Privacy Policy

Effective Date: September 27, 2026
Company: HEKOM – Gjorgje DOOEL ("HEKOM DOOEL"), Depa Kavajova 21, 1000 Skopje, North Macedonia
Contact Email: winksi.app@gmail.com

This Privacy Policy explains how Winksi collects, uses, shares, and protects information. Winksi is a micro-location social network for adults aged 18 and over. It is not a dating application. It lets users connect with others who are pinned to the same venue (a "Point of Interest" or "POI").

1. Information We Collect

We collect only the information needed to operate Winksi.

• Account information: Your email address, your authentication credentials (handled by our authentication provider), and your date of birth.
• Age signals: Where supported and available, an age range provided by Apple Declared Age Range or Google Play Age Signals, and which platform provided it.
• Profile content: Your display name, profile photos, and short bio. Your numeric age is calculated from your date of birth.
• Location: Your device's precise location when you use Winksi's location features while the app is open. See Section 6.
• Pins and settings: The venue you pin to, when you pinned, and your history visibility setting.
• Connections and safety data: Winks, connections, blocks, and reports you submit or that concern you.
• Messages: Message content while in transit until delivery, and conversation snapshots collected when a conversation is reported. See Section 5.
• Technical and device data: IP address, device model, operating system, app version and build, crash and diagnostic logs, and push notification (FCM) tokens.
• Advertising data: Data processed by the Google Mobile Ads SDK. See Section 7.

2. How We Use Information

We use information to:

• Provide Winksi, including nearby venues, pins, venue lists, winks, connections, and messaging.
• Determine eligibility for our 18+ service.
• Review reports, moderate content, and enforce our Terms of Use.
• Protect the service against security threats, fraud, and abuse, including through usage limits.
• Diagnose problems and determine whether you are using a supported app version.
• Send service and transactional emails, such as account verification, security notices, report responses, and policy updates. We do not send marketing emails without your consent.
• Show advertising (see Section 7).
• Comply with legal obligations.

3. Age Requirement

Winksi is restricted to adults aged 18 and over.

• You must provide an eligible date of birth to complete your profile and use Winksi's features. If the date of birth you provide shows you are under 18, you cannot complete a profile or access the service.
• You cannot change your date of birth after your profile is created.
• Where supported and available, we use an Apple or Google age-range signal to check eligibility against the date of birth you provide. These signals are not available for all users and are not used for tracking.
• Date of birth and age are self-declared. Winksi does not otherwise verify a user's age or identity and cannot guarantee that every user has reported their age accurately.
• If we learn that an account belongs to someone under 18, we block its access to the service and may terminate the account. If we learn that we have collected personal information from a child under 13, we delete it.

4. What Other Users Can See

Winksi does not host a public feed. Profiles and content are not publicly available, not viewable by non-users, and not indexed by search engines.

• In venue lists (live and history), other users may see your display name, a thumbnail of your profile photo, and when you pinned.
• When they open your profile, they may also see your numeric age, short bio, and profile photos.
• Other users' apps also receive your internal account identifier and an age category used by the app. Your date of birth, email address, and precise GPS coordinates are not shown to other users.

Visibility rules:

• Current venue: You may appear to other users who are currently pinned to the same venue.
• Pin duration: You remain visible at a venue until you unpin, pin elsewhere, or your pin expires. A pin normally expires about six hours after your most recent pin or visibility update. Leaving the venue physically does not end your pin. The Unpin option may not be available immediately after pinning.
• Venue history: While you are pinned with history visibility on, you are also shown to users who open that venue in their History page, even if they are not at the venue. You choose whether history visibility is on each time you pin to a venue; it is on by default. You can turn it off at any time, including while pinned. Turning it off removes you from the history list while you remain in the live venue list. You leave a venue's history when you unpin, pin elsewhere, or your pin expires. A recently loaded list may briefly continue to show you.
• Blocking: Blocking prevents profile viewing, winks, connections, and private messages between the two accounts, and ends an existing connection. It does not by itself remove either account from live venue lists or venue history.

Winksi may moderate profile photos, bios, and reported content to enforce our rules.

5. Private Messaging and Report Moderation

Who can message: Messaging is available only between mutually connected users (both users have winked at each other).

No end-to-end encryption: Messages are not end-to-end encrypted.

On our servers: Undelivered messages may be stored temporarily on our servers. In the ordinary course, we remove them after the recipient's device confirms delivery. Offline message storage is set to expire after about 10 days, and database cleanup may occur shortly afterward.

On devices: Delivered messages are stored on the recipient's device. The app's periodic cleanup normally removes them after about 30 days. Ending a connection or blocking normally removes the conversation from view in the app, unless it is preserved because of a report.

Reporting a conversation: When you report a conversation, the app uploads a copy of recent messages from that conversation from your device. We store it on our servers as moderation evidence.

Corroboration from the reported user's device: Where technically possible, Winksi may ask the reported user's app for its copy of the same conversation, to help assess the reliability of the report.

• The reported user's app may keep this copy in a separate, encrypted form on their device, outside the normal chat view, until it is uploaded, the request expires, or local cleanup removes it.
• The reported user is not notified that a report was made.
• Corroboration is limited to messages from the reported conversation that are already on the device. It does not give Winksi access to other conversations or other device content.
• A pending corroboration request expires within 7 days, and no later than the reporting user's snapshot.

Retention and use of report evidence: Conversation snapshots, from the reporting user and, where collected, the reported user, are scheduled to expire 45 days after the report. A reported user's snapshot never expires later than the reporting user's snapshot. Database cleanup may occur shortly after expiry. Report records, such as category and status, are kept for about 1 year. Snapshots are used only for safety, moderation, and legal compliance. Comparing snapshots supports human review; it does not by itself decide or impose account sanctions.

