Winkup Privacy Policy

This Privacy Policy explains how [Winkup] (referred to as "Winkup", "we", "us", or "our") collects, uses, stores, discloses, and otherwise processes your personal information when you access or use the Winkup mobile application, our website, and any related products, features, or services. These products, features, and services are collectively referred to as the "Services".

Winkup provides features such as social networking, instant messaging, livestreaming, party rooms, voice and video interactions, virtual gifts, virtual currency, and in-app purchases.

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. Where applicable law requires consent, we will separately request your consent.

Winkup is intended only for people who are at least 18 years old. Individuals under the age of 18 may not register for or use the Services.

1. Overview

This Privacy Policy explains:

Unless we provide a separate privacy notice for a specific feature, region, or data processing activity, this Privacy Policy applies to all users of the Services.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

If we make material changes, we will provide reasonable notice through the Services, by email, by prominent notice on the official website, or by other means required by applicable law.

The "Last Updated" date at the top of this Privacy Policy indicates when the latest revised version takes effect. If applicable law requires us to obtain your consent again, we will obtain your consent before implementing the relevant changes.

2. Who Is Responsible for Processing Your Personal Information

For the purposes of the General Data Protection Regulation (GDPR), the UK GDPR, and other similar data protection laws, the data controller responsible for processing your personal information is:

Privacy contact email: [mukhtarahmad188786@gmail.com]

3. Information We Collect

We may collect information directly from you, through your use of the Services, from other users, and from third-party service providers.

3.1 Information You Provide Voluntarily

A. Account and Profile Information

When you register for or use Winkup, you may need to provide:

You must provide true and accurate age information. Winkup prohibits individuals under the age of 18 from registering for or using the Services.

B. Photos, Audio, Video, and Other Media Materials

Depending on the features you use, we may process:

To provide communication services, voice and video data may be processed in real time. Such content may be stored where you voluntarily save or publicly publish it, enable recording features, where content moderation or safety review is required, or where retention is permitted by law.

C. Messages and Social Activity Information

We may collect or process records related to your activities within Winkup, including:

Private communication content will be used to provide messaging services to the recipients you choose. We may also process relevant communication information where reasonably necessary to prevent fraud, abuse, exploitation, illegal conduct, or threats to user safety.

D. Purchase and Transaction Information

When you purchase virtual currency, virtual gifts, subscriptions, or other digital products, we may receive:

Payments are usually processed by Apple App Store, Google Play, or other authorized payment service providers. In general, we do not receive or store your full bank card number or bank account login credentials.

Payment service providers will process your payment information in accordance with their own privacy policies and terms of service.

E. Customer Service and Communications Information

When you contact us, we may collect:

3.2 Information Collected Automatically

When you access or use Winkup, we and our service providers may automatically collect the following information.

A. Device and Technical Information

B. Usage and Log Information

"Browsing records" in this Privacy Policy generally refers to browsing and interaction records generated within Winkup or webpages operated by Winkup. Unless we separately explain otherwise and the relevant collection complies with legal requirements, we do not collect webpage browsing history unrelated to Winkup that you generate through ordinary browsers.

C. Network and Communication Quality Information

To provide real-time voice and video services, we may process:

D. Cookies and Similar Technologies

Our website, in-app webpages, and integrated SDKs may use:

These technologies may be used for authentication, security protection, anti-fraud, data analytics, advertising attribution, user preferences, performance measurement, and advertising where permitted by law.

Where applicable law requires it, we will obtain your consent before using non-essential cookies or similar technologies.

3.3 Information Obtained from Other Sources

We may obtain information from the following sources:

4. How We Use Your Personal Information

We use personal information for the following purposes.

4.1 Providing and Operating the Services

We process information to:

4.2 Safety, Risk Control, and Fraud Prevention

We process information to:

We may use automated tools, risk signals, and human review to identify potentially unsafe, fraudulent, abusive, or underage accounts.

4.3 Personalization and Recommendations

Where permitted by applicable law, we may use information to:

4.4 Data Analytics and Service Improvement

We may use information to:

Where reasonably practicable, analytics data will be aggregated, pseudonymized, or de-identified.

4.5 Marketing, Advertising, and Attribution

With necessary consent and in compliance with applicable law, we may use information to:

You may limit advertising tracking through device settings, app privacy settings, privacy choice pages, or by contacting us.

4.6 Legal Compliance

We may process personal information to:

5. Legal Bases for Processing Personal Information

Where the GDPR, UK GDPR, or other laws requiring a lawful basis for processing apply, we will process personal information based on one or more of the following legal bases.

