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Privacy Policy

This page explains what personal data Whoo collects, how we use it, who we share it with, and the choices you have.

Draft for legal review · not yet in effect · last updated 19 October 2026

The short version. We collect what we need to seat you at tables, run your chats and keep Whoo safe. We never sell your data and we don't use it for ads. We only train AI on your chats if you turn that on, and it's off by default. You can see, edit or delete what your Twin knows at any time. You can download or delete your data whenever you like.

1. Who we are and how to reach us

Xava Labs Hong Kong Limited, of 7F, 262 Des Voeux Road West, Sheung Wan, Hong Kong 999077, Hong Kong, is responsible for your personal data on Whoo. In data protection terms, we are the "controller".

This policy covers the Whoo app and our website. It works together with our Terms of Service.

2. What we collect and why

We collect data you give us, data created when you use Whoo, and a small amount of data from your device and app store.

DataExamplesWhy we use itLegal basisKept for
Account detailsEmail or phone, sign-in details, date of birth, language, countryCreate your account, confirm you're 18+, show Whoo in your languageContractWhile your account is open, plus 28 days
Mode and preferencesDating or Friends, gender, who you're interested inSeat you with people whose interest matches yours both waysExplicit consent (for gender and sexual orientation); contractWhile your account is open, plus 28 days
Your TwinYour 3-minute Twin chat; on Whoo Plus, Twin Talk and what your Twin has learnedBuild and run your Twin; help with seating and match reasonsContract; consent for AI processingUntil you edit or delete it, or close your account, plus 28 days
Session activityTables joined, who you chatted with, your Yes and No choicesRun sessions, make matches, avoid repeats within 7 days, improve seatingContract; legitimate interestsWhile your account is open, plus 28 days
MessagesSession chats, matched chats, translationsDeliver and translate messages, suggest replies, keep members safeContract; consent for AI processing and translationUnmatched session chats 30 days; matched chats while your account is open, plus 28 days
PurchasesPlan, renewal dates, unlocks used (payments are handled by Apple or Google)Give you what you paid for; meet tax and accounting rulesContract; legal obligationAs long as tax law requires
Safety recordsReports, blocks, moderation decisions, appealsInvestigate reports, enforce house rules, prevent banned people returningLegitimate interests; legal obligation1 year after a ban; longer for serious cases
Identity checks (only if we ask)ID image, age check resultConfirm age or identity when the law or a safety review requires itLegal obligation; legitimate interestsID images deleted within 30 days (up to 90 days in Japan)
Device and usage dataDevice type, app version, IP address, crash logsKeep Whoo working and secure, fix bugs, stop abuseLegitimate interestsUp to 1 year
Waitlist: emailsEmail addressConfirm your sign-up, email you about your seat and tell you when Whoo launchesConsentSee section 8
Waitlist: your seatNormalised email key, invite code, referrer (who invited you), place in line, when you signed up, confirmed and unsubscribedRun your seat: one seat per inbox (normalised key), let friends join with your code and count the invite (code, referrer), keep your place (place in line, times) and respect an unsubscribeLegitimate interestsSee section 8
Waitlist: seat linksOne-time sign-in link tokens, a device token for your seatLet you open your seat from an email link, and show your seat when you come back on the same browserLegitimate interestsSee section 8
Waitlist: sign-up checksA salted hash of your network IP address, normalised email keyStop duplicate and automated sign-upsLegitimate interestsSee section 8
Messages to usEmails to support, safety or privacyAnswer you and keep a recordLegitimate interests; legal obligationUp to 3 years [counsel to confirm]

We don't ask for photos and Whoo has no public profiles.

3. Sensitive data and how we ask for it

Your gender and who you're interested in can reveal your sexual orientation. Many laws treat this as sensitive data. Some, like Washington's My Health My Data Act and Nevada's SB 370, may also treat it as consumer health data.

Anything sensitive you choose to say in a chat is handled like the rest of your messages. Please share only what you're comfortable with. See our Consumer Health Data Privacy Policy for more.

4. How our AI uses your data

Whoo is AI-first. Here is exactly what our AI does with your data. More detail is on the Your Twin and Whoo's AI page.

No automated decisions with legal or similar effects. The AI never decides a match on its own. A match needs two Yes answers, given by members or, on Auto-Date, by a member's Twin. Seating changes who you meet, but it doesn't stop you using Whoo.

Your right to object. You can object to profiling for seating at any time by emailing privacy@meetwhoo.com. Seating would then use only the fixed rules and random order. [Counsel: confirm opt-out design.] In Korea, you can also refuse an automated decision or ask us to explain it.

