Wisher Pro’s privacy policy
This privacy policy (“Privacy Policy”) applies to the use of the website https://wisher.pro/ in its entirety, including all of our subpages, associated sites or pages (“Website”), and the Wisher Pro mobile app, which is accessible with your mobile phone (“App”) (collectively, “Wisher Pro”), are operated by Wisher Pro TOO, Satpayeva st., b. 85, 050046, Almaty, Kazakhstan (“we”, “us”, “our”). We are responsible for all information relating to an identified or identifiable natural and, where applicable, legal person (“Personal Data”) that we collect, process, and use during your use of Wisher Pro. This Privacy Policy outlines how we process your Personal Data both in connection with Wisher Pro and otherwise. The Website includes links to third-party websites, such as social networks. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We do not control these third-party websites, and we encourage you to read the privacy policy of those third-party websites.
1. Privacy-first approach
We are committed to protecting your privacy and handling your Personal Data in accordance with applicable laws and regulations.
To achieve this, we adhere to the principles of data minimization and purpose limitation.
We will only collect and process personal information that is necessary for the specific purposes stated in this policy.
Your data will not be used for any purpose other than those disclosed and we will only retain it for as long as required to fulfill these purposes or requests under applicable law.
We also prioritize transparency and respect for your privacy choices.
You have the right to access, correct, or delete your personal data held by us.
Your privacy is important to us, and we are committed to maintaining the highest standards of data protection and user control in order to make Wisher Pro a service that people love and trust.
2. What Personal Data do we collect
Some of the personal data we collect is mandatory for the provision and functioning of Wisher Pro, while other personal data is considered optional, designed to enhance your user experience.
Please be aware that without providing the mandatory personal data, we won't be able to grant you access to Wisher Pro.
When you visit the Website or App, we can process the following categories of Personal Data from you:
• Technical Data: IP address, operating system, date and time of access, country from which Wisher Pro is accessed, browser type, referrer URL, log-in data, and device type;
• Tracking Data: See Article 5 below.
When you create your Wisher Pro account, you voluntarily provide us with certain information. In this way, we can process the following categories of your Personal Data, which are either mandatory or optional for creating account and using Wisher Pro:
• Mandatory: gender (man, woman, or non-binary); account data, including User ID;
• Optional: email address (see Article 8 of the Privacy Policy); identity data, details about your address (personal description, age, height).
3. How do we use your Personal Data
We use your Personal Data to provide you with services, offer you support, communicate with you, or conduct other business operations, such as using data to improve and personalize your experience.
4. What legal basis do we rely on when processing your Personal Data
We process your Personal Data based on the following legal bases:
• Performance of contractual obligations: It is necessary for us to process your Personal Data to provide Wisher Pro to users and thus carry out our obligations under the terms and conditions of Wisher Pro (e.g., create user account, receive payments);
• Legitimate interests: It is necessary to process your Personal Data to pursue our legitimate business interests, provided that your rights and freedoms do not override these legitimate interests, which include but are not limited to the protection of Wisher Pro and enhancing the functionality and efficiency of Wisher Pro;
• Compliance with applicable laws and regulations: It is necessary to process your Personal Data to comply with our legal obligations (e.g., accounting, tax, and other statutory data retention obligations); and
• Your consent: If you choose to provide us with Personal Data that may be considered sensitive in certain jurisdictions, such as your sexual identity data, you are giving us consent to process that Personal Data in accordance with this Privacy Policy.
We will explicitly ask for your consent to collect specific Personal Data such as your precise geolocation, to transfer your Personal Data to countries without an adequate level of data protection (for more information please see Article 7 of the Privacy Policy), or to use your Personal Data for certain specific reasons (e.g. direct marketing). You may withdraw your consent at any time by contacting us as stated in this Privacy Policy.
You can exercise this right at any time and doing so won't affect the legality of processing your data that occurred before the withdrawal, as long as you were informed before giving your consent.
5. Online tracking and analysis
When using Wisher Pro, general access data is stored in a log file for the creation of statistics.
We use this data for statistical and technical evaluations in anonymized form, for example to optimize the server infrastructure, to determine on which days there are particularly many accesses, or to draw conclusions about possible improvements to the user interface and functionalities.
A personal evaluation of this data does not take place.
6. Social networks
There are links on our Website to our profiles on the following social networks:
• Meta Platforms Inc., 1601 Willow Road, Menlo Park, CA 94025, USA. Please find more information about data protection here.
• Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. Please find more information about data protection here.
If you click on the social network icons, you will automatically be redirected to our profile on the corresponding social network.
When you open a link to one of our profiles, a direct connection is established between your browser and the server of the relevant social network.
This provides the network with the information that you have visited Wisher Pro with your IP address and accessed the link.
If you access a link to a network while logged into your user account on the network in question, the content of Wisher Pro may be linked to your user account on the network, i.e., the network may link your visit originating from Wisher Pro directly to your user account on the social network.
If you want to prevent this, you should log out from your account before clicking on the corresponding links.
In any case, an association takes place when you log in to the relevant network after clicking on the link.
7. Data Transfers to Third Countries
We may transfer your Personal Data abroad to our business partners located in third countries, specializing in Analytics, Data Processing, Business Operations and Data Integration, Content Moderation, Marketing, and App Tracking.
To safeguard your data privacy rights when transferring your personal data to third countries, including those where adequate data protection might not be guaranteed, we use tools such as Standard Contractual Clauses (SCCs) - approved by the European Commission and other relevant data protection authorities, Binding Corporate Rules (BCR) and other appropriate mechanisms that ensure the personal data transfer complies with applicable laws and regulations.
