Privacy Policy

Wink is developed by Euphorica, Inc. This Privacy Policy applies to the Wink family of services, including Wink and Wink Social (collectively, the "Wink Platform").

To avoid confusion, we refer to Wink as the relevant entity throughout this policy. However, Euphorica, Inc. is the business that collects and stores your information. Wink Platform and Euphorica, Inc. knows that you take your privacy seriously. Your data and privacy is important to us and our affiliated companies (collectively, “Wink”, “us”, “our”, or “we”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share data from or about individuals who use the Wink or Wink Social (each, an “app”) or visit our website at www.getwinkapp.com (collectively, the “Services”) to make friends online. By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service and Community Guidelines.


Information we collect

We collect a variety of information from or about you or your devices from various sources, as described below.


Information you give us directly:

  • Registration information. When you sign up to use a Wink Platform, you provide us with basic information like your email, phone number, name, age, country, and gender etc.
  • Profile information. When you create a profile on a Wink Platform, you provide us with information such as profile pictures, name (first and/or last), and any other information you choose to provide.
  • Please see the “Other users” section under “HOW IS INFORMATION SHARED” below for important details about how your profile information is viewable by other users.
  • Content. When you through the Wink Platform send or receive a message, participate in a video chat or provide audio visual content via your device or camera, we collect the contents of the message, any attachments to the message (including, for example, voice messages, audio and video content and photos), and information about the message (such as who you are communicating with).
  • Wink communications. When you reach out to us (through, for example, an in-app report or email, we collect and store the contents and details of that communication, including things like date, time, method of communication, and resolution (if applicable).
  • Polls, surveys, and questionnaires. When you voluntarily respond to polls, surveys, and questionnaires, we receive the contents of your responses and any other information you provide, such as your address and basic demographic information.

Information we collect when you use our Services:

  • Log and data usage information. We collect information about your activity on the Wink Platform and how you use the Services, such as the date and time you send a message, who you chat with, your internet protocol ("IP") address, and how you use third-party websites or services accessed through the app.
  • Device and browser information. We collect information from and about the device you use to access our Services, which may include information like your hardware model, operating system version, device model and/or carrier, web browser type and settings, push notification tokens, advertising identifiers (e.g. Apple IDFA or Google Advertising ID), unique device identifiers, and mobile network information, as well as information you’ve shared with us through device settings, like GPS location, camera access, photos and related metadata.
  • Location information. We use your IP address to infer your general location when you use the Services.
  • Information collected from cookies and similar technologies. We and our third party partners, such as advertising partners, may collect information through the use of cookies and similar technologies like web beacons. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.
  • Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.
  • Information we collect when you use our Services:
  • Information from third parties. We may receive information about you from third parties, including third parties that integrate with the Services or that provide services to us. This may include information such as log and data usage information collected from our Services or other online services, device and browser information, location information, and information collected through cookies or other similar technologies. We may combine this information with demographic and other interest-based segment information we receive from third parties.
  • Information from third party services. If you created your account using a third party account, such as your Google account, we may receive certain information about you from these third parties such as your first name, last name, and profile picture. If you wish to limit the information we receive, you should visit the privacy settings of your third party accounts to learn about your options.

How we use information

We use the information we collect to:

Provide, maintain, improve, and enhance the Services. We use information we collect about you to provide the Services you request from us and to provide the functionality of the app and the features you choose to use. For example, we use the information we collect to facilitate your use of the Wink Platform’s features, to allow you to connect with other users, to deliver your messages, to provide the ability to make voice and video calls and connect with others, and to display your intended themes and profile images. We also use your information to register you and display your profile on new Wink features and apps.

Personalize your experience on the Services. For example, we use the information we collect to personalize content and make suggestions that are relevant to you.

Understand and analyze how you use the Services. We aim to continuously improve our offerings to bring you the best way to make meaningful connections. Accordingly, we are continuously analyzing how users access and use the app and its features in order to improve existing Services and develop new ones. Our analysis of how you use the Wink Platform can help us do things like evaluate the popularity and functionality of certain features, identify and fix potential bugs, and understand what our users want.

Communicate with you. The information we collect lets us respond to your comments and questions or otherwise provide customer support, and keep you updated on other information such as Wink Platform’s latest product announcements, software updates, and upcoming events.

Enable social functionality. We use the information we collect to support the social functionality of the Services, including to allow you to post content on third party services, such as social media networks.

Promote safety and security. We also use information to find and prevent fraud and promote trust and safety on the Services. For example, we may scan your messages for inappropriate content to protect the safety and integrity of our Services and our users.

Compliance purposes. We may use the information we collect to enforce our Terms of Service, Community Guidelines, and other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

Send you push notifications. We may use the information we collect to send you push notifications.

Other purposes. We may also use the information we collect for other purposes for which we provide notice at the time the information is collected. We will not use Verification Data for any materially different purpose without first obtaining any additional consent required by applicable law.

Photo Verification and Biometric Data. If you choose to verify your profile, we may ask you to complete a live video verification process using your device camera. During this process, you may be asked to position your face within the camera frame and follow on-screen instructions so that we can confirm that you are a real, live person and that the person completing verification appears to match the person shown in your profile photos.

When you complete Photo Verification, we and our service providers may collect and process images, video frames, and related verification data from the live video verification process, and may use facial scanning technology to detect a face and create a scan of facial geometry or similar biometric identifier derived from that content (“Verification Data”). Verification Data may be considered biometric information or a biometric identifier in some jurisdictions.

Your live verification video, images, or frames are not posted to your profile and are not visible to other users.

We use Verification Data only to provide, maintain, troubleshoot, and secure the Photo Verification feature, including to verify your profile and help prevent fraud, impersonation, and misuse of the Services.


We use third-party providers, including Hive and AWS Rekognition, to help perform Photo Verification. These providers are permitted to process Verification Data only as necessary to provide the verification service to us and must not use Verification Data for their own advertising, profiling, resale, or model-training purposes.


We ask for your explicit consent before collecting or processing Verification Data. Photo Verification is optional.


Your face scan, live verification video, images, frames, and other biometric Verification Data are deleted within 3 days after the Photo Verification process is completed or no longer needed for that process, including deletion by our verification service providers. We may retain non-biometric verification results, such as whether verification succeeded or failed, for as long as reasonably necessary to maintain the integrity, safety, and security of the Services, comply with legal obligations, resolve disputes, enforce our Terms, and prevent fraud or abuse.


