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Privacy Policy

(last updated: June 30, 2026)

We, Whimscope LLC, a limited liability company duly organized and existing under the laws of the State of Delaware, welcome you to our Privacy Policy (hereinafter referred to as the “Policy”).

The purpose of this Policy is to describe our practices regarding the collection, processing, use, and disclosure of the information provided by you while using the Application developed by us, and to inform you about your privacy rights and the protection of your personal data under applicable laws.

We use your personal data to provide and improve the Application.

By using the Application, you acknowledge that you have read and understood this Privacy Policy.

If you do not agree with the terms of this Policy, you may discontinue using the Application.

2. Definitions

  • - Personal Data means any information relating to a natural person – a user of the Application – who is identified or can be identified;
  • - User (You) means any person who accesses the Application by completing the registration process and, as a result, creating an account for the purpose of using the product;
  • - Data Controller means the legal entity Whimscope LLC, which independently determines the purposes and means of processing personal data;
  • Account means a record containing a unique set of information that the User provides to the Application during the registration process. The created Account grants the User access to the Application and the ability to use its functionality;
  • - Company (referred to in this Policy as the “Company”, “We”, “Us”, or “Our”) refers to Whimscope LLC, 131 Continental Dr, Suite 305, Newark, DE 19713, New Castle County, Delaware;
  • Application means the software product named Whimscope, created by the Company and downloaded by You onto any electronic device with access to the developed functionality;
  • There are no restrictions on the Country of use of the Application. The Application is available worldwide and may be accessed by Users from different countries;
  • Device means any device capable of accessing the Application, such as a computer, mobile phone, or digital tablet;
  • Service Provider means any natural or legal person who processes data on behalf of the Company. This includes third-party companies or individuals engaged by the Company under civil and/or commercial contractual agreements to provide services, perform service maintenance on behalf of the Company, provide services related to the Application, or assist the Company in analyzing the use of the Application;
  • Usage Data means data collected automatically, either generated through the use of the Application or obtained from the Application infrastructure itself (for example, the duration of the User’s active use of the Application);
  • User Consent means the expression of the User’s will by which the User, through clear affirmative actions, confirms their consent to the processing of their personal data;
  • Legitimate Interest means the ability to process the User’s personal data without obtaining separate consent where such processing is reasonably necessary for the proper functioning of the Application and does not violate the User’s rights;
  • Performance of a Contract means our need to process personal data because without such processing we would not be able to provide You with access to and use of Whimscope. In other words, We provide You with access to and use of the Application, while You agree to be bound by our Terms of Use;
  • Content means information, including photographs, videos or posts that You create or upload while using the Application, as well as data/information uploaded by the Company during the creation and ongoing development of the Application.

3. Information We Collect

In this section, we will inform You about the information we collect, namely: the information You provide to Us (when registering or using the Application), as well as the information We collect as a result of Your use of the Application.

In certain cases, We may also collect additional information with Your consent.

3.1. Information You Provide

3.1.1. Your Account Information

To use our Application, You need to create an Account. For this purpose, We ask You to provide information necessary for the creation of such Account, for example: Your username, password for access to the Account, email address, date of birth (where required and/or for certain Application features), phone number, access to Your social media accounts (only if You create an Account using login through such social media accounts), and profile picture.

3.1.2. User Content

We store and process the Content that You create while using the Application, including photographs and videos that You upload or create while using the Application, information that You provide while using the Application, as well as related metadata, including when, where, and by whom such Content was created.

Even if You are not a User, information about You may appear in User Content uploaded to the Application.

The Platform may process personal data contained in user-generated content (UGC) for the following purposes:

  • ensuring the functioning of the Platform;
  • content moderation;
  • prevention of violations;
  • personalization of services.

Such data processing is carried out in accordance with this Policy and the User Generated Content Policy.

The Platform may use automated systems to analyze Content; however, it does not use personal data for training third-party models without an appropriate legal basis.

3.1.3. Your Phone Contacts

If You choose to synchronize Your contacts from Your phone book, We will receive the following information: names, phone numbers, email addresses, and We will compare such information with information of Users who already have an existing Account in the Application.

