Wainkum Privacy Policy

Version 2.1 · In force from 9 November 2026

Operated by Wainkum Integrated Computer Solutions Company (شركة وينكم لحلول متكامله حاسوبيه), a one-person company, Commercial Licence 2026/14957, CR 550193, Qibla, Al-Mubarakiya Street, Capital Governorate, State of Kuwait · support@wainkum.app

Article 1 — Introduction and Who We Are

1.1 This Privacy Policy (the "Policy") explains how Wainkum Integrated Computer Solutions Company (شركة وينكم لحلول متكامله حاسوبيه), a one-person company incorporated under the laws of the State of Kuwait, commercial license no. 2026/14957, commercial register no. 550193, registered address Capital Governorate, Qibla, Al-Mubarakiya Street, Osama Yousef Mohammed Al-Omar Building, Floor 1, Shop 9, State of Kuwait (the "Company", "Wainkum", "we" or "us"), collects, uses, shares, keeps and protects Personal Data when a User uses the Service.

1.2 The Company decides why and how Personal Data is Processed in the Service and is responsible for that Processing. Questions and requests about this Policy go to support@wainkum.app (Article 21).

1.3 This Policy forms part of the Agreement described in clause 1.3 of the Wainkum Terms and Conditions (the "Terms"), as clause 18.1 of the Terms provides, and must be read with them, in particular Article 3 (Eligibility), Article 7 (Location), Article 8 (Engagements), Article 11 (Community), Article 14 (Monitoring), Article 18 (Privacy, Notifications and Communications), Article 19 (Termination) and Article 24 (Changes). Accepting the Terms and accepting this Policy are recorded separately (Article 19). As clause 2.2 of the Terms provides, if the Terms conflict with this Policy, this Policy prevails on the handling of personal data and the Terms prevail on everything else.

1.4 In brief, and without limiting the Articles that follow:

(a) Wainkum is a social map. The User decides when to Check-in, what to post and who may see it, and can change Visibility Settings, hide from particular Friends, use Ghost Mode, Block anyone, download a copy of the User's data and delete the Account, all inside the Application;

(b) the Application reports the User's live position to the Company only while the User is Checked-in or on a Join Me Trip (Article 6);

(c) a new Account is set to "Everyone", so that while the User is Checked-in every other User can see the User's Presence, pin and public profile, until the User chooses "Friends only", which the User can do at any time in the Application (Article 7);

(d) the Company does not sell Personal Data, does not show advertising, does not use the device's advertising identifier and does not track Users across other companies' applications or websites;

(e) Direct Messages are not submitted to Automated Content Checks and are not routinely read by anyone at the Company; an Administrator may read a conversation only where it has been reported, and each such access is recorded (Article 11); and

(f) much of what Users share expires by design (Wains after 24 hours, Place Chats after the periods in the Terms, Check-ins no later than 24 hours after they begin), while some records are kept after an Account is deleted, as Article 15 explains.

1.5 This Policy is drafted in English; a translation is for convenience only and the English text prevails except where the mandatory law of the User's country of residence requires otherwise. The version in force is the version displayed in the Application and at wainkum.app/privacy. Headings do not affect interpretation.

Article 2 — Definitions

2.1 Capitalised terms that are not defined in this Policy have the meanings given to them in the Terms, including "User", "Account", "Service", "Application", "Website", "Check-in", "Checked-in", "Presence", "Live Location", "Join Me Trip", "Wain", "Place", "Place Chat", "Direct Message", "Group Chat", "Friend", "Friend Request", "WainTag", "Visibility Settings", "Ghost Mode", "Blocking", "Hangout", "Host", "Event", "Organizer", "Attendee", "Organization", "Organization Account", "Event Pass", "Message Request", "Vibe", "Stamp", "Ticket", "Company Message", "Automated Content Checks", "Third-Party Provider", "User Content", "Public Content" and "Minimum Age".

2.2 In this Policy:

(a) "Personal Data" means any information relating to an identified or identifiable natural person, including a User, a person acting for an Organization, a person shown or named in User Content, a visitor to the Website and a person who joins the waitlist;

(b) "Processing" means any operation performed on Personal Data, including collecting, recording, storing, using, disclosing, transferring and deleting it, and "Process" has a matching meaning;

(c) "Service Provider" means a Third-Party Provider that Processes Personal Data on the Company's behalf and on its instructions;

(d) "Independent Provider" means a Third-Party Provider that receives Personal Data through the Service but handles it under its own terms and privacy policy, as described in clause 10.4;

(e) "Administrator" means a member of the Company's staff whom the Company has authorised to use its administration tools;

(f) "Fault Report" means an internal note, with any screenshot, prepared by a member of the Company's team to report, investigate or fix a fault in the Service or to suggest an improvement to it, as described in clause 10.5;

(g) "Consent Record" has the meaning given in Article 19;

(h) "Backup" means an encrypted copy of the Company's database and stored files, kept to recover the Service from loss or failure; and

(i) "Network Address" means the internet protocol (IP) address from which a device connects to the Service, or a part of it.

2.3 "Including" means without limitation. Where this Policy describes a period or a limit as "currently" or "normally" applying, it describes how the Service works on the date of this Policy; the Company may change it under clause 19.1 of the Terms, and will notify a material change under Article 20.

Article 3 — What This Policy Covers

3.1 This Policy applies to Personal Data Processed through the Application, the Website (including its pages for Events, Organizations and ratings, and its waitlist form), push notifications, Live Activities, Company Messages and the User's correspondence with the Company.

3.2 This Policy does not apply to services operated by others that the User chooses to open or share to from the Service, such as Instagram, Spotify, Apple Music, Apple Maps, Google Maps, Waze, a third party's ticket page linked from a listing posted by the Company under clause 9.6 of the Terms, or a Payment Processor's own pages. Those services handle Personal Data under their own terms and privacy policies.

3.3 Where an Organizer, its door staff or a Host receives information about Attendees through the Service, it may use that information only to administer the Event or Hangout, as clauses 15.3(d) and 15.7 of the Terms require. The Company controls what the Service shows them but is not responsible for what they do with information outside the Service.

3.4 Users may post Wains, captions, comments and messages that show or name other people, including people who do not use the Service. The User who posts is responsible for having every consent the law requires (clauses 6.5(c) and 12.2(a) of the Terms). A person who is shown or named may report the content in the Application or write to support@wainkum.app.

