Privacy Policy

Effective Date: 17 Jan. 2025

21ST Q LTD ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and share your personal information when you use our application, Wisp ("App"), and your rights regarding your data. By using the App, you agree to the practices outlined in this policy.

1. Information We Collect

A. Information You Provide

We collect the following information you provide directly:

• Name
• Phone number
• Gender
• Email address
• Birth date
• Profile photo
• Account settings and preferences
• Messages, photos, videos, and other content shared through the App
• Payment details and transaction history (processed via third-party providers)
• Sensitive data (optional): Sexual orientation, interests, health-related data, or other data shared voluntarily for specific features or personalization

B. Information Collected Automatically

When you use our App, we automatically collect:

• Device details (e.g., operating system, browser type, manufacturer, and model)
• IP address
• Device identifiers
• Language settings
• Mobile carrier information
• General location information (e.g., city, state, or geographic area)
• Precise geolocation data (if permission is granted)
• Usage data, including interactions with features, buttons clicked, and time spent in the App
• App crash reports, diagnostics, and performance metrics
• Advertising identifiers (if applicable)
• Technical data such as app settings, app crashes, cookies, and browser characteristics
• Biometric data (e.g., face geometry for verification features if permission is granted)

We may use cookies, web beacons, and similar technologies to enhance your experience and collect data about your interactions with the App.

2. How We Use Your Information

We use your information for the following purposes:

• Account Creation and Management: To create and manage your account.
• Personalization: To enhance your experience and provide tailored features, including conversation preferences and interaction history.
• Analytics: To monitor usage, improve our services, and analyze trends.
• Marketing and Advertising: To send promotional messages and display targeted advertisements (with user consent where required by law).
• Payments: To process transactions for premium features and manage rewards.
• Security: To prevent fraud, unauthorized access, and other illegal activities.
• Legal Compliance: To comply with applicable laws and respond to legal requests.
• Research and Development: To conduct surveys, focus groups, and market studies to improve the App.

3. How We Share Your Information

A. Service Providers

We may share your information with third-party service providers such as:

• Google Firebase: For data storage and security.
• PostHog, Sentry, and Crashlytics: For app analytics and debugging.
• Stripe: For payment processing.
• Mixpanel: For advanced analytics and user behavior tracking.
• Google Analytics: For website and app performance monitoring.
• AWS (Amazon Web Services): For cloud storage and server hosting.
• SendGrid: For email delivery and communications.
• Twilio: For phone and SMS communication services.
• Zendesk: For customer support and ticket management.
• Apple and Google: For account login and app-specific data syncing.
• Ad Networks: For targeted advertising based on anonymized user data.

B. Advertising Partners

We may share limited device and usage data with advertising partners to deliver targeted ads. However, we do not share messages, photos, or other personal content for advertising purposes.

C. Professional Advisors

We may share your data with professional advisors like lawyers, auditors, and insurers when necessary.

D. Legal Obligations

We may disclose your information to law enforcement or other authorities as required by law or to protect our rights.

E. Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the transaction.

4. Data Security

We use industry-standard measures to protect your data, including:

• Encryption of data in transit via HTTPS.
• Role-based access controls.
• Secure storage on protected servers.
• Regular security audits and testing.

While we strive to protect your data, no system can guarantee complete security. In the event of a breach, we will notify affected users promptly.

5. Data Retention

We retain your data for as long as necessary to provide the App’s services or comply with legal requirements. Specific retention periods include:

• Account Data: Retained until account deletion.
• Transaction Data: Retained as required for financial reporting.
• Usage Data: Retained for analytics and service improvement.

You can request deletion of your data by contacting us at info@getwisp.app.

6. Your Rights

Under applicable laws, you have the right to:

• Access your data.
• Request corrections to your data.
• Request deletion of your data.
• Withdraw consent for data processing.
• Opt out of targeted advertising and data sharing for marketing purposes.

To exercise these rights, contact us at info@getwisp.app.

7. Cookies and Tracking

We use cookies and similar tracking technologies to:

• Recognize your device and preferences.
• Analyze usage patterns.
• Deliver personalized content and ads.

You can manage or disable cookies through your device or browser settings.

8. Compliance with Laws

We comply with the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA/CPRA), and other applicable regulations. For users in the European Economic Area, we process data based on your consent or other lawful grounds.

9. Children’s Privacy

The App is not intended for users under the age of 13. If we discover that a child under 13 has provided personal information, we will delete it promptly.

10. Changes to This Privacy Policy

We may update this policy from time to time. Changes will be communicated through the App, and the "Effective Date" will reflect the most recent updates.

11. Contact Us

If you have any questions or concerns about this policy, contact us at:

• Email: info@getwisp.app
• Address: 6980 O Banno Drive, Las Vegas, Nevada, 89117

This Privacy Policy is designed to ensure transparency and compliance with legal standards, protecting both your rights and our responsibilities.