Privacy Policy

This Privacy Policy explains how DPA Tech Solutions SRL ("we", "us", "our") collects, uses, and protects your personal data when you use the WhereU mobile and web application, the website at whereu.fun, and the native applications for Android and iOS (collectively, the "Service"). We act as the data controller for your personal data under the EU General Data Protection Regulation (GDPR), Romanian Law no. 190/2018, and applicable global data protection laws (including CCPA/CPRA).

1. Who we are

DPA Tech Solutions SRL, a company incorporated in Romania. For any privacy inquiries, data access requests, or to exercise your rights, contact our Data Protection Officer at privacy@whereu.fun.

2. Data we collect

• Account data: email address, chosen username, display name, avatar, preferred language, and invite/whitelist registration metadata.
• Profile data: bio, social interests, optional links, and curated or favorited places.
• Location data: live GPS coordinates and movement speed when you enable location sharing or "Live" mode. A location history is used to aggregate dwell stops (stays of 15 minutes or longer) and generate your personal day map and daily activity metrics. Sharing can be paused instantly using Ghost Mode / Ghost Mode+ or set to expire automatically on a timer.
• Social graph & interactions: connections, squads, event RSVPs, group and direct messages, message reactions, read receipts, pings, vibe checks, community dinner preferences, Pulse (shake) connections, blocks, and reports.
• Payment data: processed securely by Stripe for WhereU PRO, event tickets, and host organizer plans. We store subscription tier status, expiration timestamps, and the last four digits of the payment method returned by Stripe; we never receive, process, or store full credit/debit card numbers.
• Device & telemetry data: device model, operating system, browser, IP address (retained temporarily for fraud prevention and rate limiting), crash/error diagnostics, and, upon explicit consent, push notification tokens (APNs / FCM / Web Push).
• Agent & API access: logs of AI assistants or tools you authorize via the Model Context Protocol (whereu.fun/mcp), granted permission scopes, and authenticated activity timestamps.

3. Artificial Intelligence (AI) & Automated Features

WhereU incorporates focused machine learning and Large Language Model (LLM) capabilities to enhance your social experience:

• Profile blurbs & summaries: We use Google Gemini models (hosted via Lovable AI Gateway) to generate optional, lighthearted weekly profile summaries based on your public check-ins and top-visited categories. No private direct messages, financial data, or raw GPS coordinates are shared with LLM providers.
• Safety & content moderation: Automated text classification algorithms assist in detecting severe policy violations (such as self-harm, threats, hate speech, and spam) to protect community safety.
• No automated legal profiling: We do not use artificial intelligence or automated processing to make decisions that produce legal or similarly significant effects concerning you (Article 22 GDPR).
• User control & opt-out: You can regenerate, edit, clear, or disable AI-generated profile summaries at any time directly in your profile settings.

4. Legal bases for processing

• Performance of a contract: To operate your account, provide real-time social and map features, process WhereU PRO subscriptions, and issue QR ticket passes.
• Consent: For live GPS location sharing, push notifications, behavioral telemetry, and marketing communications. Consent can be toggled or withdrawn at any time in Settings and Cookie Preferences.
• Legitimate interests: To maintain platform security, prevent abuse and fraud, throttle malicious requests, enforce safety reports, and optimize application reliability.
• Legal obligation: Accounting, tax compliance, handling lawful regulatory inquiries, and adhering to consumer protection rules.

5. How location data is protected

Live location is sampled from your device through a battery-conscious background tracker. The system skips redundant writes when stationary and automatically backs off write cadence. Live positions older than 15 minutes are hidden from public map layers by default. Server-side access to location records is strictly protected by database Row-Level Security (RLS): only you and the specific friends you have authorized can query your active location.

6. Third-party sub-processors & data recipients

We never sell, rent, or trade your personal data to advertisers or third parties. We share data strictly with authorized sub-processors necessary to deliver the Service:

• Supabase Inc. (USA / EU): Cloud database hosting, user authentication, edge functions, and secure storage buckets.
• Stripe Payments Europe, Ltd. (Ireland / USA): Payment processing, host payouts, invoicing, and subscription billing portal.
• Google LLC / Lovable AI (USA / EU): Google Gemini LLM API for profile summaries; Firebase Cloud Messaging (FCM) for Android push notifications.
• Apple Inc. (USA): Apple Push Notification service (APNs) for iOS notifications and Apple Sign-In authentication.
• MapLibre / MapTiler / Mapbox / OpenStreetMap (OSRM): Vector map rendering, geocoding, and routing calculations.
• Cloudflare, Inc. (USA / Global): TLS encryption, CDN caching, DDoS mitigation, and edge infrastructure.
• Resend / Transactional Email Provider: Transactional account notifications, pass receipts, and verification codes from notify.whereu.fun.

Where data transfers occur outside the European Economic Area (EEA), we ensure adequate safeguards are in place through European Commission-approved Standard Contractual Clauses (SCCs).

7. Data retention & permanent deletion of uploads

• Account data & uploads: Retained while your account is active. When you request account deletion, your profile, avatars, uploaded media files, and photos are scheduled for permanent purge immediately and fully expunged.
• Live location records: Hidden after 15 minutes; historical trajectories are permanently wiped after 30 days (up to 12 months for WhereU PRO users).
• Direct and group messages: Retained until deleted by conversation participants or upon thread deletion.
• Safety reports & moderation logs: Retained for up to 180 days to enforce community safety and prevent repeat abuse.
• Financial and tax records: Retained for 10 years in compliance with statutory fiscal retention obligations.

8. Your statutory rights (GDPR & CCPA)

Under applicable data protection laws, you possess the right to access, rectify, port, restrict, or request permanent erasure ("Right to be Forgotten") of your personal data:

• Self-serve deletion: Delete your account and all associated uploads permanently at whereu.fun/data-deletion or inside in-app settings.
• Data portability & export: Request a complete JSON export of your profile and history from your profile dashboard.
• Contact DPO: Email privacy@whereu.fun for any specialized privacy inquiries.

You also have the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (ANSPDCP) in Romania (dataprotection.ro) or your national EU supervisory authority.

9. Security standards

All data in transit is encrypted using modern TLS/HTTPS protocols. Data at rest is encrypted using industry-standard AES-256. We enforce strict database Row-Level Security, least-privilege service roles, JWT authentication, signed webhooks, rate limiting on sensitive routes, and continuous vulnerability scanning. Suspected vulnerabilities can be submitted to security@whereu.fun.

10. Children's privacy

WhereU is not directed to individuals under the age of 16. We do not knowingly collect personal data from minors. If you believe a minor has registered without consent, contact us at privacy@whereu.fun for immediate removal.

11. Updates to this policy

We may revise this Privacy Policy periodically. If material changes are introduced, we will notify you via in-app notification or email at least 15 days before the updates take effect.