3.5 The Service is designed for Kuwait first. One Policy applies to every User. Where the mandatory law of a User's country of residence gives that User greater rights over Personal Data, those rights apply (clauses 22.2 and 23.4 of the Terms), and the Company may add a country annex to this Policy when it offers the Service in another country.

Article 4 — Data the User Gives Us

4.1 Account. To create an Account the User provides:

(a) a mobile telephone number, which is verified by a one-time code sent by SMS (or, once the Application offers it, by WhatsApp) and identifies the Account; it is never shown to other Users;

(b) a date of birth, which is required. The Service does not complete a registration without a date of birth or with one below the Minimum Age (Article 18). The User may choose in the Application whether it is shown on the User's profile;

(d) the User's Visibility Setting, "Everyone" or "Friends only". A new Account is set to "Everyone"; where the version of the Application in use asks the User to choose during registration, the User's choice applies instead. The User may change the setting at any time in the Application.

The Company assigns each Account a WainTag and a matching QR code. If the User sets a password, it is stored by the Company's authentication provider only in one-way hashed form; the Company cannot read it.

4.2 Optional profile details. The User may add a gender (self-declared and not verified, and used where a Host limits a Hangout by gender), languages spoken, favourite activities, what the User is looking for in the Service, a favourite song (as an Apple Music or Spotify link), the countries the User has visited ("Places I've been"), answers to profile prompts and Vibes.

4.3 Check-ins and Places. Each Check-in records the Place (its name, address, category and position), the time it began and ended and how it ended, and any rating, caption, Vibe or Wain the User adds. The Company also records Stamps earned, ratings the User gives Places, and the User's Saved Places.

4.4 Content and connections. The Company stores what the User creates or does in the Service, including:

(a) Wains, with their photo or video, caption, music, GIFs, overlays, the Place from which they were posted and the audience chosen;

(b) comments, likes and reactions;

(c) Direct Messages and Group Chat messages, including GIFs, Events shared into a chat and any location the User chooses to share in a chat;

(d) Message Requests, Friend Requests, Friendships, nicknames the User gives Friends, the Friends the User hides from, and Blocks;

(e) Hangouts, including the exact meeting point the Host enters; RSVPs, waitlist positions and invitations for Events and Hangouts; and Join Me invitations;

(f) ratings and comments the User gives Organizations, and an Organization's replies; and

(g) reports, appeals and requests the User sends, and the User's correspondence with support@wainkum.app.

4.5 Organizations. Where an Organization is involved:

(a) an application for an Organization Account collects the applicant's full name, e-mail address, mobile number, an optional Instagram handle and what the applicant says about the Organization, together with the Company's decision and any note on it. Applications are currently paused (clause 15.2 of the Terms); applications already made are kept as clause 14.2(k) states;

(b) an Organization Account's page holds its name, description, logo, Instagram handle and website, and its Events hold their title, details, Place, times, cover image, link, contact number and capacity and, under clause 15.8 of the Terms, any price, currency and refund rule;

(c) if an Organization enters payout details, the Company stores the account holder's name, the bank name and the IBAN; the Organization's owner sees them masked in the Application and Administrators see them in full. Each time payout details are entered, changed, verified or un-verified, the Company records who did it and when, with the account holder's name, the bank name and the last four (4) characters of the IBAN, never the full IBAN (clause 14.2(k));

(d) if an Organization names a User as door staff, the Company records that appointment and, if the User leaves the role, when the User left; and

(e) for Events that use Event Passes, the Company stores each Event Pass, each scan and its reversal, the member of door staff who scanned it, and any ban of a pass with its stated reason.

4.6 Website and waitlist. A person who joins the waitlist on wainkum.app gives an e-mail address; the Company also records the language of the page used and the date. The Company uses that e-mail address only to tell that person when Wainkum launches, does not add it to any other mailing list and does not use it for advertising.

4.7 The User must keep the information the User provides accurate (clauses 4.1 and 4.4 of the Terms) and may provide information about another person only where the User is entitled to do so (clause 12.2 of the Terms).

Article 5 — Data Collected Automatically

5.1 Device information. The Application sends the device model, system version, Application version and build, language and region setting, time zone and an identifier that Apple issues to the Application for that device (the "identifier for vendor"). The Company uses them to keep the User signed in on one device at a time (clause 4.3 of the Terms), to support older and newer versions of the Application, to help the User when the User contacts the Company, and to prevent abuse, including enforcing a termination or ban.

5.2 Notification tokens. When the User allows notifications, the Company stores the token Apple issues for sending push notifications to that device, and, while a Live Activity is running, the token for updating it (Article 12).

5.3 Usage information. The Application records, against the Account, which screens are opened, which features and controls are used, steps of registration, location and notification prompts and the answers given, the kind of a search and whether it found anything, shares, notifications opened and the start and end of each session. It records these only as categories and timings. It never records the words searched, the text of a message or caption, or a person's or Place's name.

5.4 Diagnostics. The Application reports errors (the part of the Application, an error code and a technical description) and measures how long the Service takes to respond. The Company uses these only to find and fix faults and keep the Service fast.

5.5 Network Address. Every request a device makes reaches the Company's servers and providers from a Network Address. The Company itself stores it only in a Consent Record (Article 19) and, for a short time, to protect sign-in and the waitlist against abuse (clause 16.4); the Company's providers also keep standard request logs under their own retention rules. The Company does not use a Network Address to locate the User.

5.6 Camera, microphone and photos. The Application uses the camera, microphone and photo library only when the User chooses to capture or pick a photo or video, and uploads only what the User posts. The Application removes embedded location and device information from Wain videos before upload, and deletes anything already uploaded for a Wain that is stopped or fails to post (clause 14.2(f)).

5.7 Face ID. If the User turns on Face ID to unlock the Application, the check is performed by the device's operating system; the Company never receives biometric data.

5.8 Country. The Company determines the country connected with the User's use of the Service, for example from the country code of the mobile number and from the location of a Check-in or Event, in order to apply the Minimum Age, to apply the content rules for that country (Article 9) and to show nearby Events.

5.9 What the Application does not collect. The Application does not access the User's contacts or address book, does not use the advertising identifier, does not track the User across other companies' applications or websites, and contains no third-party advertising or analytics software.

5.10 The Website. The Website stores the User's chosen theme and language in the browser's local storage, uses no advertising or analytics cookies, and loads its fonts from Google (clause 10.3(h)).