We do not sell, lease, trade, or use Verification Data for advertising, profiling, or training artificial intelligence models. We do not “sell” or “share” Verification Data as those terms are defined under applicable U.S. state privacy laws.


We will not collect, store, or use your Verification Data for any purpose other than Photo Verification, fraud prevention, impersonation prevention, safety, security, and legal compliance without first obtaining any additional consent required by applicable law. Residents of Illinois, Texas, Washington, and other jurisdictions with biometric-specific laws may have additional rights under those laws; contact support@euphorica.ai with questions.


HOW IS INFORMATION SHARED

  • Other users. The Wink Platform is a social service intended to help you make new friends and interact with them. Please be aware that your profile information will always be viewable by other users. You may edit your profile information within the Wink Platform through your profile settings. We are not responsible for other users’ use of available information, so you should carefully consider whether and what to include in your profile or otherwise share through the Services. We also share your information if you ask us to. For example, we send the messages and other content you ask us to send to other users either directly or within a group chat. Please be aware that anyone you send a message to will have their own copy of the message and any content attached to that message. Therefore, even if you delete your copy of the message from your account, they may duplicate, store, or reshare at their own discretion.
  • Social networks. Our services allow you to share information with social networking services, such as Instagram. You understand and agree that the use of your information by any social networking websites will be governed by the privacy policies of these third party platforms and your settings on that platform. We encourage you to review their privacy policies before sharing any information with them.
  • Third party integrations. Certain features you use through Wink are offered by third parties such as logging in with Google. Those features may include things such as GIFs, emojis, smileys, web pages optimized for the Wink Platform, etc. When you choose to use these third-party features, or other services that use, or are integrated with, our Services, those third parties (and other users of those third party services) may be able to see things like your user profile and receive information about what you post or share. These third parties may use this information as described in their privacy policies, which can include advertising. You understand and agree that the use of your information by these third parties will be governed by the privacy policies of these third party platforms and your settings on that platform. We encourage you to review their privacy policies before sharing any information with them.
  • Our service providers. We share the information we collect with third-party service providers that help operate our business. Examples include suppliers who host our data, provide customer service, support safety and security, or help provide identity-verification and Photo Verification services. Where service providers process Verification Data, they are permitted to process it only as necessary to provide services to us and must not use it for their own advertising, profiling, resale, or model-training purposes.
  • Our related companies. We may share your information with affiliated companies strictly for operational purposes — such as shared login functionality, cross-platform moderation, and analytics.
  • Other Wink Platform. In furtherance of servicing and operating the Wink Platform, your registration and account information and associated data will be shared and available across all Wink products that you are eligible to access, including Wink and Wink Social.
  • To protect Wink and its users, or for legal purposes. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) detect, prevent or address fraud or other illegal activity (b) respond to your requests; (c) comply with law enforcement requests and legal process, such as subpoenas, warrants, production orders, or similar instruments; or (d) protect your, our, or others’ rights, property, or safety, including when there is an emergency involving potential harm, loss of security or serious injury to people or threats of such emergencies. For the avoidance of doubt, we may disclose your information if you post any objectionable content on or through the Services.
  • Merger, financing or sale. We may share your information with service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a merger, financing, acquisition, dissolution transaction, bankruptcy or proceeding involving the sale, transfer, or divestiture of all or a portion of our business or assets. Verification Data is not sold, leased, traded, or used for advertising, profiling, or model training, and any disclosure or transfer of Verification Data in connection with a corporate transaction will be limited to what is permitted by applicable law and subject to appropriate confidentiality, security, and use restrictions.
  • Consent. We may also share your information with your permission.

User Controls

  • Update your information. You can update your profile information through the Wink Platform settings.
  • Delete your account. You may deactivate or terminate your account at any time, for any or no reason, by accessing the settings page of your account or by contacting us. For account deletion please contact us via support@euphorica.ai, and we will provide you with further assistance and guide you through the process. Once you choose to delete your account, you will not be able to reactivate your account or retrieve any of the User Content or information you have added.
  • Photo Verification Data. If you complete Photo Verification, your face scan, live verification video, images, frames, and other biometric Verification Data are deleted as described in the “Photo Verification and Biometric Data” section above. If you delete your account, any remaining Verification Data will be deleted in accordance with that section, unless continued retention is required or permitted by applicable law for safety, security, fraud prevention, dispute resolution, enforcement of our Terms, or legal compliance. We may retain a non-biometric verification result, such as whether verification succeeded or failed, for as long as reasonably necessary to maintain the integrity, safety, and security of the Services, comply with legal obligations, resolve disputes, enforce our Terms, and prevent fraud or abuse.
  • Blocking and reporting users. You can block users or report users who are engaging in harmful or offensive conduct to us through the controls provided in the Wink Platform.
  • Marketing and promotional communications. You may unsubscribe from emails in the footer of any marketing or promotional email. Please note that even if you opt-out of receiving marketing or promotional messages from us, you will continue to receive administrative messages from us.

SECURITY OF YOUR INFORMATION

We make reasonable efforts to protect your information by using safeguards designed to improve the security of the information we maintain. We apply appropriate technical and organizational safeguards designed to protect Verification Data, including limiting access to personnel and service providers who need it to provide, secure, troubleshoot, or support the Photo Verification feature. Despite these efforts, you should know that we cannot guarantee the privacy or security of your information because we cannot fully eliminate the security risks associated with online transmissions.

INTERNATIONAL USERS

The Wink Platform and all of our data, including your Data, are hosted on servers in the United States. If you are using or accessing the Services from outside of the United States, your Data will be transferred to, processed and stored in the United States. As a result, United States federal and state governments, courts, or law enforcement or regulatory agencies may be able to obtain your Data through laws applicable in the United States. United States laws may not offer the same privacy protections as the law of your jurisdiction. Personal information collected in the EU may be transferred to, and stored at, a destination outside of the EU and processed by employees operating outside of the EU who work for us, one of our business partners, or service providers. We rely on the European Commission’s updated Standard Contractual Clauses (2021/914) and conduct Transfer Impact Assessments (TIAs) to ensure compliance with GDPR when transferring personal data from the EU. Where required, we obtain user consent for such transfers. When we transfer personal information across country borders, we will make sure there is a transfer mechanism in place to transfer the data in a manner consistent with that described in this Privacy Policy. For citizens of the European Union, you should know that Wink is a controller and a processor of your personal information. The legal basis for which we collect and use the information described above depends on what the information is and why we collected it. The four bases upon which we rely include:

Contract. This means we need the information to perform our contract with you. For example, when you want to send a message, we use information to carry out your request to transmit that message to its intended recipient.

