Privacy Policy

Last updated: 17.10.2026 · Version: 1.9

This Privacy Policy explains, in a clear and practical language, how we handle your personal data while you use the WIN platform (the "Platform").

Related documents (quick links)

1. Where is this policy applicable?

This policy applies to the following operated under the WIN brand:

• WIN mobile application (iOS/Android),
• WIN web domains (https://whoisnextapp.com/ (opens in a new tab) and https://legal.whoisnextapp.com/ (opens in a new tab)),
• help center / campaign pages that may be connected to the Platform (under these domains)

It is applicable to all of these.

If any feature or service requires a separate privacy text, it will be provided to you separately and that specific text will apply with priority.

2. Our approach to privacy (design principles)

By the nature of a "social matching/dating" platform, we design the Platform without concealing the fact that some information will be visible, while aiming to provide the user with a control space.

Our core principles:

• Purpose limitation: We process data for purposes that are genuinely necessary to provide the Platform to you.
• Data minimization: We aim not to open unnecessary data fields and, if opened, not to retain data unnecessarily.
• Layered transparency: We build bridges between documents for users who want detail (KVKK, Cookie, Explicit Consent, Biometric).
• User control: We base our approach on enabling you to manage permissions and consents (and withdraw them).
• Security and abuse prevention: We focus on reducing risks of fake accounts, spam, harassment, and fraud.

3. How does "visibility" work on the Platform?

The core function of WIN is that you create a profile, view profiles and make picks, and message once the picked person starts the chat. Therefore, some of your information may be visible to other users.

4. What information do we collect? (details by WIN flows)

In this section, we explain "which data is generated at which step" based on typical Platform flows. For the legal framework and data categories table, the KVKK Information Notice should also be reviewed.

4.1 Account creation and login (Google / Apple / phone)

Login to WIN may be provided via Sign in with Google (OAuth), Sign in with Apple (iOS devices only) or phone number login (SMS/OTP).

Sign in with Google: Google transmits the information it states will be shared from your account with the Platform. Typically, name (or Google profile name), e-mail address, profile photo, and Google user ID (technical) may be received. The e-mail address is generally considered verified in line with Google processes. After profile creation, phone number verification may be required for certain interactions such as making picks and sending messages; until this verification is completed, related functions may be restricted.

Sign in with Apple (iOS): Apple transmits the information you choose to share during sign-in: a technical user identifier that Apple creates for your account, an e-mail address (if you use Apple's "Hide My Email" option, a relay address generated by Apple that forwards to your real address) and, if you choose to share it, your name (Apple generally provides this only at the first sign-in). With Sign in with Apple, too, phone number verification may be required for interactions such as making picks and sending messages.

Phone login: Identity verification is OTP-based. E-mail verification and phone number verification steps are positioned to be completed during the profile creation process rather than at the moment of registration.

4.2 Legal consent & explicit consent layer (first login)

At first use, links to KVKK texts and agreements are presented, and separately selectable permission/consent checkboxes are shown. Example consent topics:

• Processing of location data
• Selfie/face verification
• Matching preferences and compatibility parameters
• Cross-border transfer (cloud infrastructure / providers)
• Campaign and notifications (commercial communication)

Detailed texts: Explicit Consent Texts and Biometric Data Notice and Consent.

4.3 Profile creation (basic fields)

In the onboarding flow, the following profile fields are typically collected. For users who use phone number login, e-mail and phone verification steps are also completed during this profile creation process.

• Profile name (max 16 characters)
• Date of birth (your age is calculated from it)
• Place of birth and optional time of birth (for astrology features; see Section 4.5)
• Gender
• Profession
• Height
• Smoking / alcohol frequency
• Sign
• Profile note (Bio) (max 50 characters)

4.4 "Value & compatibility" parameters (sensitive field risk)

In WIN, there may be some "importance level" questions to increase matching compatibility. Example:

• "How important is religion in your life?" (Options: I do not believe, Not central in my life, Important, Very important)
• "How important is the political view of the person you will match with for you?" (Options: I am not interested in politics, They may have a different view, Important to some extent, It is very important that we share the same view)
• "How important are appearance / financial status?"