Article 6 — Location in Detail

6.1 Permissions. The Application asks for location access "While Using the App" to show the User on the map, find nearby Places and Check-in, and asks for "Always" access only so that it can check the User out automatically on leaving a Place and update the User's estimated arrival during a Join Me Trip. The User may refuse or change either permission at any time in the device's settings; the related features then stop working.

6.2 While the Application is open. The Application uses the device's precise location on the device to show the map and the User's position on it. To find nearby Places it uses Apple's mapping services, to which the device sends its location. Some requests to the Company's servers for nearby content carry a location, such as the position of a Place; the Company uses it to answer the request and does not keep it as the User's position.

6.3 At Check-in. A Check-in records the Place and the time (clause 4.3) and the device's position at that moment. The Place is shown to other Users according to the User's Visibility Settings (Article 7). The device's position is kept privately with the Check-in, is not shown to other Users, and is used on the Company's servers to find the people at the same Place ("people here").

6.4 Live Location while Checked-in. While the User is Checked-in, the Application reports the device's position periodically, including in the background. The Company keeps only the latest reported position and its accuracy, replacing it with each new report. It is used to detect that the User has left the Place and to check the User out automatically (acting only on a sufficiently precise position). It is not shown to other Users as a moving position (clause 2.1(i) of the Terms). It is deleted when the Check-in ends, unless another Check-in of the User is still open, and when the User turns location sharing off in the Application. A Check-in ends automatically no later than 24 hours after it began, whatever permission the User has given.

6.5 Not Checked-in. When the User is not Checked-in, the Application does not report the User's live position to the Company's servers, except during a Join Me Trip.

6.6 Join Me. When a Friend accepts an invitation and starts a Join Me Trip, the Application reports that Friend's position and estimated time of arrival to the Company, including in the background, while the trip runs. Only the Inviter sees them, as a moving position, and they stop being shown if not updated for ten (10) minutes. A trip runs for at most ninety (90) minutes. The Company clears the stored position when the trip closes and, at the latest, when the Inviter's Check-in ends; the record of the invitation and its status remains with the Inviter's Check-in. The invited Friend sees the Place, not the Inviter's live position, and the Inviter's Lock Screen may show the Friend's name and estimated arrival (clause 7.5 of the Terms).

6.7 Hangouts. The exact meeting point of a Hangout is shown only to the Host and accepted participants.

6.8 Wains. A Wain shows the Place from which it was posted for as long as it is visible, including after the User has checked out (clause 8.2 of the Terms).

6.9 Sensitive places. A Check-in at a home, workplace, clinic, place of worship or similar location can reveal a great deal (clause 7.3 of the Terms). The Company does not use Check-ins to infer a User's health, religious belief or other sensitive characteristics, and does not use them to build advertising profiles.

6.10 How to stop. The User can end location sharing at any time by checking out, turning location sharing off in the Application, using Ghost Mode, revoking the location permission or, for a Join Me Trip, stopping the trip. Deleting the Application stops reporting but does not check the User out (clause 7.1 of the Terms).

Article 7 — Who Can See the User's Data

7.1 Visibility Settings. "Everyone" shows the User's Presence, pin and public profile to every User while the User is Checked-in, including Users who are not the User's Friends. "Friends only" shows the User's name and photo to accepted Friends; other Users see an anonymous placeholder instead. A new Account is set to "Everyone" unless the User chooses "Friends only" during registration, where the version of the Application in use asks. The User can change the setting at any time in the Application. An Account in business mode is always shown as Everyone and is not counted among the people at a Place.

7.2 When a "Friends only" identity is shown to others. Even under "Friends only" (clause 11.2 of the Terms), the Service shows the User's name and profile to another User where the User has reached out to or engaged with that person through the Service, namely:

(a) to a person to whom the User has sent a Friend Request that is still pending;

(b) to Users who can see an Event or Hangout the User hosts, until twelve (12) hours after it ends;

(d) to the other participant in a Direct Message conversation that the User started, including by a Message Request; and

(e) to the other participants in a Place Chat, Hangout chat or Event chat in which the User has sent a message that is still visible, for as long as they remain in that chat. A participant who has checked out of a Place Chat no longer sees the User's profile through it, although the User's name stays on the User's messages for as long as that participant can still read them.

7.3 Ghost Mode, hiding and Blocking. Ghost Mode hides the User's pin, Presence, Check-ins and Wains begun while it is on from every other User, including Friends, except that a Join Me invitation shows the User to the invited Friend; it does not hide ratings or other activity outside Check-ins and Wains. Hiding from a particular Friend stops that Friend seeing the User's Presence, Check-ins, Wains, activity and Check-in notifications. Blocking removes the User and the Blocked User from each other's view and prevents further contact through the Service. These controls are enforced on the Company's servers; changes apply going forward and may take a short time to take effect (clause 11.2 of the Terms).

7.4 Check-ins. Other Users can see a Check-in only while it is open and, so that their maps can remove it, for a short period after it ends (currently up to twenty (20) minutes), and never where Ghost Mode, hiding or Blocking prevents it. The User's earlier Check-ins are otherwise visible only to the User, although the User's Stamps and recent activity shown to Friends in the Pulse feed may reflect them. Friends may be notified when the User Checks-in, subject to the User's Visibility Settings and notification settings.

7.5 Profile. Other Users who may see the User's profile under this Article see the details the User has chosen to add (clauses 4.1 and 4.2), the User's WainTag and Stamps, and the User's current Vibe. Changes of display name or avatar emoji may appear in Friends' Pulse feed. The User's mobile number is never shown to other Users.

7.6 Wains. A Wain is shown to the audience the Application offers when it is posted, subject to Visibility Settings, Ghost Mode, hiding and Blocking. The User who posted a Wain can see who has viewed and liked it (clause 8.2 of the Terms). Comments and likes on a Wain are visible to those who can see the Wain.

7.7 Chats. A Direct Message is visible to its two participants (Article 11). A Group Chat message is visible to every participant of that chat (clause 8.4 of the Terms). Where the User has read receipts turned on, the other participants can see when the User has read a message.

7.8 Hangouts and Events. Joining a Hangout or RSVPing to an Event may show the User's identity and attendance to the Host or Organizer and, as the Application shows, to other participants and to Friends. Where an Event uses Event Passes, the Organizer and its door staff see each Attendee's name and photo and the entries recorded (clause 15.7 of the Terms).

