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".
- Privacy questions and requests: privacy@meetwhoo.com
- Data protection officer: [DPO contact]
- EU representative: [EU representative]
- UK representative: [UK representative]
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.
| Data | Examples | Why we use it | Legal basis | Kept for |
|---|---|---|---|---|
| Account details | Email or phone, sign-in details, date of birth, language, country | Create your account, confirm you're 18+, show Whoo in your language | Contract | While your account is open, plus 28 days |
| Mode and preferences | Dating or Friends, gender, who you're interested in | Seat you with people whose interest matches yours both ways | Explicit consent (for gender and sexual orientation); contract | While your account is open, plus 28 days |
| Your Twin | Your 3-minute Twin chat; on Whoo Plus, Twin Talk and what your Twin has learned | Build and run your Twin; help with seating and match reasons | Contract; consent for AI processing | Until you edit or delete it, or close your account, plus 28 days |
| Session activity | Tables joined, who you chatted with, your Yes and No choices | Run sessions, make matches, avoid repeats within 7 days, improve seating | Contract; legitimate interests | While your account is open, plus 28 days |
| Messages | Session chats, matched chats, translations | Deliver and translate messages, suggest replies, keep members safe | Contract; consent for AI processing and translation | Unmatched session chats 30 days; matched chats while your account is open, plus 28 days |
| Purchases | Plan, renewal dates, unlocks used (payments are handled by Apple or Google) | Give you what you paid for; meet tax and accounting rules | Contract; legal obligation | As long as tax law requires |
| Safety records | Reports, blocks, moderation decisions, appeals | Investigate reports, enforce house rules, prevent banned people returning | Legitimate interests; legal obligation | 1 year after a ban; longer for serious cases |
| Identity checks (only if we ask) | ID image, age check result | Confirm age or identity when the law or a safety review requires it | Legal obligation; legitimate interests | ID images deleted within 30 days (up to 90 days in Japan) |
| Device and usage data | Device type, app version, IP address, crash logs | Keep Whoo working and secure, fix bugs, stop abuse | Legitimate interests | Up to 1 year |
| Waitlist: emails | Email address | Confirm your sign-up, email you about your seat and tell you when Whoo launches | Consent | See section 8 |
| Waitlist: your seat | Normalised email key, invite code, referrer (who invited you), place in line, when you signed up, confirmed and unsubscribed | Run 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 unsubscribe | Legitimate interests | See section 8 |
| Waitlist: seat links | One-time sign-in link tokens, a device token for your seat | Let you open your seat from an email link, and show your seat when you come back on the same browser | Legitimate interests | See section 8 |
| Waitlist: sign-up checks | A salted hash of your network IP address, normalised email key | Stop duplicate and automated sign-ups | Legitimate interests | See section 8 |
| Messages to us | Emails to support, safety or privacy | Answer you and keep a record | Legitimate interests; legal obligation | Up 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.
- We ask for your explicit consent before we use it, in a separate step at sign-up.
- We use it only to seat you with people whose interest matches yours, and for safety.
- We never show it to other members as a label, and never use it for ads.
- You can withdraw your consent by deleting your account. We can't seat you without it.
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.
- Your Twin. Your Twin is built from your 3-minute Twin chat. On Whoo Plus it keeps learning from Twin Talk, your own messages and your own Yes and No choices. It never learns from the other person's messages. You can see, edit or delete what it knows at any time, on every plan.
- Auto-Date. On Whoo Plus, if you turn it on, your Twin can chat for you in up to 5 chats a day. Those chats are stored so you can review them in Date Recap.
- Seating. Our AI picks who sits at your table, based on your Twin, your preferences and past sessions. This is profiling. Fixed rules come first: interest must match both ways, blocked people are never seated with you, and you won't meet someone you met in the last 7 days.
- Icebreakers, reply ideas and match reasons. Our AI reads the chat to suggest an opener or replies, and to explain a match. Reply ideas are never sent unless you choose them.
- Translation. Your messages are sent to an AI translation service so the other person can read them in their language. The original is always shown too.
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:
- Other members. The person you're chatting with sees what you write. If that person's Twin is chatting on Auto-Date, the Twin's owner can read the chat later in Date Recap. Matches see your messages after an unlock. Nobody ever sees your No.
- Service providers. Companies that host our servers, provide AI models, translate messages, send email, and help with moderation and support. They act only on our instructions, under contract. [Vendors to be listed.]
- App stores. Apple and Google handle payments for Whoo Plus. Their own privacy policies apply to that.
- Legal requests and safety. We share data with authorities when the law requires it, or when we believe it's needed to prevent serious harm.
- Business transfers. If Whoo is merged, sold or reorganised, your data may move to the new owner. This policy keeps applying, and we'll tell you before anything changes.
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
| Data | How long |
|---|---|
| Account, Twin and matched chats | While your account is open, then deleted within 28 days |
| Unmatched session chats | 30 days |
| ID images (if collected) | Deleted within 30 days; up to 90 days in Japan |
| Safety records | 1 year after a ban; longer for serious cases or where the law requires |
| Purchase records | As long as tax and accounting law requires |
| Device and usage logs | Up to 1 year |
| Waitlist | Until 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:
- see the data we hold about you (access);
- correct it;
- delete it, including your whole account;
- download it in a portable format;
- object to processing based on our legitimate interests, including profiling for seating;
- limit how we use it;
- withdraw any consent you gave, at any time;
- ask for a person to review an automated moderation decision;
- complain to your data protection regulator.
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.
- We do not sell or "share" personal data for cross-context behavioural advertising.
- We use sensitive data, such as sexual orientation, only to provide Whoo and keep it safe. You can still ask us to limit its use.
- We honour Global Privacy Control signals.
- Whoo hasn't launched yet. From launch, this section will list the categories collected in the past 12 months (section 2) and why.
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
- Privacy: privacy@meetwhoo.com
- Data protection officer: [DPO contact]
- EU representative: [EU representative]
- UK representative: [UK representative]
- Post: Xava Labs Hong Kong Limited, 7F, 262 Des Voeux Road West, Sheung Wan, Hong Kong 999077
You can also use our contact page.