Legitimate Interests. This means we have a legitimate interest that does not outweigh your privacy rights. When we collect and process information based on our legitimate interests, we consider how we can accomplish what we need to in a way that is the least obtrusive on your privacy. For example, it is in our interest to protect your safety and security in the app, so we collect and use information that has been flagged by users or requested by law enforcement; to make sure you are satisfied with how the Services work, troubleshoot technical problems or develop new features, we collect and use information about how you and others use the Services; and to respond to your service inquiries, we collect and use information in that request and, if relevant to the inquiry, information about how you access and use the Services.

Legal Obligations. We may need to use your personal information to comply with a law enforcement preservation request, subpoena, or other legal process or to protect the rights of other users.

Consent. If we have no other legal basis for collecting or using your information, we will ask you for consent for a specific purpose. If we do, you have the right to withdraw consent at any time. Withdrawing your consent will not apply to any processing conducted in reliance on lawful processing bases other than consent.

For users in the European Economic Area, the United Kingdom, or other jurisdictions where biometric data requires a special legal basis, we process Verification Data for Photo Verification based on your explicit consent, unless another legal basis is required or permitted by applicable law. You may withdraw your consent as described in this Privacy Policy, but doing so may affect your ability to use or maintain Photo Verification features.

EU Users' Rights

In addition to other rights detailed in the policy (such as requesting deletion, correction or updating of your personal information), EU citizens have certain rights regarding your personal information, including:

Right to Object and Restrict Processing. You have the right to object to or restrict our use of your personal information for direct marketing purposes or under certain circumstances when the legal basis for using your information is based upon our legitimate interest. If you wish to object to our use of your information, you can send us a request to delete your account by emailing us at support@euphorica.ai.

Right to Erasure. You have the right to have your personal data erased and no longer processed. You can send us a request to delete your account by clicking here. Upon receiving the request, we will make a reasonable effort to delete your personal information from the app and from our internal network within a reasonable period of time as long as we are not obligated to preserve your information due to things like law enforcement preservation requests, subpoenas, investigations, litigation, or otherwise meet any of our other legal obligations. We may also retain depersonalized information after deletion.

Data Portability. You can exercise your right to export your personal data by emailing support@euphorica.ai.
File a complaint. You have the right to complain to the data protection authority located in your Member State. To find contact details, click here.

USER RIGHTS OF CALIFORNIA, COLORADO, CONNECTICUT, UTAH, AND VIRGINIA RESIDENTS

The California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”), plus the Colorado Privacy Act (“CPA”), Connecticut Data Privacy Act (“CDPA”), Utah Consumer Privacy Act (“UCPA”) and Virginia Consumer Data Protection Act (“VCDPA”) allow consumers in these states to opt out of certain sharing of their data. As such, California, Colorado, Connecticut, Utah and Virginia residents may request that Wink:

Disclose the sources, categories, and specific pieces of personal information we have collected about them, how that information is used, and with whom Wink shares it

Disclose the purpose for collecting personal information

Disclose the categories of third parties with whom Wink shares personal information

Delete/rectify/restrict their personal information, subject to certain exceptions (right of rectification not applicable to Utah residents)

Disclose, for any “sales” of personal information, the categories of personal information collected and sold and to what categories of third parties it was sold

Opt them out of sales of their personal information (if any) or subject certain personal information to automated decision-making algorithms (not applicable to Utah residents)

Provide a copy of their personal information in a readily usable format that allows the information to be transmitted to others

Residents in these states may not be discriminated against for exercising any of the rights described above.
California, Colorado, Connecticut, Utah and Virginia residents may exercise these rights by contacting Wink at support@euphorica.ai.

CALIFORNIA USERS

If you are a California user, please refer to our California Resident Privacy Notice for additional information about the data we collect and your rights.

THIRD PARTIES

This Privacy Policy does not apply to services offered by other companies or individuals, including products or services that we link to or display on the Services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any information to them.

CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time, and the updated version will be effective when posted. We encourage you to regularly check this page to review any changes we might make. If we make material changes to the Privacy Policy, we will notify you by posting an announcement on our Services, or by sending you an email or other communication.

CONTACT US

If you have any questions, comments, complaints or suggestions, please contact us at: Euphorica, Inc.
Attention: Privacy Office

Email: support@euphorica.ai

California Resident Privacy Notice

This California Resident Privacy Notice supplements the information and disclosures contained in our Privacy Policy. It applies to individuals residing in California from whom we collect Personal Information as a business under California law. The Table below describes how we process California consumers’ personal information (excluding our personnel), based on definitions laid out in the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”). For the purposes of this notice, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the CCPA.

Personal Information does not include information that is: (1) lawfully made available from government records, (2) deidentified or aggregate information, or (3) otherwise excluded from the scope of the CCPA.
Not all of the items listed in the Table below are relevant to you. For example, we do not collect Social Security numbers from our users, but we may collect this data in the course of evaluating a job applicant.

Categories of personal information collected over the 12-month period prior to the effective date of our Privacy Policy

Sources of collection over the 12-month period prior to the effective date of our Privacy Policy

Categories of third parties with whom the business shared or disclosed the personal information for a business purpose over the 12-month period prior to the effective date of our Privacy Policy

Business or commercial purposes for which the personal information was collected over the 12-month period prior to the effective date of our Privacy Policy

A. Identifiers


(Examples: Name, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.)

From you (for instance if you create an account or apply for a position at our company). From social media networks (for example if you log into our service through an account you have on a social media network).

From our affiliated companies (for example, for activating Wink Live functionality and for anti-fraud and safety purposes)

Other users as part of the general operation of the service.
Others, upon the instruction of a user using a profile sharing functionality.
Vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein.
Our payment service providers and fraud vendors (e.g., for anti-fraud purposes and to fight against other illegal activities).
To our affiliated companies (for example, for activating Wink Live functionality and for anti-fraud and safety purposes).

For providing, maintaining, improving, and enhancing the Services, providing customer service, verifying user information, processing payments, to provide the ability to make voice and video calls and chat with other users, to display your intended themes and profile images, display your profile on new Wink features and apps.