7.9 Ratings of Organizations. A rating and comment a User gives an Organization appear on the Organization's page in the Application and on the Website with the rater's first name and emoji (clause 8.7 of the Terms).

7.10 The Website. Event listings, Organization pages and ratings may appear on the Website, where persons without an Account and search engines can see them. The Website does not show who is attending an Event, the person behind an Organization Account, comments or mobile numbers. Profile photos, Organization logos and Event covers are kept in storage from which they can be displayed to others, so anyone who has the link to such an image can view it.

7.11 Outside the Service. Anything a User can see, another User can copy, screenshot or share outside the Service, including through the Service's own sharing features (clause 8.2 of the Terms).

Article 8 — How We Use Data and Why

8.1 The Company Processes Personal Data for the following purposes. Where the law of the User's country requires a legal basis for Processing, the basis is the one stated:

(a) to provide the Service the User has asked for, including the map, Check-ins, Presence, Wains, chats, Friendships, Hangouts, Events, Event Passes, notifications, data download and Account deletion, as necessary to perform the Agreement;

(b) to provide location features (Article 6), on the basis of the User's own action, such as Checking-in or starting a Join Me Trip, and the location permission the User grants, which the User may withdraw at any time;

(c) to keep the Service safe and lawful: Automated Content Checks (Article 9), reports, review of content and conduct, enforcement of the Terms and protection of minors, on the basis of the Company's legitimate interest in a safe service, the Agreement and the Company's legal obligations;

(d) to secure the Service and prevent abuse: sign-in protection, limits on requests, one device at a time, detection of ban evasion, investigation of misuse, and the records of changes and Administrator actions described in clause 14.2(o), on the basis of the Company's legitimate interest and the Agreement;

(e) to communicate with the User: service, account, safety and moderation notices, Company Messages and replies to the User's requests, on the basis of the Agreement and the Company's legitimate interest;

(f) to improve the Service and fix faults, using the usage categories, diagnostics and Fault Reports described in Article 5 and clause 10.5, and records drawn from the Account, namely the User's gender, age band, the country code of the mobile number, Visibility Setting and Ghost Mode, device model, system version and Application version, Check-ins (including the Place), and the User's other actions in the Service, such as posting, watching or liking Wains, comments, messages and reactions, RSVPs, creating Events and Hangouts, Friend Requests, ratings, Blocks and reports, each with its date and time but without the text of a message or comment; authorised Administrators may view these for an individual Account, as totals and as a dated list of actions, on the basis of the Company's legitimate interest;

(g) to support Organizations, Events, Event Passes, door staff and, once offered, Tickets and payouts, as necessary to perform the Agreement with the Organizer and the Attendee;

(h) to keep the waitlist and send the launch e-mail, on the basis of the request the person made by joining it; and

(i) to comply with law, respond to lawful requests from competent authorities, keep proof of what each User accepted (Article 19), keep financial records, including the record of changes to payout details (clause 14.2(k)), and establish, exercise or defend legal claims, on the basis of the Company's legal obligations and legitimate interests.

8.2 The Company does not sell or rent Personal Data, does not use it for advertising or to build advertising profiles, and does not share it with data brokers. The Company may use aggregated statistics derived from use of the Service that do not identify any person (clause 16.3 of the Terms).

8.3 The mobile number, date of birth and display name are required to create an Account; without them the Service cannot be provided. Other profile details are optional. Withdrawing a permission or consent does not affect Processing that took place before it was withdrawn.

Article 9 — Automated Content Checks and Artificial Intelligence

9.1 What is checked. To keep the Service safe and within the law of the country in which it is used, the following may be checked by an artificial intelligence system when posted, afterwards, or both: display names, WainTags, profile prompt answers, Vibes and profile photos; Hangout and Event titles, details, place names, links, contact numbers and cover images; and Wain captions, images, thumbnails and still frames sampled from Wain videos.

9.2 What is not checked. Direct Messages, Group Chat messages (including Place Chat messages) and comments on Wains and Events are not submitted to Automated Content Checks (clauses 8.4 and 14.2 of the Terms). Comments and Group Chat messages may still be reported and reviewed under clause 14.3 of the Terms, and content may be hidden automatically once a set number of Users (currently three) have reported it.

9.3 Who performs the check. The checks are performed by OpenAI, L.L.C. as a Service Provider. It receives the item being checked, the kind of field it came from and the instructions described in clause 9.4, with no mobile number, Account identifier or location attached. Under the terms that apply to the Company's use, OpenAI does not use this content to train its models.

9.4 Results. The rules and thresholds differ by country: for example, content that is unlawful in Kuwait may be treated differently from the same content posted by users outside Kuwait. A clear violation may be held back or removed and the User is notified; an uncertain result may be published and reviewed later by a member of the Company's team; Events may be published first and reviewed afterwards. The Company keeps each result (including the verdict, its categories and the system's literal answer) linked to the content and the Account, for moderation, audit, appeal and legal purposes (clause 14.2(l)). It also keeps, without any Account attached, a fingerprint of checked text or images and the verdict, so that identical content is not sent for checking twice. To make the checks more accurate, text that a member of the Company's team has reviewed after a check may be included, without any Account details, as an example in the instructions sent with later checks. The number of checks one Account can trigger is limited (currently sixty (60) in an hour).

9.5 Review and appeal. Automated systems make mistakes in both directions. A User may ask for a review of any enforcement action by writing to support@wainkum.app within thirty (30) days (clause 14.5 of the Terms); a member of the Company's team will consider it.

9.6 Other uses of AI. The Company also uses artificial intelligence:

(a) to prepare descriptions of event listings it posts under clause 9.6 of the Terms, through OpenAI; these descriptions are prepared from the public details of the listing and use no User's Personal Data; and

(b) to analyse Fault Reports and help the Company's team plan and make fixes, through Anthropic, as clause 10.5 describes.

9.7 The Company does not use Personal Data to train artificial intelligence models of its own or of others.

Article 10 — Sharing with Providers and Others

10.1 The Company shares Personal Data only as this Policy describes. It does not sell or rent it.

10.2 Other Users, Organizations and the public. Personal Data is shown to other Users, to Organizers and their door staff, to Hosts and on the Website as Article 7 describes, and in Company Messages to the User as Article 12 describes.