If You decide to synchronize Your contacts, You confirm that You have the right to provide Us with such contacts and that You have informed the relevant persons about such processing.

Such data processing is carried out on the basis of the Company’s legitimate interest (Article 6(1)(f) GDPR) for the purpose of enabling contact discovery features and improving interaction between Users.

The Company implements appropriate measures to minimize the impact on the rights of third parties, including:

  • processing only the minimum amount of data necessary;
  • not using such data for marketing purposes;
  • not retaining contacts for longer than necessary to achieve the stated purpose;
  • not independently contacting persons who are not Users of the Application.

Contact synchronization is entirely voluntary and is carried out only upon Your explicit consent.

3.1.4. Support Requests

If You contact our support team, We collect and store the Content and messages necessary to resolve Your issue and/or request.

3.2. Information We Collect Automatically

While using the Application developed by Us, and for the purpose of ensuring its optimal functionality, We may collect and process, with Your prior consent, the following information:

3.2.1. Usage Information

We collect information about Your use of the Application, for example, information about Your interactions with the Application, including what You do with the Content displayed to You, which filters You apply, which Users You search for, and the Users You follow.

3.2.2. Preference Information

Including interests, gender, and age range, which We use solely for the purpose of content personalization and improving user experience.

3.2.3. Technical Information

While using the Application, for the purpose of ensuring stable operation, analytics, and service improvement, We may automatically collect technical information, including:

  • device type, model, and operating system;
  • unique device identifiers;
  • IP address;
  • interaction with the Application and features used;
  • error logs, crash data, and performance data.

3.2.4. Location Data

We may obtain:

  • approximate location data (country/city) based on IP address; or
  • more precise location data only with Your separate consent through Your device settings.

You may disable access to geolocation at any time through Your device settings.

In addition, if You choose to add location information to Your Content, We will also collect such information, including landmarks, stores, or other places worth visiting.

3.2.5. Access to Camera and Media Files

With Your prior consent, the Application may access:

  • camera;
  • photo gallery.

Such access is used solely for creating or uploading Content to the Application. Permissions may be withdrawn at any time through Your device settings.

3.2.6. Social Media Data (in Case of Registration/Login Through Social Media Accounts)

If You log in through third-party services (such as Google, Apple, Facebook, etc.), We may receive the following information:

  • name;
  • email address;
  • profile photo;
  • other information made available in accordance to Your settings in such services.

3.2.7. Tracking and Analytics Technologies

We may use tracking and analytics technologies, including SDKs and other tools, for the following purposes:

  • ensuring the operation of the Application;
  • analyzing usage and user behavior;
  • improving functionality and stability.

Such technologies may collect information about the device, interaction with the Application, and technical events (such as crashes or errors).

Where required by applicable law, We will obtain Your consent for such processing.

You may limit the collection of such data through Your device settings.

3.2.8. Tracking Technologies and Device Identifiers (Apple AppTrackingTransparency)

If You use the Application on Apple devices, We may use tracking technologies that are subject to the requirements of Apple AppTrackingTransparency (ATT).

In such cases, We will request Your prior permission through Apple’s standard system prompt before conducting any tracking that may involve access to the device advertising identifier (IDFA) or similar technologies.

If You do not grant permission, We will not conduct such tracking.

You may change Your choice at any time through Your device settings.

3.3. Information from Third Parties

3.3.1. Authorization Services and Social Networks

If You choose to log into or register for the Application through third-party services (for example, Apple, Google, Facebook, or other similar services), We may receive certain information according to Your account settings in such service, including:

  • name;
  • email address;
  • profile photo;
  • other information that You permitted to be shared through the settings of the relevant service.

3.3.2. Analytics and Technical Services

We may also receive technical information regarding the use of the Application, including:

  • device type and model;
  • operating system and its version;
  • Application version;
  • crash, error, and performance data.

Such data is generally used in anonymized or statistical form and usually does not allow Us to identify You personally.

3.3.3. Application Distribution Platforms

We may receive limited information from application distribution platforms (for example, Apple App Store or Google Play), including:

  • data regarding installation and use of the Application;
  • general analytics metrics and performance reports.

