Privacy Policy

1. Data Fiduciary

For the purposes of India’s Digital Personal Data Protection Act, 2023 (“DPDP Act”) and the Information Technology Act, 2000 and its rules, the Data Fiduciary responsible for your personal data is:

2. Information We Collect

2.1 Information You Provide

When you register and use Wish, we collect:

• Display name and real name (where provided)
• Date of birth or age
• Gender
• Mobile number
• Selfie or profile verification photo (see Section 2.3)
• Profile content including bio, preferences, avatar selection, and content you create in Soul Facts and Dream Date features
• Messages and communications you send through the App
• Subscription and payment information (processed via Apple App Store and Google Play in-app purchases)

2.2 Information Generated Through Your Use

We automatically collect:

• Discovery feed activity, chat interactions, and Soul Facts / Dream Date game activity
• App interaction data, session duration, and feature usage patterns
• Device information: IP address, device type, operating system, app version, crash logs, and device identifiers
• Firebase Analytics and Crashlytics data including session information and crash reports (see Section 8)
• Push notification tokens stored to deliver notifications (see Section 8)

2.3 Selfie Verification

We require a selfie during account setup and verification for the sole purpose of confirming account authenticity and that users are real, adult individuals. We want to be transparent about exactly how this works:

• Your selfie is uploaded to our servers over HTTPS/TLS and stored in Amazon Web Services (AWS) S3 in the Mumbai region (ap-south-1)
• Selfies are not displayed on your public profile — all users interact through avatars and display names
• Selfies are reviewed manually by authorised Soul Wish Tech personnel for verification only
• Access to selfies is limited to our application systems and authorised administrative review tools; they are not shared with other users
• We do not use your selfie for facial recognition, biometric identification, or automated profiling
• We do not sell or share your selfie with third parties except as needed to operate our AWS storage infrastructure under our instructions
• Selfies are retained for the duration of your account and deleted within 30 days of account deletion, unless retention is required for fraud prevention or legal compliance
• If your verification is rejected, we delete the submitted selfie from our storage and clear it from your account record

3. How We Use Your Information

We use the information we collect to:

• Create, verify, and manage your account
• Operate Soul Facts, Dream Date, and the gamified discovery experience
• Enable discovery, chat, and communication between users who have unlocked chat under app rules
• Apply the 12-hour restriction following an incorrect Soul Facts guess, where applicable
• Display your profile within the App according to your preferences and other users’ preferences
• Process subscriptions and payments
• Send OTP verification and transactional notifications
• Provide customer support and respond to complaints
• Detect and prevent fraud, abuse, harassment, fake accounts, and policy violations
• Improve App performance, safety, and user experience using analytics data
• Comply with applicable laws, court orders, and regulatory obligations

We do not use your personal data for automated decision-making that produces legal or similarly significant effects without human oversight.

4. Legal Basis for Processing

We process your personal data on the following legal bases under the DPDP Act, 2023:

• Consent: You provide explicit consent at registration for the collection and use of your personal data, including selfie verification
• Contractual necessity: Processing required to provide the services you have signed up for
• Legitimate interests: Fraud prevention, security, and App improvement, where these do not override your rights
• Legal obligation: Where processing is required to comply with applicable Indian law

You may withdraw consent at any time by deleting your account or contacting us. Withdrawal does not retroactively affect the legality of prior processing activities.

5. How We Share Your Information

We do not sell your personal data. We may share information in the following circumstances:

5.1 With Other Users

Information you choose to make visible on your profile — such as your display name, age, gender, avatar, and profile content — is shared with other users for discovery. Your real name, mobile number, and selfie are never shared with other users.

5.2 With Service Providers (Data Processors)

We share data with the following third-party service providers who process data on our behalf:

5.3 For Legal Reasons

We may disclose information if required by law, court order, or a valid government or regulatory request under Indian law.

5.4 To Protect Rights and Safety

We may share information to investigate or prevent fraud, abuse, harassment, or threats to the safety of users or the App.

5.5 In a Business Transfer

If Soul Wish Tech Pvt Ltd is involved in a merger, acquisition, or sale of assets, your data may be transferred. We will notify you before your data is transferred and becomes subject to a different privacy policy.

6. Age Restrictions

Wish is intended exclusively for users who are at least 18 years of age. We do not knowingly collect personal information from anyone under 18. If we become aware that a minor has created an account, we will delete the account and associated data. If you believe a minor is using the App, contact us at support@soulwishtech.com.