To personalize your experience on the Services, including content, and to make suggestions that are relevant to you.

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

Debugging to identify and repair errors that impair existing intended functionality.

Establishing and managing our relationships with our vendors and consultants.

To enable social functionality. We use the information we collect to support the social functionality of the Services, including to allow you to post content on third party services, such as social media networks

To communicate with you, to respond to your comments and questions or otherwise provide customer support, and to keep you updated on other information such as Wink’s latest product announcements, software updates, and upcoming events.

To promote safety and security, to identify and prevent fraud and promote trust and safety on the Services. For example, we may scan your messages for inappropriate content or capture screens hots of video streams or chat conversations to protect the safety and integrity of our Services and our users.

For compliance purposes, including to enforce our Terms of Service, Community Guidelines, and other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

To deliver personalized ads and other sponsored content based on information we collect about your interests, actions and connections.
To send you push notifications.

B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e)

(Examples: Name, signature, address, telephone number.)

From you (for instance if you create an account or apply for a position at our company).
From our affiliated companies (for example, for activating Wink Live functionality and for anti-fraud and safety purposes).

Other users as part of the general operation of the service.
Others, upon the instruction of a user using a profile sharing functionality.
Vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein.
Our payment service providers and fraud vendors (e.g., for anti-fraud purposes and to fight against other illegal activities).
To our affiliated companies (for example, for activating Wink Live functionality and for anti-fraud and safety purposes).

C. Characteristics of Protected Classifications under California or Federal Law


(Examples: Sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions).

From you (for instance if you create an account or apply for a position at our company).
From social media networks (for example if you log into our service through an account you have on a social media network).
From our affiliated companies (for example, for activating Wink Live functionality and for anti-fraud and safety purposes).

Other users as part of the general operation of the service.
Others, upon the instruction of a user using a profile sharing functionality.
Vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein.
Our payment service providers and fraud vendors (e.g., for anti-fraud purposes and to fight against other illegal activities).
To our affiliated companies (for example, for activating Wink Live functionality and for anti-fraud and safety purposes).

D. Commercial Information

From you (if you purchase something from us).

Other vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein.

E. Biometric Information

We collect and process a scan of facial geometry or similar biometric identifier when you choose to complete Photo Verification through our live video verification process.

From you, through your device camera during the live video verification process, including images, video frames, and related verification data generated when you position your face within the camera frame and follow the on-screen verification instructions.

Identity-verification, safety, and service providers, including Hive and AWS Rekognition.

To provide Photo Verification, confirm that you are a real, live person, confirm that the person completing verification appears to match the person shown in your profile photos, help prevent fraud and impersonation, maintain the safety and integrity of the Services, troubleshoot and secure the Photo Verification feature, and comply with applicable law.

Your face scan, live verification video, images, frames, and other biometric Verification Data are deleted within 3 days after the Photo Verification process is completed or no longer needed for that process, including deletion by our verification service providers, unless a longer retention period is required or permitted by applicable law for safety, security, fraud prevention, dispute resolution, enforcement of our Terms, or legal compliance. We may retain non-biometric verification results, such as whether verification succeeded or failed, for as long as reasonably necessary for those purposes.

We do not sell or share biometric information or Verification Data as those terms are defined under applicable U.S. state privacy laws. We do not use Verification Data for advertising, profiling, or training artificial intelligence models.

F. Internet or Other Electronic Network Activity Information


(Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement)

From you (for example, Logs generated when using the Wink Applications, such as the date and time you send a message, who you chat with, your internet protocol ("IP") address, and how you use thirdparty websites or services accessed through the app.
From users of our services (for instance through other users' interactions with you).
Information collected from cookies and similar technologies.
We and our third party partners, such as advertising partners, may collect information through the use of cookies and similar technologies like web beacons.

Vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein.

Vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein.

We use your IP address to infer your general location when you use the Services.

G. Geolocation Data

(Example: Exact physical location.)

Other users as part of the genera l operation of the service, including live video chat.

Others, upon the instruction of a user using a profile sharing functionality.

Vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein.

H. Sensory Information

(Examples: Audio, electronic, visual, thermal, olfactory, or similar information.)

From you (for instance if you upload a photo when creating an account or otherwise share your photo or video to another user, or if you participate in a video chat).
From social media networks (for example if you log into our service through an account you have on a social media network).
From our affiliated companies (for example, for activating Wink Live functionality and for anti-fraud and safety purposes).
Certain visual information collected during Photo Verification may also be processed as Biometric Information as described in Category E above.

I. Professional or Employment Information

From you (for example, if you say who your employer is in your profile).

Other users as part of the general operation of the service, including live video chat.
Others, upon the instruction of a user using a profile sharing functionality.
Vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein

J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99).

From you (for example, if you include your educational background in your profile).

Other users as part of the general operation of the service.
Others, upon the instruction of a user using a profile sharing functionality.
Vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein.

K. Inferences Drawn from Personal Information

(Examples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.)

Created from data in your profile.

Vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein.

In the preceding twelve months, we have not sold any California resident’s Personal Information, and as a result no opt-out choice is necessary.


Use of Personal Information

We collect, use, and disclose your Personal Information in accordance with the purposes disclosed in our Privacy Policy and for the specific business purposes below:

Auditing Interactions: Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

Fraud and Incident Prevention: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

Debugging: Debugging to identify and repair errors that impair existing intended functionality.

Transient Use: Short-term, transient use.

Contracting Vendors: Contracting with service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
Product Improvement: Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.

Notified Purpose: For other purposes for which we provide specific notice at the time the information is collected.

Disclosure of Your Personal Information

Pursuant to our Privacy Policy, we disclose your Personal Information to our affiliates, service providers, and third parties for which you have authorized us to disclose your information.

Your California Privacy Rights

If you are a California resident, you may exercise the following rights. Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information (as defined by the CCPA) collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you.

Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.

Submit Requests. To exercise your rights under the CCPA, please send an email to support@euphorica.ai, or use our online form. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations.

Verification. To verify your access or deletion request, please log into your account and navigate to our online form. Alternatively, please provide us with a screenshot of your Wink account. The screenshot should display your [name, user name, and account settings] so we can verify your identity in our records. We may provide you with a temporary user name which we will ask you to change your user name to before sending us a screenshot of your account.

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

Contact Information

If you have any questions, comments, or concerns about our processing activities, or you would like to exercise your privacy rights please email us at support@euphorica.ai or write to us at: Euphorica, Inc.

