PRIVACY POLICY

PRIVACY POLICY

Last updated: March 12th 2026

PRIVACY POLICY OF WINGMAWO™

This Privacy Policy (“Policy”) explains how Affinity Grid Private Limited, a company incorporated under the Companies Act, 2013 (“Affinity Grid”, “we”, “us”, “our”), collects, uses, stores, discloses, and protects personal data of individuals (“you”, “user”) who access or use the Wingmawo™ mobile application and any services directly connected to the application (“Service”).
Wingmawo™ is a digital product wholly owned, operated, and legally governed by Affinity Grid Private Limited. Your use of Wingmawo™ constitutes consent to the data practices described in this Policy.
This Policy is compliant with the Digital Personal Data Protection Act, 2023 (DPDPA) of India, and, where applicable, the General Data Protection Regulation (GDPR) for users in the European Economic Area.
If you do not agree to this Policy, you must discontinue use of the Service.

1. Definitions & Scope

For the purpose of this Policy:
This Policy applies to all individuals using the Wingmawo™ Service, regardless of nationality or location, to the extent permitted by applicable law.

2. Legal Bases & Processing Principles

We process Personal Data under the following legal bases:
We adhere to the principles of:
Users will receive meaningful information regarding automated systems whenever required by law.

3. Data We Collect

We collect the following categories of data:
A. Account & Identity Data
B. Profile & Preference Data
C. Behavioral & Usage Data
D. Device & Technical Data
E. Location Data
F. Communications & Media
G. Payment Data
H. Support & Correspondence
I. Marketing & Landing Page Data
J. Authentication & OTP Data
K. Third-Party Data (Optional)
We do not sell Personal Data.

4. How We Use Your Data

We use your Personal Data to:
Algorithmic and moderation decisions may be supported by automated tools, subject to human review whenever required.

5. Consent & User Controls

Users may:

6. Sharing & Disclosure

We may share Personal Data with:
Cross-border data transfers follow legal safeguards such as Standard Contractual Clauses. We never disclose your Personal Data to advertisers without your explicit consent.

Data Retention, Account Deletion & Data Erasure

7.1 General Data Retention Principles
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including delivering the Service, improving functionality, conducting safety investigations, preventing fraud, enforcing community standards, and complying with legal obligations.

Data is retained only for legitimate operational, safety, legal, regulatory, or accounting purposes. Once the purpose has been fulfilled, personal data is securely deleted or irreversibly anonymized. Backup systems are purged within defined retention cycles.
Retention practices comply with:

7.2 Right to Delete Your Account
Wingmawo provides users with the ability to permanently delete their account and associated personal data at any time through an in-app mechanism.
Account deletion is:

7.3 In-App Account Deletion (Primary Method)
Users may delete their account directly inside the Wingmawo mobile application:
Upon confirmation:
Wingmawo does not require users to contact support to delete their account.

7.4 Legal Basis for Data Erasure
A. Under the Digital Personal Data Protection Act, 2023 (India)
Users may request erasure where:
Wingmawo acts as a Data Fiduciary and processes deletion requests in accordance with statutory obligations.
B. Under GDPR – Article 17 (Right to Erasure)
Where applicable, users may obtain erasure without undue delay where:
Personal data will be erased unless retention is required under Article 17(3), including:

7.5 Scope of Data Deleted
Upon confirmed deletion, the following categories of data are permanently removed from active production systems:
Deleted data cannot be restored.

7.6 Backup Retention

7.7 Lawful Retention Exceptions
Limited data may be retained strictly where required for:
A. Legal and Regulatory Compliance
B. Fraud Prevention & Platform Safety
Only the minimum necessary information is retained. Access is restricted, time-bound, and controlled through role-based permissions. Retained data is never used for marketing or personalization.

7.8 Data Shared With Other Users
Messages sent to other users may remain visible in their chat history unless both accounts are deleted.
However:

7.9 Third-Party Service Providers
Wingmawo uses third-party processors for:
Upon confirmed deletion:

7.10 Subscriptions and External Accounts
Deleting a Wingmawo account:
Users must cancel subscriptions directly via the respective app store platform.