Performance of a Contract

To perform our contract with you, we may process information to:

Consent

Where required by law, we will process information based on your consent, including:

You may withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of data processing activities completed before your withdrawal.

Legitimate Interests

We may process information based on the following legitimate interests:

When relying on legitimate interests to process information, we will assess whether those interests are limited or overridden by your privacy rights.

Legal Obligations

We will process relevant information where necessary to comply with legal, regulatory, tax, lawful request, child safety, and other binding legal obligations.

Protection of Vital Interests

In emergencies, we may process or disclose relevant information where reasonably necessary to protect someone's life, personal safety, or other vital interests.

6. Third-Party SDKs and Data Sharing

Winkup integrates third-party software development kits and technical services to provide functions such as instant messaging, voice communication, account login, data analytics, advertising measurement, and install attribution.

We will make reasonable efforts to configure third-party SDKs so that they collect only the information necessary to achieve the relevant purpose.

Where technically and legally permitted, we or our service providers may use the following SDKs:

SDK: RongCloud

Provider: RongCloud

Purpose of use: To provide real-time messaging functions and services.

Information collected: Device brand, device model, ANDROID_ID, operating system version, CPU information, memory usage, IP address, network access method and type, user ID under the App Key, application package name, time zone, language, app version number, app App Key, user token, RongCloud SDK version number, carrier code MNO, API call error codes, and connection failure error codes.

Privacy Policy: https://doc.rongcloud.cn/rcloud/-/-/privacy#%E4%B8%80-imlib-sdk

SDK: Agora

Provider: Agora

Purpose of use: Voice calls.

Information collected: Network type, user's local IP address, WLAN and cellular network signal status, operating system, device model, CPU, memory, device battery level, audio stream data, Bluetooth, network latency, packet loss rate, bitrate, resolution, audio bitrate, and sampling rate.

Privacy Policy: https://www.shengwang.cn/SDK-privacy-policy/

SDK: Facebook

Provider: Meta

Purpose of use: Facebook Event Manager.

Information collected: Please refer to https://www.facebook.com/privacy/policy/?section_id=1-WhatInformationDoWe.

Privacy Policy: https://www.facebook.com/privacy/policy/?section_id=0-WhatIsThePrivacy

SDK: Google

Provider: Google

Purpose of use: Login.

Information collected: OpenID.

Privacy Policy: https://policies.google.cn/privacy

SDK: Adjust

Provider: Adjust

Purpose of use: Install data attribution analysis.

Information collected: App activity, device identifiers, or other identifiers.

Privacy Policy: https://help.adjust.com/en/article/google-play-data-safety#data-collection-by-adjusts-sdk

We make every effort to provide security measures for users' personal information to prevent illegal use, unauthorized access, disclosure, leakage, damage, and loss of personal information. We will use all possible security measures within a reasonable level of security to ensure information security. For example, we will use encryption technologies such as SSL, anonymization, encrypted storage, and other means to protect your personal information; establish trusted protection mechanisms to prevent malicious attacks against personal information; establish access control mechanisms, follow the principle of minimum access, and ensure that only authorized personnel can access personal information; and conduct training courses on security and personal information protection to strengthen employees' understanding of personal information protection.

7. Device Permissions

Winkup may request the following device permissions. We will request permissions only when the relevant feature requires them. You can manage most permissions through device settings.

7.1 Album, Media, and Storage Permissions

Purposes of use:

Refusing this permission may prevent you from uploading or saving media content.

7.2 Microphone Permission

Purposes of use:

Winkup will not enable the microphone without the relevant system permission authorization. While the microphone is in use, your device system may display the corresponding permission-use indicator.

7.3 Camera Permission

Purposes of use:

Winkup will not enable the camera without the relevant system permission authorization.

7.4 Notification Permission

Purposes of use:

You can turn off notifications through device settings, but doing so may cause you to miss calls or messages.

7.5 Floating Window or Display Over Other Apps Permission

On Android devices that support this feature, Winkup may request floating window permission or permission to "display over other apps".

Purposes of use:

This permission is not mandatory, and you can disable it in Android system settings.

7.6 Device Identifiers and Advertising Identifiers

In compliance with platform rules, user consent requirements, and device settings, Winkup or its service providers may access:

Purposes of use:

Where applicable, access to IDFA will comply with Apple's App Tracking Transparency requirements.

7.7 Network Access and Network Status Permissions

Purposes of use:

Network information may include connection type, signal status, IP address, network latency, packet loss rate, and mobile network operator information.