These mechanisms are designed to provide a legal framework for the protection of your personal data during international transfers and demonstrate our commitment to maintaining the highest standards of data protection.
8. With which third parties do we share Personal Data
In alignment with data protection regulations, we prioritize transparency when it comes to the transfer of your personal data to third parties.
This section provides you with essential details regarding such transfers.
We may transfer your personal data to carefully selected third parties situated within or outside Switzerland when we have a business reason to engage these organizations.
Once again, we would like to emphasize that we consistently ensure compliance with legal requirements by using up-to-date necessary and recognized mechanisms, guaranteeing the confidentiality and integrity of your personal data's privacy and security throughout its processing and transmission to these third parties.
As we operate on a global scale, the recipient of shared Personal Data and the location data of processing may vary depending on your geographical location and other events.
Third parties are located and may process shared data in countries within the European Economic Area (EEA) and the European Union (EU) (including but not limited to Ireland, Belgium, Netherlands, Denmark, France, Germany, Cyprus, and Finland).
Additionally, data may be shared with other countries in Europe (including but not limited to the United Kingdom and Russia), as well as with Asia (including but not limited to Israel, India, Vietnam, Japan, Singapore, and Hong Kong).
Furthermore, data processing and sharing extends to third parties in North and South America (including but not limited to the United States of America, Canada, Mexico, and Brazil) and Australia.
9. What Personal Data do we share with third parties
In particular, we may disclose your Personal Data to the following categories of recipients:
• Service providers: We work with trusted service providers that process your Personal Data on our behalf or under joint responsibility (e.g., providers of telecommunications systems, email, database, hosting, outsourcing, payment, user verification, advertising, marketing, analytics, anti-spam, anti-fraud services). These service providers may also use your Personal Data for their own purposes. Service providers provide information about their independent data processing in their own privacy statements.
• Buyers or merger partners: In connection with an actual or potential restructuring of part or all of our business or our assets or any rights or interests therein, we may disclose your Personal Data to potential buyers or merger partners or sellers and their advisors.
• Government agencies: We may disclose your Personal Data to governmental agencies, courts, and other authorities, both domestic and foreign, if we are legally obligated or entitled to do so or if we deem it necessary to do so in order to protect our interests.
This disclosure aligns with our commitment to transparency, in accordance with relevant data protection laws and regulations.
Please refer to Article 7 of the Privacy Policy for detailed information on data sharing and protection practices.
10. What Personal Data do we receive from third parties
By signing in to Wisher Pro using your Apple ID, you give permission to Apple to share your Apple login, your name, and your email with Wisher Pro.
Apple offers an option to hide your email, so you can keep your email address private but still receive messages from the App.
To enable this, Apple will create a random email address, link it to your account on Wisher Pro, and allow your personal email to stay private.
11. How long do we retain your Personal Data
We only retain your Personal Data for as long as it is needed for the purpose for which it was originally collected or as we are required to retain it under applicable laws and regulations or contractual agreements.
If you manually initiate the deletion of a chat conversation which involves detected abuse, attempted scams, or other violations of our Terms and Conditions, Guidelines, or Privacy Policy, we will retain these chat conversations for an extended period in order to enhance our user’s safety.
This enables maintaining a secure environment while enhancing our ability to prevent potential risks, frauds, and undesirable activities and safeguarding crucial information, which is vital for our legitimate interest in ensuring the platform’s integrity and the user's well-being.
12. How do we secure your Personal Data
We use appropriate technical and organizational security measures to protect Personal Data from loss, misuse, or alteration.
Our employees and the service providers commissioned by us are contractually obliged to maintain confidentiality and to comply with the provisions of data protection law. However, it is not possible for us to guarantee the absolute security of Personal Data.
In this context, please note that data transmitted over an open network such as the Internet or an email service is openly accessible. We cannot guarantee the confidentiality of messages or content shared over these networks.
Thus, Personal Data sent to us via open networks will not be subject to the same security measures as Personal Data contained within Wisher Pro.
13. Your rights
You have the following rights:
• Access: You have the right to access your Personal Data. This gives you the opportunity to check what Personal Data we process about you and that we process it in accordance with the applicable data protection regulations.
• Rectification: You have the right to have inaccurate or incomplete Personal Data rectified and to be informed of the rectification.
In this case, we will inform the recipients of the data concerned of the adjustments made, unless this is impossible or involves disproportionate effort.
• Deletion: You have the right to have your Personal Data deleted under certain circumstances.
• Restrict processing: You have the right, under certain conditions, to request that the processing of your Personal Data be restricted.
• Data portability: You have the right, under certain circumstances, to obtain from us, free of charge, the Personal Data you have provided to us in a readable format.
• Lodge a complaint with a supervisory authority: You have the right to lodge a complaint with a competent supervisory authority about the way in which your Personal Data is processed.
• Withdrawal: You have the right to withdraw your consent to the processing of your Personal Data at any time, free of charge, and without giving any reason by contacting us at the address provided in this Privacy Policy.
Processing activities conducted with your consent in the past, prior to you revoking consent, do not become unlawful as a result of your revocation.
Please note that the above-mentioned rights are not absolute.
These rights are subject to exceptions and their applicability is largely dependent on the legal basis we rely on in each case and the various circumstances of each specific request.
14. Children's policy
We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children.
15. Changes to this Privacy Policy
We may change this Privacy Policy to address changes in the legislation or on Wisher Pro.
Changes to this Privacy Policy will take effect automatically after they are first posted on the Website or App.
16. Contact
If you would like to exercise any of your rights or if you have feedback, comments, or questions about data protection or this Privacy Policy please contact us by email at support@wisher.pro.