification results to WivMe.

We may collect personal information about you using cookies or similar technologies. Please refer to our Cookies Policy for details about the cookies and similar technologies we use and how you can control them.

6 How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

where you have given consent
to comply with our legal and regulatory obligations
for the performance of a contract with you or to take steps at your request before entering into a contract, or
for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Create and manage your account with us	To perform our contract with you or to take steps at your request before entering into a contract
Providing services and/or the functionalities of the Services to you	Depending on the circumstances:; to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services)
To enforce legal rights or defend or undertake legal proceedings	Depending on the circumstances:; to comply with our legal and regulatory obligations; in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others
Communications with you not related to marketing, including about changes to our terms or policies or changes to the Services or service or other important notices	Depending on the circumstances:; to comply with our legal and regulatory obligations; in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you
Protect the security of systems and data	To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Operational reasons, such as improving efficiency, training, and quality control or to provide support to you	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you
Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app
Updating and enhancing user records	Depending on the circumstances:; to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services); to comply with our legal and regulatory obligations; where neither of the above apply, for our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services
To comply with our legal and regulatory obligations	Depending on the circumstances:; to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services); to comply with our legal and regulatory obligations; where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services
Send service communications and notifications, including transactional email and push notifications about your account, plans, messages or safety-related matters	Depending on the circumstances: to perform our contract with you; to comply with our legal and regulatory obligations; and/or for our legitimate interests in providing and supporting the Services.
Process credit purchases, maintain credit balances and transaction records, and administer refunds or restorations where applicable	Depending on the circumstances: to perform our contract with you; to comply with our legal, tax and accounting obligations; and/or for our legitimate interests in administering payments and preventing fraud.
Moderate user-generated content, investigate reports, enforce our Terms and Community Guidelines, and protect member safety	Depending on the circumstances: to comply with our legal and regulatory obligations; to perform our contract with you; and/or for our legitimate interests or those of a third party, including preventing abuse, harmful content and misuse of the Services.
Verify that members meet our eligibility requirements, including the 18+ requirement, and help prevent duplicate or abusive accounts	Depending on the circumstances: to perform our contract with you; to comply with our legal and regulatory obligations; and/or for our legitimate interests or those of a third party, including protecting members and the integrity of the Services.
To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency.; In such cases information will be anonymised where possible and only shared where necessary	Depending on the circumstances:; to comply with our legal and regulatory obligations; in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

7 Who we share your personal data with

We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services.

We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us. These providers include hosting, cloud and database providers; website hosting and form providers; identity and age-verification providers; payment and app-store providers; content moderation and safety providers; security and anti-bot providers; place-search providers; sign-in and notification providers; and transactional email providers. Current providers include Lovable, Supabase, Netlify, MailerLite, Didit, Stripe, RevenueCat, Google, OpenAI, Sightengine, Cloudflare and Geoapify. Not every provider receives every category of personal data.

We or the third parties mentioned above may occasionally also need to share your personal data with:

external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

We will not share your personal data with third parties except as described in this privacy policy or where required or permitted by law.

8 How long your personal data will be kept

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including to provide the Services and to satisfy legal, regulatory, accounting, safety, fraud-prevention and reporting requirements. When you permanently delete your account, ordinary account and profile information and associated user content are deleted or anonymised through our account-deletion process, subject to information we are required or permitted to retain.

We retain certain payment, credit, points and transaction records for up to 6 years where required for accounting, tax, legal or dispute-resolution purposes. We may also retain certain safety, moderation and abuse-prevention records, including reports made about an account, for as long as reasonably necessary to protect members, prevent misuse, investigate complaints, establish or defend legal claims, or comply with legal obligations. Where data is no longer required, we will delete or anonymise it.

9 DE-IDENTIFIED INFORMATION

The personal data we collect may have analytical, educational, or commercial value to us. Where we have de-identified the information we have collected, we reserve the right to process and distribute such information.

10 AUTOMATED DECISION-MAKING

We may use automated systems to identify potentially harmful, fraudulent, unlawful or prohibited content and behaviour, and to support verification of whether members meet the 18+ eligibility requirement.

Automated moderation systems may generate warnings, detect suspicious activity, score or flag content for review, or temporarily restrict certain functionality. Our verification provider, Didit, uses age-estimation technology as part of the verification process and returns a verification outcome to WivMe.

Decisions to suspend or terminate an account for moderation or conduct reasons are not made solely by automated means and involve human review. Verification and age-estimation outcomes may affect access to participatory features of the Services.

11 Transferring your personal data out of the UK

As part of providing the Services, we may share or make personal data available to service providers that process data outside the UK, including in the EEA, the United States and other locations. These include;

Lovable and Supabase, which provide application hosting, cloud infrastructure, database, authentication, storage and transactional email services;
Netlify and MailerLite, which support the marketing website and the storage of details submitted through marketing website forms (MailerLite is not currently used by WivMe to send marketing communications);
Didit, which provides mobile verification and 18+ age-estimation services;
OpenAI and Sightengine, which provide automated content and image safety/moderation services;
RevenueCat and Google, which support native app purchases, Google Play Billing, Google Sign-In and Firebase Cloud Messaging; and
Cloudflare, Geoapify and Stripe, which support anti-bot/security checks, UK place search and web payment processing respectively, together with other technology providers used to operate the Services.

Additionally, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:

The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
Any country located outside the UK/EEA: we would rely on appropriate safeguards under the UK GDPR, such as by relying on an Adequacy Decision being in place for that country, or entering into an International Data Transfer Agreement.

In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.

12 Your rights

You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.

Right	What it means
Access to a copy of your personal data	The right to be provided with a copy of your personal data.
Correction (also known as rectification)	The right to require us to correct any mistakes in your personal data.
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data—in certain situations.
Restriction of use	The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
To object to use	The right to object:; at any time to your personal data being used for direct marketing (including profiling); in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests.
Not to be subject to decisions without human involvement	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you, subject to the exceptions provided by applicable data protection law.; Where this right applies, you may also have rights to obtain human intervention, express your point of view and challenge the decision. Please see the section “Automated decision-making” above.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please complete a request by email, call or write to us using the contact details below. When contacting us please:

provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
let us know which right(s) you want to exercise and the information to which your request relates

13 Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

14 How to complain

Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner.

The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

15 Changes to this privacy policy

We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Services or by other means, such as email.

16 How to contact us

For further information about our privacy policy or practices, or to access or correct your personal data, or make a complaint, please contact us using the details set out below:

Name: WivMe Privacy Team

Email: privacy@wivme.app