7.8 Permission Choices

You can withdraw relevant permissions through device settings. However, some permissions, including microphone, camera, and network access, are necessary to use the corresponding Winkup features.

Withdrawing permissions will not automatically delete information that has already been collected. You may separately exercise your deletion right as described below.

8. How We Disclose Personal Information

We may disclose your personal information in the following circumstances.

8.1 Disclosure to Other Users and the Public

Information you voluntarily publish or share may be visible to other users or the public, including:

Messages, voice communications, and video communications will be disclosed to the recipients you choose.

You should not publish or transmit information that you do not want others to receive, record, copy, or further disseminate.

8.2 Service Providers and Data Processors

We may disclose information to vendors that provide the following services:

These service providers may process relevant information only for authorized purposes and in accordance with contractual or legal obligations.

8.3 App Stores and Payment Service Providers

We may exchange transaction information with Apple, Google, payment service providers, or financial institutions to:

8.4 Business Transactions

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, asset sale, or similar transaction, personal information may be disclosed as part of that transaction, subject to appropriate confidentiality and legal safeguards.

8.5 Legal Requirements and Law Enforcement Agencies

Where we reasonably believe it is necessary, we may preserve, access, or disclose information to:

We will assess the legal validity and scope of government and law enforcement requests. Where permitted by law, we will endeavor to disclose only the information reasonably necessary to respond to the relevant request.

Where permitted by law and necessary to prevent evidence from being deleted or lost, we may preserve relevant records before receiving formal legal process.

8.6 At Your Direction or with Your Consent

If you direct us to disclose information or have given valid consent, we may disclose information according to your direction or consent.

9. Sale and Sharing of Personal Information

We do not sell personal information to third parties for money without authorization.

However, under some privacy laws, disclosures of information related to advertising, promotion campaign measurement, advertising attribution, or data analytics may be considered a "sale", "sharing", "targeted advertising", or "cross-context behavioral advertising" of personal information even when no money is exchanged.

Depending on your region, device, consent choices, and our current technical configuration, device identifiers and app event information may be disclosed to service providers such as Meta and Adjust for promotion campaign attribution, data analytics, anti-fraud, or advertising effectiveness measurement.

Where required by law, you may opt out through:

In web interfaces that support this feature, we will recognize legally valid browser opt-out preference signals, such as Global Privacy Control, to the extent required by applicable law.

We do not knowingly sell or share personal information of individuals under the age of 18. Individuals under the age of 18 may not use Winkup.

10. California Privacy Notice

If the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies to our data processing activities, this section applies to California residents.

10.1 Categories of Personal Information

In the past 12 months, we may have collected the following categories of personal information:

We will retain each category of information only for the period reasonably necessary to achieve the purposes described above, and in accordance with the data retention provisions below.

10.2 Privacy Rights of California Residents

Subject to applicable exceptions, California residents may have the following rights:

To exercise these rights, please contact [mukhtarahmad188786@gmail.com].

We may ask you to provide information reasonably necessary to match your request with the relevant account in order to verify your identity. Where permitted by law, an authorized agent may submit a request on your behalf, but we may need to verify the agent's authorization and the user's identity.

We will respond to your request within the period required by applicable law.

11. Privacy Rights of Users in the European Economic Area, the United Kingdom, and Switzerland

Depending on your jurisdiction, you may have the following rights:

These rights may be subject to legal conditions, limitations, and exceptions.

To exercise relevant rights, please email [mukhtarahmad188786@gmail.com]. To verify your identity and protect your account, we may ask you to provide reasonably necessary information.

You also have the right to lodge a complaint with the supervisory authority where you live, where you work, or where you believe a data protection violation occurred.

12. Privacy Rights of Users in Other Regions

Residents of other jurisdictions may have additional rights, including:

We will respond to the rights you have under law based on your place of residence and the laws applicable to the relevant data processing activity.

We will not discriminate against you for exercising privacy rights protected by law.

13. Automated Processing, Safety Detection, and Recommendations

Winkup may use automated systems to:

Automated systems may analyze account information, device information, usage behavior, communication-related risk signals, report information, and transaction patterns.

Where required by law, you may request information about relevant automated processing or request human review of decisions that produce legal effects or similarly significant effects.

Unless such processing is permitted by law and appropriate safeguards are provided, Winkup does not intend to make decisions based solely on automated processing that produce legal effects or similarly significant effects for users.

14. Data Retention

We retain personal information only for as long as reasonably necessary to achieve the following purposes:

Specific retention periods depend on:

After the relevant retention period expires, information will be deleted, destroyed, or irreversibly anonymized.