Attention: Privacy Office

Email: support@euphorica.ai


Last Updated: June 5, 2026

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Privacy Policy

Wink is developed by Euphorica, Inc. This Privacy Policy applies to the Wink family of services, including Wink and Wink Social (collectively, the "Wink Platform").

To avoid confusion, we refer to Wink as the relevant entity throughout this policy. However, Euphorica, Inc. is the business that collects and stores your information. Wink Platform and Euphorica, Inc. knows that you take your privacy seriously. Your data and privacy is important to us and our affiliated companies (collectively, “Wink”, “us”, “our”, or “we”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share data from or about individuals who use the Wink or Wink Social (each, an “app”) or visit our website at www.getwinkapp.com (collectively, the “Services”) to make friends online. By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service and Community Guidelines.


Information we collect

We collect a variety of information from or about you or your devices from various sources, as described below.


Information you give us directly:

  • Registration information. When you sign up to use a Wink Platform, you provide us with basic information like your email, phone number, name, age, country, and gender etc.
  • Profile information. When you create a profile on a Wink Platform, you provide us with information such as profile pictures, name (first and/or last), and any other information you choose to provide.
  • Please see the “Other users” section under “HOW IS INFORMATION SHARED” below for important details about how your profile information is viewable by other users.
  • Content. When you through the Wink Platform send or receive a message, participate in a video chat or provide audio visual content via your device or camera, we collect the contents of the message, any attachments to the message (including, for example, voice messages, audio and video content and photos), and information about the message (such as who you are communicating with).
  • Wink communications. When you reach out to us (through, for example, an in-app report or email, we collect and store the contents and details of that communication, including things like date, time, method of communication, and resolution (if applicable).
  • Polls, surveys, and questionnaires. When you voluntarily respond to polls, surveys, and questionnaires, we receive the contents of your responses and any other information you provide, such as your address and basic demographic information.

Information we collect when you use our Services:

  • Log and data usage information. We collect information about your activity on the Wink Platform and how you use the Services, such as the date and time you send a message, who you chat with, your internet protocol ("IP") address, and how you use third-party websites or services accessed through the app.
  • Device and browser information. We collect information from and about the device you use to access our Services, which may include information like your hardware model, operating system version, device model and/or carrier, web browser type and settings, push notification tokens, advertising identifiers (e.g. Apple IDFA or Google Advertising ID), unique device identifiers, and mobile network information, as well as information you’ve shared with us through device settings, like GPS location, camera access, photos and related metadata.
  • Location information. We use your IP address to infer your general location when you use the Services.
  • Information collected from cookies and similar technologies. We and our third party partners, such as advertising partners, may collect information through the use of cookies and similar technologies like web beacons. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.
  • Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.
  • Information we collect when you use our Services:
  • Information from third parties. We may receive information about you from third parties, including third parties that integrate with the Services or that provide services to us. This may include information such as log and data usage information collected from our Services or other online services, device and browser information, location information, and information collected through cookies or other similar technologies. We may combine this information with demographic and other interest-based segment information we receive from third parties.
  • Information from third party services. If you created your account using a third party account, such as your Google account, we may receive certain information about you from these third parties such as your first name, last name, and profile picture. If you wish to limit the information we receive, you should visit the privacy settings of your third party accounts to learn about your options.

How we use information

We use the information we collect to:

Provide, maintain, improve, and enhance the Services. We use information we collect about you to provide the Services you request from us and to provide the functionality of the app and the features you choose to use. For example, we use the information we collect to facilitate your use of the Wink Platform’s features, to allow you to connect with other users, to deliver your messages, to provide the ability to make voice and video calls and connect with others, and to display your intended themes and profile images. We also use your information to register you and display your profile on new Wink features and apps.

Personalize your experience on the Services. For example, we use the information we collect to personalize content and make suggestions that are relevant to you.

Understand and analyze how you use the Services. We aim to continuously improve our offerings to bring you the best way to make meaningful connections. Accordingly, we are continuously analyzing how users access and use the app and its features in order to improve existing Services and develop new ones. Our analysis of how you use the Wink Platform can help us do things like evaluate the popularity and functionality of certain features, identify and fix potential bugs, and understand what our users want.

Communicate with you. The information we collect lets us respond to your comments and questions or otherwise provide customer support, and keep you updated on other information such as Wink Platform’s latest product announcements, software updates, and upcoming events.

Enable social functionality. We use the information we collect to support the social functionality of the Services, including to allow you to post content on third party services, such as social media networks.

Promote safety and security. We also use information to find and prevent fraud and promote trust and safety on the Services. For example, we may scan your messages for inappropriate content to protect the safety and integrity of our Services and our users.

Compliance purposes. We may use the information we collect to enforce our Terms of Service, Community Guidelines, and other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

Send you push notifications. We may use the information we collect to send you push notifications.

Other purposes. We may also use the information we collect for other purposes for which we provide notice at the time the information is collected. We will not use Verification Data for any materially different purpose without first obtaining any additional consent required by applicable law.

Photo Verification and Biometric Data. If you choose to verify your profile, we may ask you to complete a live video verification process using your device camera. During this process, you may be asked to position your face within the camera frame and follow on-screen instructions so that we can confirm that you are a real, live person and that the person completing verification appears to match the person shown in your profile photos.

When you complete Photo Verification, we and our service providers may collect and process images, video frames, and related verification data from the live video verification process, and may use facial scanning technology to detect a face and create a scan of facial geometry or similar biometric identifier derived from that content (“Verification Data”). Verification Data may be considered biometric information or a biometric identifier in some jurisdictions.

Your live verification video, images, or frames are not posted to your profile and are not visible to other users.

We use Verification Data only to provide, maintain, troubleshoot, and secure the Photo Verification feature, including to verify your profile and help prevent fraud, impersonation, and misuse of the Services.


We use third-party providers, including Hive and AWS Rekognition, to help perform Photo Verification. These providers are permitted to process Verification Data only as necessary to provide the verification service to us and must not use Verification Data for their own advertising, profiling, resale, or model-training purposes.


We ask for your explicit consent before collecting or processing Verification Data. Photo Verification is optional.


Your face scan, live verification video, images, frames, and other biometric Verification Data are deleted within 3 days after the Photo Verification process is completed or no longer needed for that process, including deletion by our verification service providers. We may retain non-biometric verification results, such as whether verification succeeded or failed, for as long as reasonably necessary to maintain the integrity, safety, and security of the Services, comply with legal obligations, resolve disputes, enforce our Terms, and prevent fraud or abuse.