7.11 Alternative Deletion Request (If App Access Is Unavailable)
If access to the app is unavailable, deletion may be requested by emailing:
support@wingmawo.com
Subject line: “Account Deletion Request – Wingmawo”
Identity verification may be required to prevent unauthorized deletion.
Requests are processed within a reasonable timeframe, typically within 7 business days.

7.12 Processing Timeline

7.13 Compliance Confirmation
Wingmawo confirms:

7.14 Policy Updates
We may update this Data Retention & Deletion section to reflect legal, regulatory, or operational changes. The latest version will be made available within the application or official website.

8. Your Rights

You have the right to:
Requests may be sent to: support@wingmawo.com

9. Security Measures

We employ industry-standard administrative, technical, and organizational security measures designed to protect Personal Data against unauthorized access, alteration, disclosure, or destruction.
Such measures may include, where appropriate and feasible, encryption in transit, role-based access controls, and secure cloud infrastructure.
While we take reasonable steps to safeguard Personal Data, no system can be guaranteed to be 100% secure. Users are encouraged to protect their devices, accounts, and login credentials at all times.
Breach notification is provided as required by applicable law (including GDPR, where applicable).

10. ADMIN DASHBOARD ACCESS, LIMITATIONS & SAFEGUARDS

Wingmawo™ employs strict, multi-layered administrative controls to ensure user privacy and prevent unauthorized access.
Role-Based Limited Access
Contact Information Visibility
No Message Content Access
Sensitive Data Masking
No Unrestricted Employee Viewing
Access Authorization & Clearance
Internal Controls & Compliance
Transparency to Users
Users are guaranteed a high-trust, privacy-centric environment.

11. Trademark & Brand Protection


12. User Responsibility for Device & Password Security

Users are responsible for:
We are not liable for compromise resulting from user-side negligence or unsecured devices.

13. Children & Age Restrictions

Wingmawo™ is strictly for users 18 years or older. Profiles identified as belonging to minors will be permanently removed.

14. Changes to this Policy

We may amend this Policy anytime to comply with legal or operational updates. Significant changes will be notified via email, push notification, or in-app notice. Continued use after updates constitutes acceptance.

15. Contact & Data Protection Officer

Contact, Data Protection Officer & Grievance Officer
Data Fiduciary: Affinity Grid Private Limited
Registered Office Address: 7/3 (9/4/3), C.P.RAMASAMYROAD,ALWARPET, Teynampet, Chennai, Chennai- 600018, Tamil Nadu
Support & Privacy Contact:
Email: support@wingmawo.com

Grievance Officer (India – DPDP Act, 2023)
Contact, Privacy & Grievance Officer:
Email: support@wingmawo.com

Grievance Redressal Timeline: All grievances and complaints related to personal data will be acknowledged and resolved within a reasonable time, and in any case within the timelines prescribed under applicable law.

Jurisdiction: Courts of Chennai, Tamil Nadu, India

For GDPR queries, contact the same address with subject line: "GDPR Request".

16. AI-Assisted Conversations & Third-Party AI Processing

Wingmawo™ provides an AI-assisted conversation feature that helps matched users generate icebreakers and conversation suggestions within chats.

When a user voluntarily activates this feature (for example, by tapping the sparkle icon or the “Ask Wingmawo” button), limited contextual information may be securely transmitted to a third-party artificial intelligence service provider (Google Gemini) solely for the purpose of generating real-time conversation suggestions.
To ensure data minimization and user privacy, the AI system is designed to process only :
The AI system does not access or process:
AI-generated suggestions are subject to safety safeguards and moderation controls designed to reduce the generation of harmful, abusive, sexually explicit, or harassing content.

Processing by the third-party AI provider is performed in an automated manner. The provider does not receive access to user accounts, does not have independent visibility into user profiles or conversations, and processes data only for generating requested suggestions under contractual and technical safeguards.
The AI-assisted feature is:
Third-party AI providers act strictly as data processors under applicable data protection laws and contractual safeguards.

Users may choose not to use the AI-assisted feature at any time.

For additional transparency, users can review this information at any time through the Privacy Policy link available within the application settings.