Deleted information may continue to exist in encrypted backups for a limited backup cycle and will be isolated from daily use environments until overwritten, unless it can technically be deleted earlier or the law requires earlier deletion.

After account deletion, we may continue to retain limited records in the following circumstances:

Such retained information will be used only for the relevant purposes and will not be used for ordinary personalization recommendations or marketing.

15. Data Security

We use reasonable administrative, organizational, physical, and technical security measures to protect personal information.

These measures may include:

No system or method of data transmission can guarantee absolute security. We cannot guarantee that unauthorized access, data loss, misuse, or alteration will never occur.

If a personal data breach occurs and notification is required by law, we will notify affected individuals and competent authorities in accordance with applicable law.

You are responsible for protecting the confidentiality of your account login credentials. If you suspect that your account has been accessed without authorization, you should notify us immediately.

16. Cross-Border Data Transfers

Winkup and its service providers may process personal information outside the country or region where you live.

The data protection laws of these countries or regions may differ from those of your jurisdiction.

Where required by law, we will use appropriate safeguards for cross-border data transfers, including:

You may contact [mukhtarahmad188786@gmail.com] to request information about applicable cross-border transfer safeguards.

17. Account Deletion and Data Deletion

17.1 How to Delete Your Winkup Account

You can initiate account deletion within Winkup through the following path:

Me > Settings > Delete Account

When submitting an account deletion request, we may ask you to:

You may also request account deletion by sending an email to [mukhtarahmad188786@gmail.com].

Your request should include enough information for us to identify and verify the relevant account. Please do not send passwords or full bank card information by email.

17.2 Permanent and Irreversible Deletion

Account deletion is permanent and irreversible.

After account deletion is completed:

17.3 Loss of Virtual Currency and Virtual Assets

Deleting your account will permanently delete, clear, or be deemed an abandonment of all unused or remaining virtual assets in that account, including:

After account deletion, these virtual assets cannot be transferred, restored, redeemed, or refunded, except where applicable law or mandatory rules of Apple App Store, Google Play, or other authorized payment service providers expressly require a refund.

Before submitting an account deletion request, you should use eligible virtual assets and resolve all purchase or payment disputes.

17.4 Information That May Continue to Be Retained After Deletion

Account deletion may not delete:

Uninstalling Winkup from your device does not delete your Winkup account. You must use the in-app deletion path described above or another designated deletion method.

18. Minor Privacy and Minimum Age Requirement

Winkup is not intended for children or minors.

You must be at least 18 years old to:

Parents or legal guardians may not register accounts on behalf of persons under the age of 18, may not lend adult accounts to minors, and may not authorize minors to use Winkup.

The consent of a parent or guardian does not make an individual under the age of 18 eligible to use the Services.

We do not knowingly collect personal information from individuals under the age of 18. We may use automated systems, safety risk signals, user reports, and irregular human reviews to identify accounts that may belong to minors.

If we reasonably believe that a user is under the age of 18, we may:

If you are a parent, guardian, or another person who discovers that someone under the age of 18 is using Winkup, please contact us immediately at [mukhtarahmad188786@gmail.com].

Please provide the relevant username, user ID, profile link, or other information that can help us locate the account. Please do not provide unnecessary sensitive information about the minor.

19. Third-Party Websites and Services

The Services may contain links to third-party websites, applications, payment services, or social media platforms.

We cannot control third parties' privacy practices. How third parties collect and use information is governed by their own privacy policies.

You should review the relevant third party's privacy terms before providing information to or using third-party services.

20. Your Privacy Choices

You can control certain data processing activities through:

Turning off specific permissions or data processing activities may affect the availability or performance of some features.

21. Contact Us

If you have questions, complaints, or other issues regarding privacy matters, this Privacy Policy, data rights requests, or account deletion, please contact us through the following method:

App name: Winkup

Official contact email: [mukhtarahmad188786@gmail.com]

When sending an email, please use the subject line "Winkup Privacy Request" and provide enough information for us to identify the relevant account and understand your specific request.

Please do not send us your password, full bank card number, private key, or other authentication credentials that are not necessary to provide.

To verify your identity, prevent fraudulent requests, and protect your account, we may ask you to provide additional information. Such information will be used only for identity verification and request handling.

22. Language

This Privacy Policy may be provided in multiple language versions.

To the extent permitted by applicable law, if there is any conflict between the English version and a translated version, the English version shall prevail. This provision will not limit any mandatory rights granted to you by applicable local law.