Privacy Policy

Effective date: 11/09/2026

1) Who We Are

WANA ("WANA", "we", "us", "our") is operated by Attilio Marotta, as the data controller for personal data processed through WANA.

Controller contact email: privacy@joinwana.app

Controller legal/postal address: UFFICIO RIMINI 3, CASELLA POSTALE 23, 47921 RIMINI RN

If you have data protection questions or wish to exercise your rights, contact us using the details above.

2) What This Policy Covers

This Privacy Policy explains what personal data we collect, why we collect it, how we use it, who we share it with, how long we keep it, and what rights you have.

3) What Data We Collect

A. Account and profile data — Depending on what you provide, we may collect: email address; username/handle; display name; date of birth or age-related information used to enforce the 18+ rule; city or location preferences; bio, interests, and profile details; profile photos or media you choose to upload.

B. Plans and participation data — We collect information relating to plans you create, request to join, or participate in, including: title, description, date/time, city, tags, and participant limits; join requests, approvals, denials, and membership status; host decisions and related participation records.

C. Messages and communications — We process group chat messages and related metadata such as timestamps, sender/recipient identifiers, and delivery or moderation information.

D. Safety and trust data — We collect: reports you submit; blocks you create; reasons, timestamps, and related account identifiers; moderation, enforcement, and review records.

E. Technical and usage data — We may collect: IP address; device/browser/app information; operating system; approximate technical geolocation derived from IP or settings where relevant; service interaction events (for example, plans viewed, requests sent, moderation actions, or feature use).

F. Women's Circle verification data — If you voluntarily apply for Women's Circle access, we may process: a government ID image; a short verification recording; verification status/decision; decision timestamps and minimal audit metadata. We do not use automated facial recognition to identify you and do not create biometric templates for identification.

4) Which Data Is Required and Which Is Optional

Some data is necessary to provide the service. Other data is optional.

Required for core account/service use — Typically required: email address or account login data; age/18+ information; basic account credentials; information necessary to create or join plans and to communicate in those plans. If you do not provide required data, we may be unable to create your account, verify eligibility, or provide the relevant feature.

Optional — Typically optional: bio, interests, profile photos, and certain profile fields; optional visibility/safety settings; Women's Circle verification data, unless you want access to that specific feature. If you do not provide optional data, core features may still work, but some experience or access may be limited.

5) Why We Process Data and Our Legal Bases

A. To provide the WANA service — This includes account creation, profile management, plan creation, join requests, hosting, group coordination, and in-app communications. Legal basis: performance of a contract.

B. To operate safety, abuse-prevention, and moderation systems — This includes reporting, blocking, fraud prevention, impersonation prevention, enforcing our Terms, preventing misuse, and maintaining platform security. Legal basis: legitimate interests in keeping WANA safe, secure, and trustworthy.

C. To enforce the 18+ rule — This includes age-related checks and actions relating to underage use. Legal basis: performance of a contract and legitimate interests.

D. To send service-related notifications — This includes notices about join requests, approvals, denials, plan changes, safety alerts, and important service messages. Legal basis: performance of a contract.

E. To review Women's Circle access requests — This includes authenticity review and anti-impersonation / anti-abuse checks for that optional feature. Legal basis: consent. You may withdraw that consent at any time. If you do, we will stop using the verification material for that purpose, but you may lose access to Women's Circle if verification is necessary for the feature.

F. To comply with legal obligations — Where necessary, we may process data to comply with applicable law, lawful requests, recordkeeping duties, or the defense of legal claims. Legal basis: legal obligation or legitimate interests, as applicable.

G. To improve WANA and understand growth trends — Where analytics is enabled, we may use aggregated or de-identified statistics, such as city-level or country-level usage trends, plan creation trends, join request trends, and general feature usage, to improve WANA and understand where the service is growing. We may use these aggregate insights for product planning and market strategy. These reports do not include names, email addresses, user IDs, individual profiles, or individual behaviour histories. Legal basis: consent where required for optional analytics, and legitimate interests where we use strictly aggregated or de-identified operational insights in a way that does not identify individuals.

6) Legitimate Interests We Rely On

Where we rely on legitimate interests, those interests include: protecting users from harassment, fraud, impersonation, and abuse; preventing repeated safety violations; securing the service; investigating misuse; enforcing our Terms fairly; maintaining reliable service operations.

You may have the right to object to processing based on legitimate interests in certain circumstances.

7) How Data Is Shared

A. With other users — Depending on the feature and your settings, other logged-in users may see profile and participation information such as: display name or handle; bio, interests, and photos you choose to make visible; relevant plan participation information; information hosts reasonably need to evaluate join requests.

B. With processors/service providers — We use service providers that process data on our behalf and under our instructions, such as providers for: hosting / cloud infrastructure; app or website operations; notifications or communications; customer support; analytics, where used; moderation/safety tooling, where used; verification tooling, where used.