We do not sell, lease, trade, or use Verification Data for advertising, profiling, or training artificial intelligence models. We do not “sell” or “share” Verification Data as those terms are defined under applicable U.S. state privacy laws.


We will not collect, store, or use your Verification Data for any purpose other than Photo Verification, fraud prevention, impersonation prevention, safety, security, and legal compliance without first obtaining any additional consent required by applicable law. Residents of Illinois, Texas, Washington, and other jurisdictions with biometric-specific laws may have additional rights under those laws; contact support@euphorica.ai with questions.


HOW IS INFORMATION SHARED

  • Other users. The Wink Platform is a social service intended to help you make new friends and interact with them. Please be aware that your profile information will always be viewable by other users. You may edit your profile information within the Wink Platform through your profile settings. We are not responsible for other users’ use of available information, so you should carefully consider whether and what to include in your profile or otherwise share through the Services. We also share your information if you ask us to. For example, we send the messages and other content you ask us to send to other users either directly or within a group chat. Please be aware that anyone you send a message to will have their own copy of the message and any content attached to that message. Therefore, even if you delete your copy of the message from your account, they may duplicate, store, or reshare at their own discretion.
  • Social networks. Our services allow you to share information with social networking services, such as Instagram. You understand and agree that the use of your information by any social networking websites will be governed by the privacy policies of these third party platforms and your settings on that platform. We encourage you to review their privacy policies before sharing any information with them.
  • Third party integrations. Certain features you use through Wink are offered by third parties such as logging in with Google. Those features may include things such as GIFs, emojis, smileys, web pages optimized for the Wink Platform, etc. When you choose to use these third-party features, or other services that use, or are integrated with, our Services, those third parties (and other users of those third party services) may be able to see things like your user profile and receive information about what you post or share. These third parties may use this information as described in their privacy policies, which can include advertising. You understand and agree that the use of your information by these third parties will be governed by the privacy policies of these third party platforms and your settings on that platform. We encourage you to review their privacy policies before sharing any information with them.
  • Our service providers. We share the information we collect with third-party service providers that help operate our business. Examples include suppliers who host our data, provide customer service, support safety and security, or help provide identity-verification and Photo Verification services. Where service providers process Verification Data, they are permitted to process it only as necessary to provide services to us and must not use it for their own advertising, profiling, resale, or model-training purposes.
  • Our related companies. We may share your information with affiliated companies strictly for operational purposes — such as shared login functionality, cross-platform moderation, and analytics.
  • Other Wink Platform. In furtherance of servicing and operating the Wink Platform, your registration and account information and associated data will be shared and available across all Wink products that you are eligible to access, including Wink and Wink Social.
  • To protect Wink and its users, or for legal purposes. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) detect, prevent or address fraud or other illegal activity (b) respond to your requests; (c) comply with law enforcement requests and legal process, such as subpoenas, warrants, production orders, or similar instruments; or (d) protect your, our, or others’ rights, property, or safety, including when there is an emergency involving potential harm, loss of security or serious injury to people or threats of such emergencies. For the avoidance of doubt, we may disclose your information if you post any objectionable content on or through the Services.
  • Merger, financing or sale. We may share your information with service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a merger, financing, acquisition, dissolution transaction, bankruptcy or proceeding involving the sale, transfer, or divestiture of all or a portion of our business or assets. Verification Data is not sold, leased, traded, or used for advertising, profiling, or model training, and any disclosure or transfer of Verification Data in connection with a corporate transaction will be limited to what is permitted by applicable law and subject to appropriate confidentiality, security, and use restrictions.
  • Consent. We may also share your information with your permission.

User Controls

  • Update your information. You can update your profile information through the Wink Platform settings.
  • Delete your account. You may deactivate or terminate your account at any time, for any or no reason, by accessing the settings page of your account or by contacting us. For account deletion please contact us via support@euphorica.ai, and we will provide you with further assistance and guide you through the process. Once you choose to delete your account, you will not be able to reactivate your account or retrieve any of the User Content or information you have added.
  • Photo Verification Data. If you complete Photo Verification, your face scan, live verification video, images, frames, and other biometric Verification Data are deleted as described in the “Photo Verification and Biometric Data” section above. If you delete your account, any remaining Verification Data will be deleted in accordance with that section, unless continued retention is required or permitted by applicable law for safety, security, fraud prevention, dispute resolution, enforcement of our Terms, or legal compliance. We may retain a non-biometric verification result, such as whether verification succeeded or failed, for as long as reasonably necessary to maintain the integrity, safety, and security of the Services, comply with legal obligations, resolve disputes, enforce our Terms, and prevent fraud or abuse.
  • Blocking and reporting users. You can block users or report users who are engaging in harmful or offensive conduct to us through the controls provided in the Wink Platform.
  • Marketing and promotional communications. You may unsubscribe from emails in the footer of any marketing or promotional email. Please note that even if you opt-out of receiving marketing or promotional messages from us, you will continue to receive administrative messages from us.

SECURITY OF YOUR INFORMATION

We make reasonable efforts to protect your information by using safeguards designed to improve the security of the information we maintain. We apply appropriate technical and organizational safeguards designed to protect Verification Data, including limiting access to personnel and service providers who need it to provide, secure, troubleshoot, or support the Photo Verification feature. Despite these efforts, you should know that we cannot guarantee the privacy or security of your information because we cannot fully eliminate the security risks associated with online transmissions.

INTERNATIONAL USERS

The Wink Platform and all of our data, including your Data, are hosted on servers in the United States. If you are using or accessing the Services from outside of the United States, your Data will be transferred to, processed and stored in the United States. As a result, United States federal and state governments, courts, or law enforcement or regulatory agencies may be able to obtain your Data through laws applicable in the United States. United States laws may not offer the same privacy protections as the law of your jurisdiction. Personal information collected in the EU may be transferred to, and stored at, a destination outside of the EU and processed by employees operating outside of the EU who work for us, one of our business partners, or service providers. We rely on the European Commission’s updated Standard Contractual Clauses (2021/914) and conduct Transfer Impact Assessments (TIAs) to ensure compliance with GDPR when transferring personal data from the EU. Where required, we obtain user consent for such transfers. When we transfer personal information across country borders, we will make sure there is a transfer mechanism in place to transfer the data in a manner consistent with that described in this Privacy Policy. For citizens of the European Union, you should know that Wink is a controller and a processor of your personal information. The legal basis for which we collect and use the information described above depends on what the information is and why we collected it. The four bases upon which we rely include:

Contract. This means we need the information to perform our contract with you. For example, when you want to send a message, we use information to carry out your request to transmit that message to its intended recipient.