We do not receive payment details or sensitive personal information of Users from such platforms.

3.3.4. Other Sources

In exceptional cases, We may receive information from other third parties:

  • where permitted by applicable law;
  • where such information is provided with Your consent;
  • where necessary to protect the rights, safety, or legitimate interests of Users or the Company.

3.4. Please note that, where necessary, You may enable or disable access to such information at any time through Your Device settings.

3.5. Please note that payment information is processed directly by the relevant platform (Apple App Store or Google Play). The Company does not store or have access to Users’ full payment card details.

3.6. We may also receive limited payment-related information (for example, transaction status, country, currency) from third-party payment providers. We do not store full payment details (such as bank card numbers).

Payment processing is carried out by third-party services acting as independent controllers or processors in accordance with their respective privacy policies.

4. How We Use Your Information

We use personal data only to the extent necessary for the operation of the Whimscope Application, provision of its features, improvement of the service, and compliance with legal obligations. Processing is carried out in accordance with applicable personal data protection laws, including the principles of the GDPR.

4.1. Depending on the circumstances, We process Your data on the basis of:

  • performance of a contract with You (i.e., to provide and maintain the Application in accordance with the Terms of Use);
  • Your consent;
  • Our legitimate interests; or
  • compliance with legal obligations.

4.2. We use information for the following purposes:

4.2.1. Providing and Maintaining the Application (Performance of a Contract)

  • creating, maintaining, and ensuring the secure operation of Your Account;
  • authenticating Users and enabling login functionality (including through social networks or third-party providers);
  • storing, processing, and displaying photos, videos, and other Content that You create or upload;
  • providing the core functionality of Whimscope, including discovering ideas, saving memories, creating collections, and managing of Your Content;
  • synchronizing data across Your devices and providing backup functionality;
  • ensuring the Platform security, preventing violations of the Service rules, investigating user complaints, and enforcing compliance with the Terms of Use, Community Guidelines, Acceptable Use Policy, and other WHIMSCOPE policies.

4.2.2. Personalization of the User Experience (Consent or Legitimate Interest)

  • providing recommendations, ideas, and Content tailored to Your interests and preferences;
  • using approximate location information to suggest more relevant activities or recommendations.

4.2.3. Analytics and Service Improvement (Legitimate Interest)

  • understanding how Users interact with the Application;
  • diagnosing technical issues and improving stability;
  • testing new features and improving usability;
  • analyzing aggregated usage data that is not linked to a specific individual.

4.2.4. Communication With You (Performance of a Contract or Consent)

  • sending service-related, technical, or administrative notifications (for example, regarding Account security or changes to the Application);
  • responding to Your requests through the Application support service;
  • sending news, updates, or marketing materials — only with Your consent where such consent is required by applicable law.

4.2.5. Security and Protection (Legitimate Interest and Legal Obligations)

  • protecting Accounts, data, and Users against fraud, abuse, and unauthorized access;
  • ensuring compliance with Our Terms of Use;
  • ensuring platform security, preventing violations of the Service rules, investigating user complaints, and enforcing compliance with the Terms of Use, Community Guidelines, Acceptable Use Policy, and other WHIMSCOPE policies;
  • complying with legal obligations, court orders, or regulatory requests, as well as protecting Our rights and legitimate interests.

4.2.6. De-Identified (Anonymized) Data

We may also use anonymized, aggregated, or statistical information that does not allow You to be personally identified for analytics, research, and development of the Application and its functionality.

4.2.7. Advertising

We may use Your data to display personalized or non-personalized content and advertising (where such functionality is available).

Where required by applicable law, We will request Your consent for the use of data for advertising purposes.

You may opt out of personalized advertising through the settings of the Application or Your device.

5. Legal Bases for Processing Personal Data

If You are located in the European Economic Area (EEA), the United Kingdom, or other jurisdictions where the General Data Protection Regulation (GDPR) applies, We process Your personal data only where We have an appropriate legal basis for such processing.

Depending on the circumstances, We may rely on the following legal bases:

5.1. Consent

We process data based on Your consent where such processing is necessary for features that are not essential to the operation of the Application.