10.3 Service Providers. The Company uses the following Service Providers, each of which Processes Personal Data on the Company's behalf:

(a) Supabase, Inc.: database, authentication, file storage, realtime messaging, server functions and hosting. Almost all of the Personal Data described in this Policy is stored with it;

(b) Apple: the App Store, the push notification service that carries notifications and Live Activity updates to the device (a notification may contain a person's name and the start of a message, depending on the User's settings), mapping and place search, address look-up, music previews and song look-ups, and, once offered, in-app purchases;

(d) OpenAI, L.L.C.: Automated Content Checks (Article 9) and descriptions of listings posted by the Company;

(e) GIPHY: when the User searches for a GIF, the search reaches GIPHY through the Company's servers without the User's Account details; the device then loads the chosen GIF from GIPHY, which receives the device's Network Address;

(f) GitHub: storage of encrypted weekly Backups (clause 14.3);

(g) Vercel: hosting of the Website and delivery of its pages and images; it receives the Network Address of each visitor;

(h) Google: the fonts used by the Website, which a visitor's browser loads from Google, so that Google receives the browser's Network Address;

(i) the provider that hosts the Company's e-mail, for messages sent to and from support@wainkum.app, which receives the content of those messages and the addresses they are sent from and to;

(j) Anthropic (AI analysis of internal fault reports): through its commercial service it receives each Fault Report for the analysis described in clause 10.5, under terms that do not allow it to train its models on that content; clause 10.6 describes the Company's separate use of Anthropic's development tool;

(k) once offered, Meta's WhatsApp for verification codes (it receives the mobile number), and Tap Payments and other Payment Processors for payments (the Company does not store full card numbers); and

(l) mapping, geocoding and content-delivery providers that help display the Service.

10.4 Independent Providers. Some Third-Party Providers receive Personal Data through the Service but handle it under their own terms and privacy policies, not on the Company's instructions:

(a) Meta, when the User chooses to share to Instagram Stories: the Application hands the image or video the User chose to the Instagram application on the device;

(b) Spotify, when the User adds a Spotify song link: the Application asks Spotify for the song's title and artwork, so Spotify receives the link and the device's Network Address, and opening the link opens Spotify;

(c) Apple, Google or Waze, when the User chooses to open directions in their maps applications, which receive the destination;

(d) Telegram (internal fault-report messaging), which the Company's team also uses for automated alerts about the health of the Service (clauses 10.5 and 10.6); and

(e) Anthropic, when the Company's team uses its development tool to plan and make fixes (clause 10.6).

10.5 Fault Reports. To report, investigate and fix a fault in the Service, or to suggest an improvement, a member of the Company's team may write a short note and take a screenshot of the Application. The team's rules require them to use test accounts where they can, to crop or cover other people's details, and not to include Direct Messages, mobile numbers or reported content. Even so, a screenshot may show what that team member's Account could see at that moment, such as a display name, profile photo, Group Chat message, Place, Event or position on the map. The Company uses these notes and screenshots only for this purpose. Once a Fault Report is sent, every member of the team who works on Fault Reports can see it, and a screenshot is sent to a team member only when that person asks for it. Anthropic's AI writes a short summary of each Fault Report for the team and helps the team plan and make the fix; it can see the note and any screenshot, and it makes no decision about any User. Fault Reports are not stored against any Account. Clause 14.2(q) states how long they are kept.

10.6 Telegram and Anthropic's development tool. Fault Reports are sent and stored through Telegram, a messaging service that stores what passes through it on its own servers under its own terms and privacy policy. The Company's team also uses Anthropic's AI development tool to plan and make fixes; for that use Anthropic handles what it receives, including the note and any screenshot, under its own terms and privacy policy, and may Process it outside Kuwait. The Company has turned off the setting that allows this content to be used to train Anthropic's models. Anthropic may keep this content for the periods its own terms allow, which may be longer for content its automated safety systems flag or where the law requires. Telegram and Anthropic are therefore not bound by this Policy for that content, and the Company cannot guarantee that it can remove copies they hold.

10.7 Legal disclosure. The Company may preserve and disclose Personal Data where required by law, a court order or a competent authority in Kuwait or elsewhere, or where necessary to enforce the Terms, respond to claims, protect any person's safety or address fraud or security (clause 14.7 of the Terms). Direct Messages are read or disclosed only as clause 8.4 of the Terms permits.

10.8 Change of operator. If the Agreement is transferred to an affiliate or a successor, or in connection with a merger, acquisition, reorganisation or sale of assets (clause 24.2 of the Terms), Personal Data passes to the new operator, which must continue to protect it under this Policy until it publishes its own, and the User will be told in the Application.

10.9 With the User's direction. The Company also shares Personal Data where the User directs it, for example when the User shares a Wain, a WainTag card or an Event link outside the Service.

Article 11 — Messages, Chats and Moderation Access

11.1 Direct Messages. Direct Messages are private between their two participants. They are processed automatically so that they can be delivered, stored and secured; they are not submitted to Automated Content Checks and are not routinely read by anyone at the Company. They are not end-to-end encrypted and are stored on infrastructure operated for the Company by its Service Providers (clause 8.4 of the Terms).

11.2 Message Requests. A User who is not a Friend may send a Message Request, limited to three (3) text messages until accepted. The recipient may accept it, remove it without the sender being told, or Block the sender, and may turn Message Requests off (clause 8.6 of the Terms).

11.3 Group Chats. Messages in a Place Chat, Hangout chat or Event chat are visible to every participant of that chat (clause 8.4 of the Terms), and sending one may show the User's identity to the other participants (clause 7.2(e)).

11.4 Place Chats. A User joins a Place Chat by Checking-in at the Place other than in Ghost Mode. After checking out, the User can no longer post and sees only the messages sent before checking out: for twenty four (24) hours if the User posted in that Place Chat during that Check-in, otherwise for two (2) hours, and in either case only while the Place Chat exists. Live updates stop at checkout. Leaving the chat in the Application removes it from the User's list at once. A Place Chat and its messages are deleted as clause 14.2(g) states.

11.5 Administrators. The Company's Administrators use the Application as other Users do: being an Administrator gives no special access in the Application to "Friends only" profiles, hidden or private Events, Hangout meeting points, rosters or conversations. The Company's administration tools give authorised Administrators access to Account information (including the mobile number), reports, moderation records, Events awaiting review and the other records they need to provide support, enforce the Terms, keep the Service secure and comply with law.