Human review of moderation. Automated tools help us spot rule-breaking. A person reviews reports and appeals. If an automated decision affects your account, you can ask for a person to look at it.

5. Training our AI

We do not use your chats to train AI models unless you turn on "Help improve Whoo's AI". It is off by default. Your choice doesn't change how Whoo works for you.

If you turn it on, we remove names, contact details and other direct identifiers before using chats for training [To confirm with engineering]. You can turn it off any time in settings. We then stop using your new chats for training. [Counsel: confirm handling of data already used.]

Your Twin learning on Whoo Plus only shapes your own Twin. It is not used to train models for other members. Our contracts with AI vendors will not allow them to train their own models on your data. [Vendors to be listed; counsel to confirm terms.]

6. Who we share your data with

We never sell your personal data, and we don't use it for advertising. We share it only in these cases:

7. International transfers

Whoo is global, so your data may be processed outside the country where you live. When we move data out of the EU, UK or other places with transfer rules, we use legal safeguards. These include the EU Standard Contractual Clauses, the UK Addendum, and the EU-US Data Privacy Framework where a provider is certified. You can ask us for a copy of the safeguards at privacy@meetwhoo.com.

8. How long we keep your data

DataHow long
Account, Twin and matched chatsWhile your account is open, then deleted within 28 days
Unmatched session chats30 days
ID images (if collected)Deleted within 30 days; up to 90 days in Japan
Safety records1 year after a ban; longer for serious cases or where the law requires
Purchase recordsAs long as tax and accounting law requires
Device and usage logsUp to 1 year
WaitlistUntil 6 months after launch, or sooner if you ask us to delete your seat. Unsubscribing stops emails but keeps your seat. Unconfirmed sign-ups are deleted after [To confirm with engineering: X] days.

Backups are overwritten on a regular cycle. [To confirm with engineering: the cycle length.] We may keep data longer if we must by law or to deal with a legal claim.

9. Your rights and how to use them

Depending on where you live, you can:

How to use them. Many controls are in the app: edit or delete what your Twin knows, turn AI training on or off, download your data, and delete your account. Account deletion is also available on our website. For anything else, email privacy@meetwhoo.com.

We may need to confirm it's you. We reply within one month under the GDPR and UK GDPR, and within 45 days under US state laws. If we need more time, we'll tell you why. We won't treat you differently for using your rights. You can also use an authorised agent where the law allows.

10. Notices for US states

Laws in California and other US states give residents extra rights.

Make choices on our Your Privacy Choices page. If you live in Washington, Nevada or another state with consumer health data laws, read our Consumer Health Data Privacy Policy.

11. Korea, Japan and Brazil

Korea

Under the Personal Information Protection Act, we ask for consent item by item, and tell you which items are required and which are optional. You can refuse optional items and still use Whoo. You can refuse automated decisions or ask us to explain them. We tell you when you're dealing with AI, as the AI Basic Act requires. [Counsel: domestic representative and list of overseas transfers.]

Japan

Under the Act on the Protection of Personal Information, we tell you the foreign countries your data goes to and the safeguards in place. You can ask us to disclose, correct, stop using or delete your data. [Counsel: list of countries and their data protection systems.]

Brazil

Under the LGPD, you have the rights in section 9, plus the right to know who we share data with and the effects of refusing consent. You can contact our data protection officer at [DPO contact] or complain to the ANPD.

12. Our website and the waitlist

If you join the waitlist, we ask only for your email. We send a confirmation email, and you're on the list once you confirm. Every email has an unsubscribe link. Unsubscribing stops emails but keeps your seat. To delete your seat, email privacy@meetwhoo.com.

If a friend joins with your invite code, we link the two sign-ups so we can move you up the line. We check sign-ups for fake or automated entries. See our Invite rules.

We don't show a public waitlist count before launch.

Our website uses no cookies right now. It stores a few items in your browser to remember your sign-up. Details are in our Cookie Policy.

13. Children

Whoo is for people aged 18 and over. We don't knowingly collect data from anyone under 18. If we learn that someone under 18 has an account, we close it and delete their data. If you think a child is using Whoo, tell us at safety@meetwhoo.com.

14. Security

We protect your data with encryption in transit and at rest, access controls, and regular security reviews. [To confirm with engineering.] Only staff who need data for their job can see it. [To confirm with engineering.] No system is perfectly secure. If a breach puts you at risk, we'll tell you and the regulators as the law requires.

15. Changes to this policy

We'll update this policy when Whoo or the law changes. If a change is important, we'll tell you in the app or by email before it takes effect. If a change needs your consent, we'll ask for it.

16. Contact us

You can also use our contact page.

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