Evidence on your device after sign-out: When you sign out or switch accounts, the app attempts to remove pending encrypted report evidence and its account-specific key from the device. Successful account deletion clears the app's local message data and triggers the same cleanup. Uninstalling the app generally removes app-local data under normal mobile operating system behavior, though secure-storage behavior can vary by platform.

6. Location Data

How we use location: When you use Winksi's location features while the app is open, the app obtains your device's precise location. It sends coordinates to our servers to find nearby venues and to identify the venue you pin. Winksi does not collect your location in the background.

What we keep: We store the venue you are currently pinned to, not a record of your movements. We do not show your GPS coordinates to other users. However, because other users can see that you appear at a venue or in its history, they may be able to infer that you are or were near that location.

Venue search cache: To reduce repeated lookups, we store rounded search-center coordinates and the venue results for that area as a shared service cache. This cache is not linked to your account. Cache entries are typically refreshed or marked to expire after about 180 days, and may be retained longer if the area is searched again.

Place data provider: We use Google Maps Platform to find venues. It receives the coordinates used for venue searches.

Usage limits: To enforce a daily limit on viewing venue histories, we keep a record of which venue histories you opened that day, for about one day.

On your device: The app keeps a list of up to 25 venues you have pinned to, so you can open their history.

Self-reported location: Pins are based on location data reported by your device. Winksi does not verify that anyone is physically present at a venue. A user may appear at a venue without being there, including through inaccurate, mock, or falsified location data. Do not treat a pin as proof of anyone's location.

7. Advertising

Winksi shows ads through Google AdMob. The Google Mobile Ads SDK in the app may automatically collect your IP address (from which general location can be inferred), device and advertising identifiers, ad interactions, app interaction information, and diagnostic information. Google uses this for ad delivery, measurement, analytics, and fraud prevention. Whether ads are personalized depends on your consent choices, device settings, and location.

Winksi does not intentionally include your Winksi account identifier, email address, date of birth, profile content, messages, or precise GPS coordinates in AdMob ad requests.

You can manage ad consent choices in the app where this option is available, and limit ad personalization in your device settings. Learn more about how Google uses information from apps that use its services.

8. How We Share Information

We share information only as follows:

• With other users, as described in Section 4.
• With service providers that operate Winksi for us: cloud hosting and storage (Amazon Web Services), database hosting (MongoDB Atlas), authentication and push notifications (Google Firebase), venue data (Google Maps Platform), and advertising (Google AdMob).
• For legal and safety reasons, when required by law or legal process, to report apparent child sexual abuse material as required by law, or to protect the safety of any person.
• In a business transfer, such as a merger or sale of assets, subject to this Privacy Policy.

Winksi does not sell personal information for money.

9. Data We Do Not Collect

Winksi does not collect:

• Contact lists.
• Payment, health, or biometric data.
• Location in the background.
• Message content after delivery, except conversation snapshots collected when a conversation is reported.

10. Data Retention Summary

Data	Retention
Account, profile, and FCM tokens	Until account deletion
Undelivered messages on our servers	Removed after delivery confirmation; otherwise set to expire after about 10 days
Delivered messages on devices	Normally removed by the app after about 30 days
Report conversation snapshots (reporting user, and reported user where collected)	Scheduled to expire 45 days after the report; the reported user's snapshot never expires later than the reporter's
Pending corroboration request	Expires within 7 days, and no later than the reporter's snapshot
Report records	About 1 year
Pin and venue history appearance	While pinned; a pin normally expires about 6 hours after the most recent pin or visibility update
Daily venue-history view record	About 1 day
Push notification queue data	Removed after successful sending in the ordinary course; temporary delivery metadata kept briefly for operations
Venue search cache (not linked to your account)	Typically refreshed or marked to expire after about 180 days; may be retained longer if the area is searched again
IP address and technical logs	As long as reasonably necessary for security and diagnostics

Scheduled deletions may occur shortly after the stated time. We do not promise immediate removal from backup systems; any backup copies are kept only for the backup's limited retention period and are not used for ordinary operations. We may keep information longer where the law requires us to preserve it, for example in connection with a report to authorities or a legal hold.

11. Security

We use reasonable technical and organizational measures to protect information, including encrypted connections between the app and our servers. No system is completely secure. Messages are not end-to-end encrypted.

12. Safety and User Interactions

13. Your Choices and Rights

• Delete your account at any time in the app, or by emailing us. See our Account & Data Deletion page.
• Access and correct: You can edit your profile in the app, except your date of birth. You can ask us for a copy of your information or a correction by emailing winksi.app@gmail.com. We respond as required by applicable law.
• Location: You can turn off location permission in your device settings. Location features will not work without it.
• Visibility: You can turn off history visibility, unpin once the option is available, and block other users.
• Advertising: See Section 7.

United States: Winksi does not sell personal information for money. Some U.S. state laws may treat advertising processing through AdMob as "targeted advertising" or "sharing." You can limit personalized ads through the in-app ad consent option where available and through your device settings. If a U.S. state privacy law applies to our processing of your information, you may exercise the rights it gives you by emailing us, and we will respond as that law requires.

EEA and UK: The contact email below is our data protection contact. EU and UK representative details will be added to this section before Winksi launches in regions where such representation is legally required.

14. International Processing

HEKOM DOOEL is based in North Macedonia. Our service providers may process information in other countries, including the United States and member states of the European Union.

15. Changes to This Policy

We will notify you of material changes to this Privacy Policy and may ask you to accept the updated policy in the app.

16. Contact

Company: HEKOM – Gjorgje DOOEL ("HEKOM DOOEL")
Address: Depa Kavajova 21, 1000 Skopje, North Macedonia
Email: winksi.app@gmail.com