Some of these questions may involve processing data that is special category personal data or may create inferences in that direction. Therefore:

• an additional information and explicit consent approach is adopted for relevant fields,
• the highest possible privacy and security standards are applied,
• we aim to enable you to manage your preferences for these fields.

For the legal framework: KVKK Information Notice and Explicit Consent Texts.

Your profile typically contains 6 photo slots. In order to maintain safety on the Platform, uploading at least one photo where your face is clearly visible and completing the selfie verification step is required as a rule.

Picked You preview (from version 2.0): If the person you pick has the profile gender "Male" and no active WIN Premium subscription, their "Picked You" list may show only a reduced (24-pixel), blurred copy of your first profile photo; your name and age are not shown. This copy is generated at the time of the request and is not stored on the server. Details: Subscription and Purchase Terms Section 3.8.

Selfie Verification Flow:

• Instant capture is made only via the front camera; photos cannot be uploaded from the gallery.

• We perform pose and profile photo consistency checks with Google Gemini 2.5 Flash; and inappropriate content checks on the selfie with safeSearchDetection (Google Cloud Vision).

• This step is a functional requirement to prevent fake accounts; as a rule, if consent is not given or at least one photo is not verified, the account is not included in the discovery flow (Deck). WIN may, by administrator decision and in limited cases, grant an exception to this rule for certain accounts; in that case no verification badge appears on unverified photos. It is therefore not guaranteed that every profile in the discovery flow is verified; you can see whether a photo is verified from the badge on it.

• A green checkmark/badge is placed on each verified photo. Verification is not performed on photos with other people; the verification badge appears only on photos where only the user is present.

• During photo upload:

• gallery/camera access permissions,

• photo files and technical metadata (e.g., file size, format)

may be included.

Note: It is intended not to perform biometric inference from your photos; however, features such as selfie verification are managed with separate texts as they may create an additional biometric assessment risk.

4.5 Birth details and astrology features

During profile creation you are asked for your date of birth together with your place of birth (country / province / district) and your time of birth. The place of birth must be filled in at this step; if you do not know your time of birth you can tick "I don't know" (in that case "unknown" is stored instead of a time).

• What is processed? The name of the place of birth; its approximate coordinates (at settlement level) and time zone; the time of birth or the "unknown" flag; and the zodiac sign and natal chart results calculated from these.
• How? The coordinates of your place of birth are obtained through your device operating system's address resolution (geocoding) service (Apple on iOS, Google services on Android). Natal chart and astrological compatibility calculations run on WIN's cloud infrastructure (Google Cloud).
• Why? To show your zodiac sign and to provide natal chart and astrological compatibility analyses (detailed analyses are part of WIN Premium).
• Visibility: Your place and time of birth are not shown to other users on the profile screen; other users may see your zodiac sign and (where offered) the astrological compatibility result between you and them. However, so that astrological compatibility can be calculated, when your profile appears in another user's deck your date of birth, time of birth and place of birth (including the place name and its approximate coordinates) are technically transmitted to that user's app; this information is not displayed on that user's screen.
• Legal basis: Provision of the astrology features (performance of the contract, KVKK Art. 5/2-c). Details: KVKK Information Notice.

4.6 Location (approximate/precise) and distance

WIN uses location information to show nearby users. Location history is not kept; location data is obtained instantly via GPS or network signals when the app is opened and used in distance calculations. If location permission is not granted, location-based features may be limited. Permission management: device settings and KVKK Information Notice (location and cookie/SDK tabs).

4.7 Selfie / liveness verification (camera permission) and microphone permission

Selfie/liveness verification may be applied to reduce fake accounts and increase user trust. In this flow camera permission may be requested.