For example:

  • sending news, updates, or promotional materials;
  • using analytics tools or technologies to improve content and advertising;
  • accessing certain device features that are not required for the core functionality of the Application.

You may withdraw Your consent at any time through the Application settings or by contacting Us.

5.2. Performance of a Contract

We process data where necessary to provide You with Whimscope and ensure its proper operation. Without such processing, the Application would not function properly.

Examples include:

  • creating, maintaining, and ensuring the secure operation of Your Account;
  • authenticating Users and enabling login functionality (including through social networks);
  • storing, displaying, and synchronizing Your photos, videos, and other Content;
  • providing the core functionality of Whimscope, including discovering ideas, saving moments, and collections;
  • responding to support requests;
  • backing up and protecting Your data.

5.3. Compliance With Legal Obligations

We may process data where necessary to comply with applicable laws or fulfill obligations to governmental authorities.

Examples include:

  • maintaining accounting and reporting records;
  • responding to lawful requests from courts, law enforcement, or regulatory authorities;
  • ensuring security and preventing unlawful activity.

5.4. Legitimate Interests

We may process data for Our legitimate interests provided that such interests do not override Your rights and freedoms and that the User may reasonably expect such processing when using the Application.

Examples include:

  • analyzing how Users interact with the Application in order to improve it;
  • diagnosing technical issues and improving stability;
  • protecting Accounts and Content and preventing fraud or abuse;
  • using aggregated statistics for the development of the Application.

5.5. Automated Decision-Making

We may use automated systems for:

  • detecting violations of rules;
  • content moderation;
  • ensuring platform safety and security.

Such systems may affect:

  • content visibility;
  • access to certain features;
  • User Account status.

Where provided by applicable law, You have the right to:

  • obtain an explanation of such decision;
  • challenge the decision;
  • request human review of the decision.

We always strive to minimize the amount of data processed and the impact on Your privacy when relying on this legal basis.

If You have questions regarding the specific legal basis on which We process Your personal data, You may contact Us using the contact details provided below.

Processing of data for the purposes of maintaining Service security, preventing violations of the Community Guidelines, and enforcing restrictions is carried out on the basis of the Company’s legitimate interests.

The Company may use automated tools to detect potential violations of the rules. Such tools may affect the visibility or availability of Content.

The Company may process personal data contained in copyright infringement notices (DMCA Notices) or counter-notifications for the purpose of complying with legal obligations and protecting the Company’s rights under applicable United States law.

WHIMSCOPE may process User information for the purposes of maintaining the Platform safety in accordance with the Community Safety Policy.

Personal data may also be processed in connection with Content moderation, the review of Complaints, and the enforcement of measures in accordance with the Content Moderation and Enforcement Policy.

6. Sharing and Disclosure of Information

We strive to ensure the confidentiality of Your data. We do not sell Your information to third parties for their own marketing purposes. However, We may share data in the following cases:

6.1. Service Providers

We may share data with third-party service providers that help Us operate and maintain Whimscope. Such providers may include:

  • hosting and server providers for storing and synchronizing Content;
  • analytics services used to improve the performance of the Application;
  • email service providers for sending notifications and updates.

These providers may use the data only to perform their functions and are not permitted to use such data for their own purposes.

6.2. Apple and Google

When You use Whimscope through the Apple App Store or Google Play, certain information may be shared with such platforms for the following purposes:

  • downloading and updating the Application;
  • integration with platform services;
  • analytics and improvement of the Application within the platform ecosystem.

6.3. Legal Authorities

We may disclose information where required by law or in response to lawful requests:

  • to comply with court orders;
  • to respond to requests from law enforcement or regulatory authorities;
  • to protect Our rights, ensure the safety of Users, or prevent unlawful activity.

6.4. In the Event of a Merger, Acquisition, or Sale of Business (M&A / Sale of Business)

If Whimscope is sold, merged, or otherwise transferred to another company, Your data may be transferred as part of the business assets involved in such transaction. In such cases, the new owner will be required to comply with the terms of this Privacy Policy.

We always seek to minimize the amount of data shared and ensure that it is used only for the specific purposes described in this Policy.