Legitimate Interests. This means we have a legitimate interest that does not outweigh your privacy rights. When we collect and process information based on our legitimate interests, we consider how we can accomplish what we need to in a way that is the least obtrusive on your privacy. For example, it is in our interest to protect your safety and security in the app, so we collect and use information that has been flagged by users or requested by law enforcement; to make sure you are satisfied with how the Services work, troubleshoot technical problems or develop new features, we collect and use information about how you and others use the Services; and to respond to your service inquiries, we collect and use information in that request and, if relevant to the inquiry, information about how you access and use the Services.

Legal Obligations. We may need to use your personal information to comply with a law enforcement preservation request, subpoena, or other legal process or to protect the rights of other users.

Consent. If we have no other legal basis for collecting or using your information, we will ask you for consent for a specific purpose. If we do, you have the right to withdraw consent at any time. Withdrawing your consent will not apply to any processing conducted in reliance on lawful processing bases other than consent.

For users in the European Economic Area, the United Kingdom, or other jurisdictions where biometric data requires a special legal basis, we process Verification Data for Photo Verification based on your explicit consent, unless another legal basis is required or permitted by applicable law. You may withdraw your consent as described in this Privacy Policy, but doing so may affect your ability to use or maintain Photo Verification features.

EU Users' Rights

In addition to other rights detailed in the policy (such as requesting deletion, correction or updating of your personal information), EU citizens have certain rights regarding your personal information, including:

Right to Object and Restrict Processing. You have the right to object to or restrict our use of your personal information for direct marketing purposes or under certain circumstances when the legal basis for using your information is based upon our legitimate interest. If you wish to object to our use of your information, you can send us a request to delete your account by emailing us at support@euphorica.ai.

Right to Erasure. You have the right to have your personal data erased and no longer processed. You can send us a request to delete your account by clicking here. Upon receiving the request, we will make a reasonable effort to delete your personal information from the app and from our internal network within a reasonable period of time as long as we are not obligated to preserve your information due to things like law enforcement preservation requests, subpoenas, investigations, litigation, or otherwise meet any of our other legal obligations. We may also retain depersonalized information after deletion.

Data Portability. You can exercise your right to export your personal data by emailing support@euphorica.ai.
File a complaint. You have the right to complain to the data protection authority located in your Member State. To find contact details, click here.

USER RIGHTS OF CALIFORNIA, COLORADO, CONNECTICUT, UTAH, AND VIRGINIA RESIDENTS

The California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”), plus the Colorado Privacy Act (“CPA”), Connecticut Data Privacy Act (“CDPA”), Utah Consumer Privacy Act (“UCPA”) and Virginia Consumer Data Protection Act (“VCDPA”) allow consumers in these states to opt out of certain sharing of their data. As such, California, Colorado, Connecticut, Utah and Virginia residents may request that Wink:

Disclose the sources, categories, and specific pieces of personal information we have collected about them, how that information is used, and with whom Wink shares it

Disclose the purpose for collecting personal information

Disclose the categories of third parties with whom Wink shares personal information

Delete/rectify/restrict their personal information, subject to certain exceptions (right of rectification not applicable to Utah residents)

Disclose, for any “sales” of personal information, the categories of personal information collected and sold and to what categories of third parties it was sold

Opt them out of sales of their personal information (if any) or subject certain personal information to automated decision-making algorithms (not applicable to Utah residents)

Provide a copy of their personal information in a readily usable format that allows the information to be transmitted to others

Residents in these states may not be discriminated against for exercising any of the rights described above.
California, Colorado, Connecticut, Utah and Virginia residents may exercise these rights by contacting Wink at support@euphorica.ai.

CALIFORNIA USERS

If you are a California user, please refer to our California Resident Privacy Notice for additional information about the data we collect and your rights.

THIRD PARTIES

This Privacy Policy does not apply to services offered by other companies or individuals, including products or services that we link to or display on the Services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any information to them.

CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time, and the updated version will be effective when posted. We encourage you to regularly check this page to review any changes we might make. If we make material changes to the Privacy Policy, we will notify you by posting an announcement on our Services, or by sending you an email or other communication.

CONTACT US

If you have any questions, comments, complaints or suggestions, please contact us at: Euphorica, Inc.
Attention: Privacy Office

Email: support@euphorica.ai

California Resident Privacy Notice

This California Resident Privacy Notice supplements the information and disclosures contained in our Privacy Policy. It applies to individuals residing in California from whom we collect Personal Information as a business under California law. The Table below describes how we process California consumers’ personal information (excluding our personnel), based on definitions laid out in the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”). For the purposes of this notice, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the CCPA.

Personal Information does not include information that is: (1) lawfully made available from government records, (2) deidentified or aggregate information, or (3) otherwise excluded from the scope of the CCPA.
Not all of the items listed in the Table below are relevant to you. For example, we do not collect Social Security numbers from our users, but we may collect this data in the course of evaluating a job applicant.

Categories of personal information collected over the 12-month period prior to the effective date of our Privacy Policy

A. Identifiers


(Examples: Name, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.)

From you (for instance if you create an account or apply for a position at our company). From social media networks (for example if you log into our service through an account you have on a social media network).

From our affiliated companies (for example, for activating Wink Live functionality and for anti-fraud and safety purposes)

Other users as part of the general operation of the service.
Others, upon the instruction of a user using a profile sharing functionality.
Vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein.
Our payment service providers and fraud vendors (e.g., for anti-fraud purposes and to fight against other illegal activities).
To our affiliated companies (for example, for activating Wink Live functionality and for anti-fraud and safety purposes).

For providing, maintaining, improving, and enhancing the Services, providing customer service, verifying user information, processing payments, to provide the ability to make voice and video calls and chat with other users, to display your intended themes and profile images, display your profile on new Wink features and apps.

To personalize your experience on the Services, including content, and to make suggestions that are relevant to you.

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

Debugging to identify and repair errors that impair existing intended functionality.

Establishing and managing our relationships with our vendors and consultants.