11.6 Reading a conversation. An Administrator can open a conversation, whether a Direct Message conversation or a Group Chat, only where a message in it, or the conversation itself, has been reported under clause 14.3 of the Terms. The Company records each such access, including which Administrator opened it and the report that allowed it, and keeps that record as clause 14.2(o) states.

11.7 Authorities. The Company may also preserve and disclose messages where required by law, a court order or a competent authority (clause 10.7).

Article 12 — Notifications and Messages from Wainkum

12.1 Push notifications. With the User's permission, the Application receives push notifications, including Friend Requests, Friends' Check-ins, messages, likes, Hangout and Event notices, "Still at [Place]?" reminders, automatic check-out notices and moderation, security and service notices, and silent background notifications that keep the Application up to date (clause 18.2 of the Terms). The User controls each category in the Application and the device's settings, except that account, safety and moderation notices are always on.

12.2 Friend Request notifications. Notifications of Friend Requests are limited (currently to one for each sender and recipient in any twenty four (24) hours, and to thirty (30) for each sender in any twenty four (24) hours); a Friend Request sent beyond those limits still reaches the recipient in the Application, without a notification (clause 11.1 of the Terms).

12.3 Live Activities. While the User is Checked-in, the Lock Screen and Dynamic Island may show a Live Activity with the Place and the Check-in, and, during a Join Me Trip, the invited Friend's name and estimated arrival. Anyone who can see the device can see them (clause 7.3 of the Terms). To update and end a Live Activity, the device gives the Company a token, which is deleted as clause 14.2(m) states.

12.4 Company Messages. The Company sends Company Messages to all Users or to particular Users, for example about an outage, maintenance, a fault or a security matter that affects them, and may send a particular User a message about that User's use of the Service (clause 18.4 of the Terms). Company Messages are not advertising. Authorised staff choose the recipients of a message to particular Users by name or WainTag. Decisions about a User's content or Account are notified separately. A push notification follows the User's All notifications setting; if it is off, the User sees the message inside the Application. Greetings to all Users, for example on a holiday, appear inside the Application only and are not sent as push notifications.

12.5 Records of Company Messages. When the Company sends a service message, to all Users, to the User personally or to a small group, it may record against the User's Account whether and when the message was shown to the User as a sheet, the User closed that sheet, the User opened it in the Pulse feed, or the User opened its push notification. Authorised Administrators can see this, message by message, to check that a notice got through and to help the User if the User asks about one. This record does not include the User's location or anything the User has written, and the Company does not use it for marketing or to decide what to send. Turning notifications off stops the push notification but not this record for messages seen inside the Application. For greetings sent to all Users the Company keeps totals only; for any other message sent to particular Users it keeps no such record or total. The Company also records that the User has closed a message so that it is not shown again.

12.6 E-mail. The Company e-mails a person only where that person has given an e-mail address, such as on the waitlist or in an application for an Organization Account, or has written to the Company. A person on the waitlist may leave it at any time as clause 17.4 states, and the Company does not e-mail anyone who has left it.

Article 13 — Where Data Is Processed and Transferred

13.1 The Company is established in Kuwait. Its Service Providers and Independent Providers operate servers in several countries, and Personal Data may be stored and Processed outside the country where the User lives, including outside Kuwait.

13.2 Wherever the Company's Service Providers Process Personal Data on its behalf, the Company requires that it be protected in line with this Policy, through the provider's contractual and data-processing terms and the security measures in Article 16. Where the law of the User's country imposes conditions on transferring Personal Data abroad, the Company will take the steps that law requires.

13.3 Independent Providers, including Telegram and Anthropic for the uses described in clauses 10.5 and 10.6, Process Personal Data under their own terms and in the places they choose; this Policy does not govern that Processing.

Article 14 — How Long We Keep Data

14.1 The Company keeps Personal Data only for as long as it needs it for the purposes in Article 8, for the periods below, or for longer where the law requires or where it is needed to establish, exercise or defend a legal claim, to deal with a report, or to protect a person's safety.

14.2 Periods by type of data:

(a) Account and profile: while the Account exists. A Vibe is removed from view after twenty four (24) hours and deleted shortly afterwards. A record of changes to a display name or avatar emoji, kept for Friends' Pulse feed, is deleted after thirty (30) days;

(b) Check-ins: kept while the Account exists, as the User's own history, with the device's position recorded at the time of each Check-in. Other Users can see a Check-in only as clause 7.4 describes;

(d) Join Me: the travelling Friend's position and estimated arrival are cleared as clause 6.6 describes; the invitation and its status are kept with the Inviter's Check-in;

(e) Wains: removed from view after twenty four (24) hours (clause 8.2 of the Terms). Shortly after that, or after the User deletes one, the Company permanently deletes the Wain and its files, including the still frames taken for Automated Content Checks, together with its comments and the record of who viewed and liked it. Records of moderation decisions about a Wain may be kept as paragraph (l) states;

(f) a stopped or failed post: anything already uploaded for a Wain that the User stopped before posting, or that failed to post, is deleted, normally within three (3) days;

(g) Place Chats: as clause 2.1(o) of the Terms describes, a Place Chat stays open until twenty four (24) hours after the latest Check-in that opened or renewed it and remains readable for a further twenty four (24) hours; the Place Chat and its messages are then deleted, normally within about forty eight (48) hours of that latest Check-in;

(h) Direct Messages, Hangout chats and Event chats: kept while the conversation exists and the sender's Account exists. A Hangout or Event chat that is no longer available to its participants (clause 9.3 of the Terms) is currently kept, and the Company may delete it at any time. A Message Request that the sender cancels is deleted for both participants;

(i) Hangouts and Events: deleted, with their RSVPs, comments, reactions, invitations, Event Passes, scan records and pass bans, normally about thirty (30) days after they end. An Event that was never published may be kept longer;

(j) ratings and comments on Organizations, Place ratings, Saved Places, Stamps, Friendships, hides, Blocks and nicknames: while the Account exists, unless the User removes them earlier where the Application allows;

(k) Organization records: an application for an Organization Account is kept while the applicant's Account exists. Payout details are kept while the Organization Account exists, unless removed earlier. The record of each change to payout details (clause 4.5(c)) is kept as a financial record and to investigate fraud and payment disputes for five (5) years after the change, including after the Organization Account or the Account of the person who made the change is deleted (clause 15.3(i)). A record that the User was door staff for an Organization is kept after the User leaves that role, while the User's Account exists, so that the Organization's door scan records can be read;