The selfie verification images are intended not to be displayed on the profile; for the processing, retention, and destruction approach in this area: Biometric Data Notice and Consent.

4.8 Face data — collection, use, sharing, and retention (single summary)

In line with our Platform transparency commitment, we summarize in this Privacy Policy what is meant by face data. For the detailed legal framework, consent text, and provider tables: Biometric Data Notice and Consent.

What is collected? In the verification flow: a selfie image captured instantly with the front camera (gallery upload is not provided); requested pose/liveness verification; technical outputs produced within face verification performed between the selfie and your profile photos (e.g., similarity score, match/verification result, status information); limited processing metadata (e.g., verification time, number of attempts, error code); and security logs for security and objection processes. General photo uploads published on the profile and verification selfie are designed separately; it is intended that the verification selfie is not shown on the profile.

For what purposes is it used? To increase the likelihood that the profile belongs to a real person, reduce fake accounts and abuse, protect Platform security and service integrity; to conduct reviews in verification objections; and to comply with legal obligations and protect rights. Face/biometric-type data processed in this scope is not used for ad targeting, marketing profiling, or campaign personalization.

Third parties and storage location The verification process may be used for limited automated evaluation with Google Gemini 2.5 Flash (pose and profile consistency / person verification) and Google Cloud Vision (safeSearchDetection — inappropriate content control). As infrastructure, hosting and technical logs may be involved on the Google Cloud / Firebase side. Retention of a permanent biometric template or embedding is not intended. Provider roles and location/transfer details are explained in Biometric Data Notice and Consent and KVKK Information Notice.

Retention period Data in the nature of a biometric map subject to face recognition processing is immediately destroyed after verification is completed. In the system, a non-biometric status such as "verified: yes/no" may be kept. Non-biometric audit/technical metadata records kept for process security may be retained for a limited period within legal limitation and legitimate interest periods. Consent withdrawal and exceptional long-retention cases: Biometric Data Notice and Consent Section 9-10.

Other related sections: 4.2 (consent layer), 4.4 (profile photos and verification flow summary), 4.7 (permissions and microphone note).

4.9 Messaging and interactions

When you use the Platform, the following types of data may be generated:

• Interactions: Like/dislike, matching, dual picking, and profile view logs.
• Evaluation: After the chat starts, users exceeding a specific interaction threshold are provided with a voting tool that allows evaluating the other party on Intelligence, Politeness, and Fun attributes. These scores are included in profile average.
• Messaging: Message content and timestamp metadata. Messages are not end-to-end encrypted; they may be reviewed by admins/moderators for moderation and security purposes.
• Voice messages (WIN Premium): The audio recording (audio file) you send, its duration and the time it was sent. Audio files are stored on Google Cloud / Firebase Storage; within the app only the two parties to the chat can access them and, like text messages, they may be reviewed by authorised admins/moderators for moderation and security purposes. As a rule, voice messages are removed from the chat automatically 30 days after they are sent; a copy of the removed voice message (the audio file and the message record) is kept for security and legal-claims purposes in a legal archive (the chat archive) with access limited to authorised staff (see Section 9). No voice recognition or biometric analysis is performed on your recordings.
• Security signals: Complaint, blocking, and suspicious behavior records.

This data may be used to operate the matching experience, prevent abuse, and manage disputes.

4.10 Premium subscription features

Additional privacy and visibility features may be offered under Premium subscription:

• Continued choosing: Ability to keep choosing after the free allowance has been used (see Section 3.7 of the Subscription and Purchase Terms).
• Deck allowance: 12 decks that renew every 12 hours.
• Near the top: Appearing near the top of the "PICKED YOU" list of the person you picked.
• Deck filtering: Ability to filter decks.
• Hide Profile: You can completely hide your profile in decks. In this case, only people you picked can see you (in their own "PICKED YOU" sections).
• Online (Online/Offline) Status: Ability to view other users' activity status.
• Score Viewing: Ability to view your own score and the scores users gave to you and others.
• Priority access to new profiles: Priority access to newly joined profiles in decks.
• Astrological compatibility: Detailed astrological compatibility analysis.