7. Visible Profile Content

The following may be visible to other users within the App, depending on your settings:

• Display name (your chosen username; not your real name)
• Age and gender
• Avatar, Vibe, and preferences
• Content associated with Soul Facts and Dream Date activities

8. Analytics and Tracking Technologies

We use the following tools to understand how users interact with the App and to improve performance and reliability:

• Firebase Analytics (Google LLC) — anonymised usage data including session duration, feature interactions, and in-app events
• Firebase Crashlytics (Google LLC) — device information and crash logs to help us fix bugs
• Firebase Cloud Messaging — push notifications; device tokens may be stored to deliver alerts
• Firebase / Firestore — may be used to store device tokens and, where applicable, messaging-related metadata

Firebase data may be transmitted to Google servers outside India (see Section 11). We have configured Firebase Analytics with the minimum available data retention period where configurable. We do not use Firebase for advertising purposes.

9. Payments and Subscription Access

Wish operates on a freemium model. Certain premium features — including initiating or responding to Soul Facts and Dream Date interactions — require either an active paid subscription or eligible complimentary access.

Eligibility for complimentary access to the App and its full features is determined at the time of registration based on criteria set by Soul Wish Tech Pvt Ltd and will be clearly communicated to the User within the App. Users who do not qualify for complimentary access may subscribe to premium features through the following plans:

Subscription plans (prices may vary slightly on app stores):

• 1 Month: INR 299
• 3 Months: INR 599
• 6 Months: INR 899

Full pricing, renewal terms, and promotional conditions are shown in the App and in our Terms & Conditions. Payments are processed by Apple or Google; we do not store your full payment card details.

10. Data Retention

We retain your personal data only for as long as necessary for the purposes described in this Policy:

• Account data: Retained for the duration of your active account
• Selfies: Retained during your account period; deleted within 30 days of account deletion (or sooner if verification is rejected)
• Chat and messages: Retained while your account is active; deletion timelines may depend on messaging infrastructure (including Firebase, where used)
• Crash and analytics logs: Retained for the minimum period configured in Firebase
• Legal / fraud archives: Limited account-related records may be retained in secure archives after deletion where required by law, for fraud prevention, or to resolve disputes

When you delete your account in App settings, we remove your active profile and delete your verification selfie from storage. We then delete or anonymise personal information except where retention is required as described above.

11. International Data Transfers

We store your primary user data and verification selfies on AWS servers located in India. However, certain service providers — specifically Firebase (Google LLC), Apple Inc., and Google LLC (Play Store) — may process some data on servers located outside India.

Where international transfers occur, we take steps to protect your data, including:

• Data processing agreements with processors that include appropriate safeguards
• Firebase processing under Google’s standard data processing terms
• App Store and Play Store processing under Apple and Google developer agreements

By using Wish, you acknowledge that some data may be processed internationally as described above.

12. Data Security

We implement technical and organisational measures to protect your personal data, including:

• Verification selfies and uploads stored in Amazon S3 (Mumbai region, ap-south-1), transmitted using HTTPS/TLS
• Selfies are not shown on public profiles and are accessible only through our application and authorised admin review tools
• Access to production systems and personal data is restricted to authorised personnel on a need-to-know basis
• Our cloud infrastructure uses AWS network access controls (including security groups)
• Where supported by our cloud provider, data at rest may be encrypted at the storage layer

13. Your Rights

Under the DPDP Act, 2023 and applicable Indian law, you have the following rights:

• Right to access: Request a summary of the personal data we hold about you
• Right to correction: Request correction of inaccurate or incomplete personal data
• Right to erasure: Delete your account in App settings. Uninstalling the App does not delete your account or personal data. You may also email support@soulwishtech.com to request erasure. We will delete or anonymise data within a reasonable timeframe, except where retention is required by law, a government authority, law enforcement, or a court order
• Right to withdraw consent: You can withdraw consent by deleting your account. This does not affect processing that occurred before withdrawal
• Right to grievance redressal: File a complaint with our Grievance Officer (see Section 14)

We will respond to valid requests within 15 days.

14. Grievance Officer and Redressal

In accordance with the Information Technology Act, 2000, the IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, and the DPDP Act, 2023, Soul Wish Tech Pvt Ltd has designated a Grievance Officer:

How to file a complaint

1. Email grievance@soulwishtech.com with the subject line Privacy Grievance — [Your Username]
2. Include a clear description of your concern, relevant dates, and any supporting information
3. You will receive an acknowledgement within 48 hours of receipt
4. Your complaint will be reviewed and resolved within 15 days of receipt

15. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices, technology, or applicable law. If we make material changes, we will notify you by:

• Updating the Effective Date at the top of this Policy
• Displaying a prominent notice within the App
• Sending an in-app notification where appropriate

Continued use of Wish after an update constitutes acceptance of the revised Policy. The current version is always available at soulwishtech.com/privacy.

16. Contact Us