(l) moderation records: reports, the results of Automated Content Checks, notices of removal sent to the User (which may include the caption and Place of the content concerned) and related records are kept while the Account exists, except as Article 15 states;

(m) notification tokens: a push notification token is kept while it is valid for the User's signed-in device; a Live Activity token is deleted about seven (7) days after the Live Activity ends;

(n) usage, diagnostics and devices: individual usage records are deleted after ninety (90) days, and daily totals of them per Account are kept while the Account exists; error reports and response timings are deleted after seven (7) days; device records (clause 5.1) are kept while the Account exists;

(o) activity and Administrator records: the Company keeps an internal record of each change made in the Service to profiles, Check-ins, Place ratings, Places and Friendships, whether made by the User, by another User or by an Administrator, and of each Administrator action. Each record identifies the Account that made the change, where there is one, and the item concerned, and has a short description, such as the name of the Place of a Check-in, a rating, or a display name or avatar emoji. For thirty (30) days after it is made, a record also holds a copy of the item before and after the change, which for a Check-in includes the device's position recorded at the Check-in (clause 6.3) and for a profile may include the date of birth and the other details in clauses 4.1 and 4.2; the copy is then removed, and the record is deleted three hundred and sixty five (365) days after it was made. These records are available only to authorised Administrators, are not shown to other Users, and are used only for the purposes in clause 8.1(d) and to answer the User's requests. They are kept even where the item has since been changed or removed, and after the Account is deleted, as clause 15.3(c) states;

(p) Company Messages: records of which service messages reached the User (clause 12.5) are deleted thirty (30) days after they are made, or earlier if the User deletes the Account, after which only totals are kept. A note that the User closed a message is kept while that message is in use and for up to thirty (30) days after it ends. For a message sent to particular Users, the list of recipients and the record that a User closed it are deleted thirty (30) days after the message ends or is cancelled, and the message itself ninety (90) days after that date. Messages sent to all Users are kept;

(q) Fault Reports: a Fault Report is not stored against any Account, and the Company keeps a reference to each screenshot on Telegram rather than its own copy of the image. A Fault Report the Company has not finished with may stay open without an end date. Once it has not been worked on for ninety (90) days, and in any event no later than one hundred and eighty (180) days after it was first sent, the Company deletes the screenshot reference and erases the original note, keeping only a short summary written so as not to name anyone. The reference is also deleted within fifteen (15) days after a Fault Report closes, and all remaining text of a Fault Report, including any plan written from it, is erased within ninety one (91) days after it closes, after which only a record of its number, type and status remains, with no text. Copies may remain in Backups as clause 14.3 states, and with Anthropic and Telegram as clause 10.6 states; copies in Telegram's chat history, including copies sent to members of the team, stay on Telegram's servers and the Company may not be able to remove them;

(r) sign-in and waitlist protection: as clause 16.4 states;

(s) waitlist: an e-mail address, with the language of the page and the date it was given, is kept while the waitlist is in use and is deleted when its owner asks (clause 17.4). Waitlist entries are not currently deleted automatically;

(t) data downloads: the time of the User's last download of the User's data, kept while the Account exists, to limit how often a download can be made; and

(u) Consent Records: as Article 19 states.

14.3 Backups. Weekly Backups are encrypted and kept for up to thirty (30) days, and the Company's database host keeps its own short-term backups. Data deleted from the Service may therefore remain in Backups for up to thirty (30) days after its deletion, where it is not used except to restore the Service after a loss or failure.

Article 15 — Account Deletion and What Survives

15.1 The User may permanently delete the Account in the Application (Profile → Account → Delete account) or by writing to support@wainkum.app, in which case identity verification may be required (clause 19.2 of the Terms). Deletion is irreversible. Any Subscription bought through Apple must be cancelled separately through Apple.

15.2 Deletion permanently removes from the Service the User's profile, Check-ins, Wains, messages, Friendships, Hangouts, RSVPs, Stamps, ratings, device records, usage records and the other data linked to the Account, together with the User's uploaded photos and videos (which are removed by a separate process, normally within one day).

15.3 The following are outside that deletion:

(a) Consent Records (Article 19), kept as proof of what the User accepted or declined;

(b) the record of a blocked mobile number: where an Account was banned or removed, the Company keeps its mobile number, the reason and the date, without a fixed end date, so that the restriction continues to apply after the Account is deleted;

(c) activity and Administrator records (clause 14.2(o)), for the periods stated there, namely: records of changes made by or concerning the User before the deletion, including the User's Check-ins with the name of the Place, profile changes and ratings; a record that the Account was deleted; and, where an Administrator deletes the Account, for example on a request made under clause 15.1 or as an enforcement measure, a record of each profile, Check-in, rating, Place and Friendship removed with it, made in the Administrator's name. Copies of the items, which may include the position recorded at a Check-in, are removed thirty (30) days after the record was made, and every record is deleted three hundred and sixty five (365) days after it was made;

(d) Fault Reports (clause 14.2(q)): the User, or a Wain that has since expired, may remain visible in a screenshot or be named in a note, because Fault Reports are not stored against the User's Account;

(e) copies in Backups, for up to thirty (30) days (clause 14.3);

(f) records held by Third-Party Providers under their own retention rules, such as the verification records of the provider that sends SMS codes, and copies held by Independent Providers (clause 10.4);

(g) Company Message totals that identify no one, and aggregated statistics that identify no one;

(h) content that other Users have already copied, saved or shared outside the Service; and

(i) where the User entered, changed, verified or un-verified an Organization's payout details, the record of that change (clause 14.2(k)), which names the User as the person who made it, for the period stated there.

15.4 Messages and content of other Users, such as the other participant's side of a conversation, are not deleted when the User's Account is deleted.

Article 16 — Security

16.1 The Company protects Personal Data with measures appropriate to the Service, including:

(a) encryption of data in transit between the Application or Website and the Company's servers;

(b) access rules enforced in the database itself, so that each request sees only what its User is allowed to see, and Visibility Settings enforced on the Company's servers, not only in the Application;

(c) Wains stored in non-public storage and displayed through time-limited links issued only to Users allowed to see them;

(d) passwords stored only in one-way hashed form, and limits on verification codes and sign-in attempts (clause 4.2 of the Terms);

(e) one signed-in device per Account at a time: when the User signs in on a new device, the Company signs out the User's other devices (clause 4.3 of the Terms);

(f) access to the administration tools limited to authorised Administrators, a report required before any conversation is opened, and a record kept of each such access (Article 11);

(g) encrypted Backups;

(h) an optional Face ID lock on the Application; and

(i) limits on how often Automated Content Checks, data downloads and other requests can be made from one Account.