7. International Data Transfers

Whimscope may use servers, cloud services, and service providers located in different countries. As a result, Your personal data may be processed or stored outside of Your country of residence, including in the United States or other jurisdictions.

Data protection laws in such countries may differ from the laws of Your country. Nevertheless, We take appropriate measures to ensure an adequate level of protection for Your information regardless of where it is processed.

In particular, We:

  • cooperate only with reliable service providers that are contractually obligated to protect data;
  • enter into data processing agreements that include confidentiality and security obligations;
  • use Standard Contractual Clauses (SCCs) approved by the European Commission or other legally recognized data transfer mechanisms;
  • implement technical and organizational security measures to protect information against unauthorized access, loss, or misuse.

We transfer data internationally only where necessary for the operation of the Application or the provision of Our services.

8. Data Retention

We retain Your personal data only for as long as necessary to operate Whimscope, provide You with Our services, and comply with legal obligations. We do not retain information for longer than is reasonably necessary.

8.1. How Long We Retain Data

In general:

  • Account data is retained for as long as Your Account remains active;
  • photos, videos, and other Content are retained until You delete them or until the associated Account is deleted;
  • technical logs, analytics, and diagnostic data may be retained for a limited period of time to improve the performance and security of the service;
  • certain data may be retained for longer periods where required by law (for example, for accounting or legal compliance purposes).

8.2. How We Determine Retention Periods

We consider the following criteria:

  • whether the data is necessary to provide You with the functionality of the Application;
  • the duration of existence of Your Account;
  • the need to ensure security and prevent abuse;
  • Our legal and regulatory obligations.

We regularly review stored data and delete or anonymize information that is no longer required.

8.3. What Happens After Account Deletion

If You delete Your Account or request that We do so:

  • Your Account and Content associated with it will be deleted or deactivated;
  • access to Your data within the Application will be terminated;
  • data will be gradually removed from Our active systems and backup copies within a reasonable period of time required for technical implementation.

8.4. Account Suspension or Blocking

In the event that an Account is suspended or blocked, personal data may be retained for the period necessary to:

  • comply with legal obligations;
  • resolve disputes;
  • prevent repeated violations.

We may retain a minimal amount of information where necessary to comply with legal requirements, resolve disputes, or protect Our rights.

If You have questions regarding data retention periods or wish to request the earlier deletion of Your data, You may contact Us using the contact details provided below.

9. Your Rights Regarding Personal Data

We respect Your right to control Your personal data. Depending on Your country of residence, You may have certain rights regarding access to, correction of, or deletion of Your information.

To exercise any of these rights, You may contact Us using the contact details provided below. We will respond to requests within the timeframes required by applicable law.

9.1. Rights of Users in the EU and EEA (GDPR Rights)

If You are located in the European Economic Area (EEA), the United Kingdom, or other regions where the GDPR applies, You have the following rights:

9.1.1. Right of Access

You may obtain information about what data We hold about You and how We use it.

9.1.2. Right to Rectification

You may request that We correct inaccurate or outdated personal data.

9.1.3. Right to Erasure

You may request the deletion of Your personal data if such data is no longer necessary or if You withdraw Your consent (although We may retain limited amount of data where required by law).

9.1.4. Right to Restriction of Processing

Under certain circumstances, You may request that We temporarily suspend the processing of Your data.

9.1.5. Right to Data Portability

You may request a copy of Your data in a structured electronic format or request that such data be transferred to another service provider where technically feasible.

9.1.6. Right to Object to Processing

You may object to the processing of Your data under certain circumstances, including for analytics or marketing purposes.

9.1.7. Right to Withdraw Consent

If data processing is based on Your consent, You may withdraw such consent at any time. Withdrawal of Your consent will not affect the lawfulness of processing carried out prior to such withdrawal.

You also have the right to lodge a complaint with a data protection authority in Your country.

9.2. Rights of Users in the United States (CCPA/CPRA)

If You are a resident of certain U.S. states (for example, California), You may have the following rights:

9.2.1. Right to Know

You may request information about the categories of personal data We collect, how We use such information, and the third-parties with whom We share it.