For contractual framework and payment details: Subscription and Purchase Terms should be reviewed.

4.11 Support, complaints, objections, and security notifications

When you submit a notification via "Report" or "Block" buttons on profile cards and chat screens, your support record, correspondence, and review notes may be processed.

Related documents:

• Community Guidelines
• Law Enforcement Guide
• Illegal Content Notification Form (for official authorities)
• Security Vulnerability Disclosure Policy
• Transparency Reports

4.12 Automatically collected technical data (device, logs, cookie/SDK)

When you use the Platform, some data is generated/collected automatically. Example:

• Device and app information: device model, operating system version, app version, language/country settings
• Network and security information: IP address, session/log records, error/crash data
• Identifiers: app installation/device identifier (see Section 4.13), device identifiers and advertising identifiers (IDFA/GAID; on iOS the IDFA only if you grant "App Tracking Transparency" permission)
• On web side: cookies and pixels/tags via technologies such as Wix and GA4
• In mobile app: analytics, error/crash and performance signals collected via Firebase SDKs (Analytics, Crashlytics, App Check, Cloud Messaging); advertising measurement (attribution) signals collected via the Meta (Facebook) and TikTok SDKs; subscription/purchase records processed via RevenueCat (see Section 4.14)

This data may be used for secure operation of the Platform, debugging, performance measurement, prevention of abuse, and (depending on your preference) analytics/marketing measurement purposes.

For detailed explanation and preference management: Cookie Policy.

4.13 Single-device session and installation identifier

As a rule, your WIN account can be signed in on one device at a time. To ensure this, the app uses an installation/device identifier for each installation and stores it on your account:

• Android: A random installation identifier generated by the app on first launch (it starts with "wn-").
• iOS: The identifier Apple provides per device for each app developer (IDFV).

When you sign in from another device, your account moves to that device and the session on the previous device is closed. The same identifier and your IP address are also used in device- and IP-based sending limits to prevent abuse of SMS verification codes. On Android, to detect whether the identifier was carried over to another phone from a backup, a signature made of the device manufacturer/brand/model is kept only on your device; it is not sent to the server (on iOS this check uses the IDFV itself, which is also stored on the account). WIN uses this identifier for the single-device session and account security (on iOS the same IDFV value may also be collected by our subscription infrastructure provider; see Section 4.14). Legal basis: performance of the contract and legitimate interest (account and service security).

4.14 Subscription infrastructure and advertising measurement (attribution) partners

• RevenueCat (subscription infrastructure): Purchases are made through the Apple App Store / Google Play; RevenueCat, Inc. (USA) is used to validate your subscription and one-time purchases, link them to your account and manage them. Your WIN user ID, purchase/subscription records (product, price, currency, transaction and renewal/cancellation information) and device/app information are transmitted to RevenueCat. In addition, so that advertising campaigns can be measured, device identifiers (on iOS the IDFV and—if you allowed it—the IDFA; on Android the Google advertising ID/GAID and the Android device ID/Android ID), your IP address, the anonymous ID assigned by Meta and, on iOS, Apple Search Ads attribution data are transmitted to RevenueCat; RevenueCat may forward purchase and renewal events together with these identifiers to Meta and TikTok.
• Meta (Facebook) and TikTok (advertising measurement): To measure the effectiveness of our advertising campaigns (to understand which ad led to an app download, registration or purchase), Meta Platforms and TikTok software components (SDKs) are included in the app. These SDKs transmit app events such as app open, sign-up, registration completion (with gender), login, making a pick and purchases to the respective platforms together with your WIN user ID; for the pick event also together with the WIN user ID of the person you picked (a technical, pseudonymous identifier); and together with device information and—where permitted—the advertising identifier. Your e-mail address and phone number are transmitted to TikTok only if you have given both your marketing consent and your consent to transfer abroad. Meta and TikTok may also use this data under their own policies to improve ad delivery on their platforms. WIN does not share your message contents, photos or device location (GPS) with these platforms.
• Your permissions: On iOS the advertising identifier (IDFA) is shared only if you grant "App Tracking Transparency" (ATT) permission; you can change this under Settings > Privacy & Security > Tracking. On Android you can reset or delete your advertising ID in the device settings.
• These providers may be located abroad; for the transfer framework see Sections 7–8 of the KVKK Information Notice. The Facebook login option has been removed from the app; the Meta SDK is present solely for advertising measurement.