16.2 No service can guarantee perfect security, and the Company does not warrant it (clause 11.3 of the Terms). The User must protect the User's own device, SIM card, verification codes and password (clause 4.2 of the Terms).

16.3 If the Company becomes aware of a security incident that is likely to affect the User's rights, it will take steps to contain it and will notify affected Users and competent authorities where and as the applicable law requires.

16.4 Sign-in and waitlist protection. To protect Accounts and the Website against automated abuse, when a device asks for a verification code, signs in or joins the waitlist, the Company:

(a) briefly records the Network Address the request comes from (the whole address for IPv4, and only the network part, the first 64 bits, for IPv6) and counts its requests each minute, without the Account, mobile number or e-mail address; these records are deleted automatically, normally within two (2) hours; and

(b) for wrong verification codes and passwords, counts attempts for each pair of a Network Address and mobile number, storing the Network Address only as a keyed hash that cannot be read back, together with the mobile number; these records are deleted automatically, normally about two (2) days after the last attempt.

The Company uses these records only to limit and lock attempts as clause 4.2 of the Terms describes. A copy caught by a weekly Backup may remain there for up to thirty (30) days.

Article 17 — The User's Rights and Controls

17.1 In the Application the User can:

(a) change Visibility Settings, use Ghost Mode, hide from particular Friends, and Block and report Users and content;

(b) turn location sharing off, check out, stop a Join Me Trip and change device permissions;

(c) control notifications, except that account, safety and moderation notices are always on and Company Messages are sent by push notification while All notifications is on;

(d) turn read receipts and Message Requests off;

(e) edit or remove profile details, and delete content where the Application allows;

(f) download a copy of the User's data ("Download my data"): a file with the User's profile, Check-ins, Stamps, Friends, Events, Wains, the messages the User sent and the User's ratings and reviews. Photos and videos are not included; and

(g) permanently delete the Account (Article 15).

17.2 Subject to the law of the User's country and to the limits that law allows, the User may also ask the Company:

(a) for access to the Personal Data the Company holds about the User and information about how it is Processed;

(b) to correct inaccurate Personal Data;

(d) to restrict, or object to, Processing based on the Company's legitimate interests;

(e) for a copy of Personal Data the User provided, in a commonly used electronic format; and

(f) to find and remove a Fault Report that shows the User. The Company will remove the Fault Report, its screenshot references and any plan made from it from its own systems and ask its team to delete their copies; the Company's development history is not rewritten, and its rules keep names and personal details out of it; copies already with Telegram and Anthropic remain until their own terms allow them to be deleted.

17.3 Requests go to support@wainkum.app from, or naming, the mobile number of the Account. The Company may ask for information to verify the requester's identity before acting, and may refuse a request that is manifestly unfounded, excessive or would reveal another person's Personal Data. The Company aims to respond within thirty (30) days and will tell the requester if it needs longer.

17.4 To leave the waitlist, a person may write to support@wainkum.app naming the e-mail address that joined it, and the Company then deletes that e-mail address from the waitlist.

17.5 Where the law of the User's country gives the User a right to complain to a data-protection or other competent authority, nothing in this Policy limits that right (Article 22 of the Terms).

Article 18 — Age

18.1 The Service is only for persons who have reached the Minimum Age: twenty one (21) years if the Account is registered with a Kuwaiti mobile number (+965), and eighteen (18) years in every other case (clause 3.1 of the Terms). The Service is not directed at children, and the Company does not knowingly collect Personal Data from anyone below the Minimum Age.

18.2 The User must enter the User's own date of birth when registering. The Service does not complete a registration without a date of birth, or with a date of birth below the Minimum Age, and does not accept a later change of the date of birth to one below it. The Company relies on the date of birth provided and may request evidence of age or identity.

18.3 On becoming aware that an Account belongs to or is used by a person below the Minimum Age, the Company may suspend or terminate it and delete its data. Anyone who believes such a person is using the Service, including a parent or guardian, should contact support@wainkum.app.

Article 19 — Records of Consent

19.1 Each time a User accepts or declines the Terms or this Policy, the Company keeps a record (a "Consent Record") of: the Account; the mobile number of the Account at that moment; the document and version, with a fingerprint of the exact text shown; whether the User accepted or declined; the way the choice was made (at registration, on an update screen, or by choosing to sign out instead); the date and time recorded by the Company's server and by the device; the Network Address the request came from; the technical description of the application making the request (its user agent); and the Application version and build, device model, system version and language. For Accounts created before Consent Records began, the Company has reconstructed an earlier acceptance from the information it held, and marks it as reconstructed.

19.2 The Company keeps Consent Records after the Account is deleted, as proof of what the User agreed to, for as long as it may need them to establish, exercise or defend a legal claim (clause 24.4 of the Terms). The User may see the User's own Consent Records and may ask for a copy under Article 17.

Article 20 — Changes to this Policy

20.1 The Company may amend this Policy at any time. Each version states its version number and date, and earlier versions are kept.

20.2 Where a change is material, the Company will notify the User in the Application before or when it takes effect, normally by a single screen shown at launch that covers the Terms and this Policy together, and may require the User to accept the amended Policy before continuing (clause 24.1 of the Terms). A User who does not accept may sign out instead, and may delete the Account. Each acceptance and refusal is kept as a Consent Record (Article 19).

20.3 Non-material changes may be made by publishing the amended Policy in the Application and at wainkum.app/privacy.

Article 21 — Contact

21.1 Privacy questions, requests under Article 17 and complaints go to support@wainkum.app. Website: wainkum.app. Privacy Policy: wainkum.app/privacy. Terms: wainkum.app/terms.

21.2 Written notices may also be sent to Wainkum Integrated Computer Solutions Company, Capital Governorate, Qibla, Al-Mubarakiya Street, Osama Yousef Mohammed Al-Omar Building, Floor 1, Shop 9, State of Kuwait.

21.3 The Company does not provide emergency services; in an emergency in Kuwait call 112.

— End of Privacy Policy, Version 2.1 —