9.2.2. Right to Delete

You may request deletion of Your personal information, except where retention is required by law or necessary for the operation of the service.

9.2.3. Right to Opt-Out

You have the right to opt out of the sale or sharing of Your personal data with third parties for advertising or marketing purposes.

Whimscope does not sell Users’ personal data.

To submit a request or exercise these rights, please contact Us using the contact details provided in this Privacy Policy.

10. Children’s Privacy

Whimscope is a general audience service and is not specifically directed to children.

We do not knowingly collect personal data from children under the age of 13 (or such other minimum age as may be required by the laws of Your jurisdiction, for example 16 years in certain EU countries) without parental or legal guardian consent.

If a child uses the Application, We encourage such use to take place under the supervision of or with the permission of parents or legal guardians.

If We become aware that We have unintentionally collected personal data from a child without appropriate parental consent, We will take reasonable steps to delete such information as soon as possible.

Parents or legal guardians may contact Us to:

  • ask questions regarding the processing of a child’s data;
  • obtain access to such information;
  • request correction or deletion of such information.

You may contact Us using the contact details provided below.

11. Information Security

We place great importance on protecting Your personal data and implement appropriate technical and organizational security measures to prevent unauthorized access, loss, alteration, or misuse of information.

In particular, We implement:

  • secure servers and cloud infrastructure;
  • encryption of data in transit (where applicable);
  • restrictions on access to data, limited to authorized persons only;
  • internal security and confidentiality policies;
  • regular monitoring, updates, and improvements of Our security systems.

We also cooperate only with service providers that adhere to appropriate security and confidentiality standards.

At the same time, no method of storing or transmitting data over the Internet is completely secure. Therefore, although We strive to protect Your information, We cannot guarantee its absolute security.

More detailed information regarding security measures and incident response procedures is provided in the Security and Incident Response Policy.

If You believe that the security of Your Account may have been compromised, please contact Us immediately.

12. Third-Party Services and Links

To ensure the operation of Whimscope, improve its functionality, and analyze the Application usage, we may use third-party services and tools.

In particular, We may use:

  • Google Analytics — for analytics and better understanding how Users interact with the Application;
  • Firebase (Google) — for hosting, technical infrastructure, analytics, push notifications, and other functionalities;
  • SDKs and other third-party integrations — to provide specific technical capabilities or improve the performance of the service.

These providers may process certain technical information (for example, device data, identifiers, usage statistics, or approximate location data) in accordance with their own privacy policies.

We select only reliable partners and aim to share the minimum amount of data necessary for the relevant purpose.

Please note that such services operate independently from Us, and therefore their data processing is governed by their own privacy policies. We recommend that You review them separately:

  • Google Privacy Policy
  • Firebase Privacy and Security Information

In addition, the Application may contain links to third-party websites or services. We do not control their content or privacy policies and are not responsible for their practices.

13. Changes to This Privacy Policy

We may update or modify this Privacy Policy from time to time in order to reflect changes in the operation of Whimscope, applicable laws, or our data protection practices.

The current version of the Policy is always available in the Application and/or on our website (https://whimscope.com/). The date of the latest update is indicated at the top of the document.

In the event of material changes, We may additionally notify You through the Application, by email, or through other appropriate means.

We recommend that You review this page periodically to stay informed about how We protect Your information.

All Platform policies should be interpreted in conjunction with one another. In case of any inconsistency between documents, the specific policy governing the relevant matter shall prevail.

14. Contact Information

If You have any questions regarding this Privacy Policy or how We process Your personal data, please contact Us.

Company (Data Controller): Whimscope, LLC
Email for privacy inquiries: support@whimscope.com
Mailing address: 131 Continental Dr, Suite 305, City of Newark, 19713, New Castle, Delaware

You may contact Us with any questions or requests, including for:

  • accessing Your personal data;
  • correcting or deleting information;
  • exercising Your rights under GDPR, CCPA/CPRA, or other applicable laws;
  • withdrawing consent or submitting a complaint.

We aim to respond to all requests within a reasonable timeframe and in accordance with applicable legal requirements.