5. What do we use this information for? (purposes — practical explanation)

For details of legal bases under KVKK, the KVKK Information Notice applies. Here, we summarize the purposes as "what does this mean for the user?":

• To provide the service: create an account, show your profile, enable matching and messaging.
• To operate compatibility and recommendation systems: recommend more suitable profiles using profile fields, preference/importance parameters, location, and usage behavior.
• Security: reduce risks of fake accounts, spam/harassment, and fraud; review complaints; apply sanctions if necessary.
• Communication: send service notifications, updates, and (if permitted) marketing announcements. Your app usage status may be used to decide to whom and when marketing notifications are sent; your subscription and purchase status may be used to keep users who have made a purchase out of purchase reminders and to measure the effect of the notifications in aggregate; for details and the retention period, see the KVKK Information Notice Sections 6.1 and 9.
• Product development: measure performance, perform error/crash analysis, improve user experience.
• Legal compliance and protection of rights: fulfill legal obligations, preserve evidence in disputes, manage official requests.

6. Matching/recommendation system and "profiling"

In the matching and recommendation (deck) flow, WIN evaluates certain parameters together to produce profile ranking/compatibility. This process may in some cases be considered profiling.

6.1 Main signals used (general)

• Profile information: age, gender, height, sign, profession, etc.; how complete the profile is
• Preference/importance parameters: who you want to see, age range and choices such as appearance/financial status/political view compatibility
• Location/distance: proximity
• Activity and interactions in the app: being active recently, having newly joined, likes/passes, picks and matching patterns (within the Platform); profiles that have already appeared to you not being shown again for some time
• Verification, safety and moderation: verification status and badges, block/report relationships, moderation decisions
• Editorial selection: profiles highlighted by the WIN team for a limited time (not paid for)
• WIN Premium: subscription status (a WIN Premium membership may increase the likelihood of being shown in decks) and WIN Premium features (see Section 4.10)

The main parameters and their relative importance are explained in Section 12 of the DSA Compliance Page.

6.2 Discrimination and sensitive areas

Fields such as religion/political view require special attention both in terms of sensitive data nature and discrimination risk. Therefore:

• explicit consent and transparency are taken as basis in these areas,
• compatibility is targeted with the minimum data possible,
• users are intended to be able to manage their preferences.

If services are provided in the EU, an additional bridge may be established with the DSA Compliance Page in terms of recommendation system transparency.

7. With whom do we share your data? (short and clear)

For detailed transfer explanations and the framework of KVKK Articles 8-9: KVKK Information Notice.

8. Cross-border transfer (cloud services) — summary

The Platform may require processing of data abroad due to cloud infrastructure or certain service providers. For the cross-border transfer approach and consent/appropriate safeguard mechanisms:

• KVKK Information Notice
• Explicit Consent Texts

should be reviewed.

9. How long do we retain data? (logic)

The retention period of data varies according to processing purpose, legal obligations, and dispute/security needs.