C. For legal, safety, and platform integrity reasons — We may disclose data where necessary: to comply with law or binding requests; to protect users, WANA, or third parties; to investigate fraud, abuse, or security incidents; to establish, exercise, or defend legal claims.

We do not sell personal data.

We do not share personal data with data brokers. We do not use personal data for third-party advertising tracking, retargeting, lookalike audiences, or IDFA-based tracking.

8) Women's Circle Verification

If you apply to access Women's Circle, we use your ID image and verification recording only to assess authenticity and reduce impersonation or abuse in that optional feature.

Verification materials: are access-restricted; are stored separately where feasible; are never displayed publicly.

We store the verification outcome (for example, verified / not verified / restricted) separately from the source files.

Retention for verification files — New Women's Circle verification submissions are currently paused. Any verification files already held are access-restricted and retained only for as long as necessary for verification review, safety or legal matters, and deletion processing. When a source file is no longer required, WANA takes steps to delete it from active storage through its storage provider. Residual copies may remain temporarily in provider backups until removed under the provider's backup-retention processes, or where longer retention is required by law. WANA does not currently promise a fixed physical-deletion period.

We may retain limited audit metadata (for example, decision, timestamps, internal reference notes) for longer where reasonably necessary for abuse prevention, safety, or legal compliance.

9) International Transfers

If personal data is transferred outside the EEA/UK, we will use appropriate safeguards, such as: an adequacy decision; Standard Contractual Clauses; or another lawful transfer mechanism.

You may request further information about the safeguards relevant to your data.

10) Retention

Core account/profile data — We keep account and profile data while your account remains active, and for a limited period afterward where needed for deletion handling, dispute resolution, legal compliance, or safety.

Plans / requests / participation data — We keep these records as needed to operate the service, address disputes, enforce safety decisions, and maintain auditability of participation and moderation outcomes.

Messages — We keep messages as needed to provide chat functionality and address safety, abuse, and legal issues.

Reports / blocks / moderation records — We keep these as long as reasonably necessary to investigate concerns, prevent repeated abuse, enforce restrictions, and comply with legal obligations.

Deletion requests — If you request account deletion, we begin deleting or irreversibly de-identifying personal data associated with your account without undue delay, after verifying the request where necessary. Certain information may be retained where required for legal compliance, safety and platform integrity, active disputes or investigations, fraud and abuse prevention, or the defence of legal claims. Data held by service providers or in backup systems may remain temporarily until removed under the applicable provider retention processes. Retained information will not be used for ordinary product purposes.

Aggregated or de-identified statistics — We may retain aggregated or de-identified statistics that no longer identify individual users, such as city-level or country-level usage totals, for product improvement, safety, operational analysis, and market strategy.

11) Cookies, Local Storage, Analytics, and Similar Technologies

WANA may use essential cookies, local storage, device storage, or similar technologies where required for authentication, session management, security, account access, safety features, preferences requested by the user, and core functionality.

WANA does not currently enable optional analytics, advertising tracking, retargeting, lookalike audiences, data-broker sharing, or IDFA-based tracking.

WANA may use aggregated or irreversibly de-identified operational information that does not identify individual users to understand service reliability and general usage trends.

If optional analytics or similar non-essential technologies are introduced in the future, we will update this Privacy Policy and provide any consent controls required by applicable law before enabling them.

12) Your Rights

Depending on your location and applicable law, you may have the right to: access your personal data; rectify inaccurate data; erase data; restrict processing; object to certain processing; withdraw consent where processing is based on consent; receive portability of certain data; lodge a complaint with a supervisory authority.

You may exercise your rights by contacting privacy@joinwana.app. We aim to respond within 30 days, subject to lawful extensions where necessary.

If you are in the EEA, you also have the right to lodge a complaint with a supervisory authority, including in the Member State of your habitual residence, place of work, or place of the alleged infringement.

13) Security

We use reasonable technical and organizational measures to protect personal data, including access controls, secure transmission, and operational safeguards appropriate to the nature of the service.

No online service can guarantee absolute security.

14) Children / Under 18

WANA is strictly for adults aged 18+. If we learn that a user is under 18, we may restrict or terminate the account and delete associated data where appropriate and lawful.

15) Changes to This Policy

We may update this Privacy Policy from time to time. If changes are material, we will provide notice in-app, by email, or through another appropriate method before they take effect.

16) Contact

Controller: Attilio Marotta

Privacy & data requests: privacy@joinwana.app

App support & account issues: support@joinwana.app

General enquiries: hello@joinwana.app

Postal/legal address: UFFICIO RIMINI 3, CASELLA POSTALE 23, 47921 RIMINI RN

Questions about your privacy?

Reach out at privacy@joinwana.app