To enable social functionality. We use the information we collect to support the social functionality of the Services, including to allow you to post content on third party services, such as social media networks

To communicate with you, to respond to your comments and questions or otherwise provide customer support, and to keep you updated on other information such as Wink’s latest product announcements, software updates, and upcoming events.

To promote safety and security, to identify and prevent fraud and promote trust and safety on the Services. For example, we may scan your messages for inappropriate content or capture screens hots of video streams or chat conversations to protect the safety and integrity of our Services and our users.

For compliance purposes, including to enforce our Terms of Service, Community Guidelines, and other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

To deliver personalized ads and other sponsored content based on information we collect about your interests, actions and connections.
To send you push notifications.

B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e)

(Examples: Name, signature, address, telephone number.)

From you (for instance if you create an account or apply for a position at our company).
From our affiliated companies (for example, for activating Wink Live functionality and for anti-fraud and safety purposes).

Other users as part of the general operation of the service.
Others, upon the instruction of a user using a profile sharing functionality.
Vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein.
Our payment service providers and fraud vendors (e.g., for anti-fraud purposes and to fight against other illegal activities).
To our affiliated companies (for example, for activating Wink Live functionality and for anti-fraud and safety purposes).

C. Characteristics of Protected Classifications under California or Federal Law


(Examples: Sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions).

From you (for instance if you create an account or apply for a position at our company).
From social media networks (for example if you log into our service through an account you have on a social media network).
From our affiliated companies (for example, for activating Wink Live functionality and for anti-fraud and safety purposes).

Other users as part of the general operation of the service.
Others, upon the instruction of a user using a profile sharing functionality.
Vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein.
Our payment service providers and fraud vendors (e.g., for anti-fraud purposes and to fight against other illegal activities).
To our affiliated companies (for example, for activating Wink Live functionality and for anti-fraud and safety purposes).

D. Commercial Information

From you (if you purchase something from us).

Other vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein.

E. Biometric Information

We collect and process a scan of facial geometry or similar biometric identifier when you choose to complete Photo Verification through our live video verification process.

From you, through your device camera during the live video verification process, including images, video frames, and related verification data generated when you position your face within the camera frame and follow the on-screen verification instructions.

Identity-verification, safety, and service providers, including Hive and AWS Rekognition.

To provide Photo Verification, confirm that you are a real, live person, confirm that the person completing verification appears to match the person shown in your profile photos, help prevent fraud and impersonation, maintain the safety and integrity of the Services, troubleshoot and secure the Photo Verification feature, and comply with applicable law.

Your face scan, live verification video, images, frames, and other biometric Verification Data are deleted within 3 days after the Photo Verification process is completed or no longer needed for that process, including deletion by our verification service providers, unless a longer retention period is required or permitted by applicable law for safety, security, fraud prevention, dispute resolution, enforcement of our Terms, or legal compliance. We may retain non-biometric verification results, such as whether verification succeeded or failed, for as long as reasonably necessary for those purposes.

We do not sell or share biometric information or Verification Data as those terms are defined under applicable U.S. state privacy laws. We do not use Verification Data for advertising, profiling, or training artificial intelligence models.

F. Internet or Other Electronic Network Activity Information


(Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement)

Vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein.

From you (for example, Logs generated when using the Wink Applications, such as the date and time you send a message, who you chat with, your internet protocol ("IP") address, and how you use thirdparty websites or services accessed through the app.
From users of our services (for instance through other users' interactions with you).
Information collected from cookies and similar technologies.
We and our third party partners, such as advertising partners, may collect information through the use of cookies and similar technologies like web beacons.

G. Geolocation Data

(Example: Exact physical location.)

We use your IP address to infer your general location when you use the Services.

Vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein.

H. Sensory Information

(Examples: Audio, electronic, visual, thermal, olfactory, or similar information.)

From you (for instance if you upload a photo when creating an account or otherwise share your photo or video to another user, or if you participate in a video chat).
From social media networks (for example if you log into our service through an account you have on a social media network).
From our affiliated companies (for example, for activating Wink Live functionality and for anti-fraud and safety purposes).
Certain visual information collected during Photo Verification may also be processed as Biometric Information as described in Category E above.

Other users as part of the genera l operation of the service, including live video chat.

Others, upon the instruction of a user using a profile sharing functionality.

Vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein.

I. Professional or Employment Information

From you (for example, if you say who your employer is in your profile).

Other users as part of the general operation of the service, including live video chat.
Others, upon the instruction of a user using a profile sharing functionality.
Vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein

J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99).

From you (for example, if you include your educational background in your profile).

Other users as part of the general operation of the service.
Others, upon the instruction of a user using a profile sharing functionality.
Vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein.

K. Inferences Drawn from Personal Information

(Examples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.)

Created from data in your profile.

Vendors and professional services organizations who assist us in relation to the business or commercial purposes laid out herein.

In the preceding twelve months, we have not sold any California resident’s Personal Information, and as a result no opt-out choice is necessary.


Use of Personal Information

We collect, use, and disclose your Personal Information in accordance with the purposes disclosed in our Privacy Policy and for the specific business purposes below:

Auditing Interactions: Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

Fraud and Incident Prevention: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

Debugging: Debugging to identify and repair errors that impair existing intended functionality.

Transient Use: Short-term, transient use.

Contracting Vendors: Contracting with service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
Product Improvement: Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.

Notified Purpose: For other purposes for which we provide specific notice at the time the information is collected.

Disclosure of Your Personal Information

Pursuant to our Privacy Policy, we disclose your Personal Information to our affiliates, service providers, and third parties for which you have authorized us to disclose your information.

Your California Privacy Rights

If you are a California resident, you may exercise the following rights. Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information (as defined by the CCPA) collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you.

Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.

Submit Requests. To exercise your rights under the CCPA, please send an email to support@euphorica.ai, or use our online form. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations.

Verification. To verify your access or deletion request, please log into your account and navigate to our online form. Alternatively, please provide us with a screenshot of your Wink account. The screenshot should display your [name, user name, and account settings] so we can verify your identity in our records. We may provide you with a temporary user name which we will ask you to change your user name to before sending us a screenshot of your account.

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

Contact Information

If you have any questions, comments, or concerns about our processing activities, or you would like to exercise your privacy rights please email us at support@euphorica.ai or write to us at: Euphorica, Inc.

Attention: Privacy Office

Email: support@euphorica.ai


Last Updated: June 5, 2026

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