Example:

• While your account is active: data required to provide the service is retained.
• Chat archive: Your chats are not deleted without being archived. When a chat or message is removed from the app, the messages and voice message files concerned are moved, before they are deleted, to a legal archive with access limited to authorised staff; archived copies are closed to other users and are not shown in the app again. This archive is retained for the relevant limitation periods for disputes and requests from authorities. This rule applies in particular in the following cases:
  • Account deletion: the messages and voice message files between you and the other parties,
  • Account deactivation (freezing): the message records of your chats that are removed from the other parties' message lists; the voice message files in these chats are not deleted when you deactivate your account and are moved to the archive and removed when their 30-day period expires,
  • Removing a person: the chat that is removed from both sides when you or the other party use the “Remove” option (including voice message files),
  • 30-day period of voice messages: voice messages removed from the chat 30 days after they are sent,
  • Unsent voice uploads: audio files that were uploaded but never attached to a message (for example, an interrupted send) are moved to the same archive when they are cleaned up.
• Voice messages: as a rule, removed from the chat automatically 30 days after they are sent. A copy of the removed voice message (the audio file and the message record) is moved to the chat archive above for security and legal-claims purposes and is subject to the retention period of the chat archive.
• When your account is deleted: your profile, photos, verification selfies, support attachments and sign-in record are deleted and your profile is closed to other users. However, not all of your data is deleted immediately; the following records are retained for the periods stated:
  • Copy of the deleted account: At the moment of deletion, a full copy of your profile record (excluding notification tokens) and the deletion reason you selected are retained for 90 days, with access limited to authorised staff, and are deleted automatically at the end of that period. For copies of accounts deleted before this retention rule began to be applied in September 2026, the 90-day period runs from the date the rule began to be applied. Purpose: abuse and fraud investigations, possible disputes and requests from authorities.
  • Chat archive: When an account is deleted, the messages and voice message files between you and the other parties are closed to other users and moved to the chat archive described above.
  • Banned accounts: If an account whose access was blocked for violating the Community Guidelines is deleted, the ban record of that account (WIN user ID, phone number, e-mail address where available and the reason for the ban) is retained without a time limit unless the ban is lifted, to prevent the banned person from opening a new account.
  • Other records: log/traffic records, moderation decisions and evidence of violations, and commercial/transaction records are retained for the periods in the legislation and in Section 9 of the KVKK Information Notice. Records held by third-party providers (e.g. subscription infrastructure, analytics and advertising measurement) are subject to the retention periods of the relevant provider.

For the detailed retention approach: KVKK Information Notice and Terms of Use — Section 13.

10. How do you manage your privacy preferences? (step by step)

11. Security

Security is ensured through both technical measures and user behaviors.

• For platform-level security approach and vulnerability disclosure channel: Security Vulnerability Disclosure Policy
• For users' safe usage: Security Tips

By the nature of the internet and mobile applications, nothing is ever 100% secure. WIN aims to apply reasonable technical and administrative measures; however, fully eliminating unauthorized access by third parties or data loss may not be practically possible. Therefore, you should also take basic measures for your account security and contact us in suspicious situations.

12. Children's privacy (18+)

WIN is not intended for individuals under 18. If you suspect a user is under 18, it is recommended that you use the in-platform reporting mechanisms.

13. Legal references (for information purposes)

In the Platform's data protection approach, the following regulations are considered to the extent applicable:

• Law No. 6698 on the Protection of Personal Data (KVKK)
• Communique on the Information Obligation under KVKK
• Regulation on the Transfer of Personal Data Abroad
• Law No. 5651 (log/traffic data approach)
• Law No. 6563 on Electronic Commerce and related secondary legislation (commercial electronic communication)
• Turkish Penal Code No. 5237 Articles 132-140 (privacy and confidentiality of communication)
• (If services are provided in the EU/EEA) GDPR and DSA

These references are shared to ensure transparency for users; concrete implementation details are provided in the relevant documents.

14) Changes and contact

We may update this policy over time. In case of significant changes, we may notify you in-app or announce via web.

For your questions, requests, and KVKK applications regarding this policy and your personal data, communication channels are available at: KVKK Information Notice. To exercise your KVKK rights, you may use the form on the KVKK Application Form page.