Privacy
Policy

Wishew operates through two affiliated entities:

• Wishew Ltd, registered in England and Wales (No. 14614244), acts as the controller of personal information for users resident in the United Kingdom and European Union.
• Wishew Inc, incorporated in Delaware, USA, acts as the controller of personal information for users resident in the United States.

For questions about this Privacy Policy or our privacy practices, contact us at support@wishew.com.

The Services are intended solely for individuals who are at least 18 years of age.

Wishew does not knowingly collect personal information from individuals under 18. If we become aware that we have collected personal information from a minor, we may suspend the relevant account and delete the information to the extent required by applicable law.

We collect information directly from you, automatically when you use the Services, and from certain third parties.

3.1 Information You Provide

When you create an account or use the Services, you may provide:

• Full name, username, and email address;
• Telephone number and date of birth;
• Country of residence and profile information;
• Photos, videos, audio recordings, and other content you upload;
• Goals, Updates, comments, messages, and other content you publish or submit;
• Selected interests;
• Social connections and interactions within the Services, such as accounts you follow or block and content you interact with;
• Customer support communications; and
• Recipient details, such as name, contact information, and delivery address, when you use features that require us to arrange or facilitate delivery to another person.

3.2 Identity Verification Information

Identity verification may be required in connection with certain payment or withdrawal functionality.

Identity verification is carried out through our third-party payment service provider and/or its identity verification partners rather than directly by Wishew.

Depending on the applicable verification process, those providers may collect information such as:

• Government-issued identification documents;
• Selfie verification images and related biometric identifiers;
• Proof of address documentation;
• Tax identification information; and
• Information required for sanctions, fraud prevention, and compliance reviews.

Wishew does not itself collect or store the underlying identity documents or biometric identifiers submitted through the provider's verification interface. Wishew may receive and retain limited information relating to the verification process, such as verification status, timestamps, provider-generated identifiers, or compliance-related status information necessary to operate the Services.

Our payment and identity verification providers process information in accordance with their respective privacy notices and applicable data protection arrangements.

3.3 Transaction Information

When you make or receive a Support Payment or request a withdrawal, Wishew may receive or process information including:

• Transaction identifiers;
• Payment amounts;
• Transaction status;
• Chargeback and refund information;
• Fraud and risk indicators; and
• Information necessary to associate transactions and withdrawals with your Wishew account.

Wishew does not receive or store complete payment card details.

Payment card, bank account, and other payment instrument information entered through a payment provider's secure interface is processed by the relevant payment provider in accordance with its own privacy and security practices.

Wishew's systems may retain limited payment-related identifiers and, where applicable to the payment infrastructure used by the Services, a digital wallet address associated with your account for purposes such as routing payouts or checking balances.

3.4 Information Collected Automatically

When you access or use the Services, we may automatically collect information including:

• IP address and approximate location;
• Device identifiers and characteristics;
• Browser type and version;
• Operating system;
• Usage activity;
• Session data and log files;
• Referring URLs; and
• Application version and technical diagnostic information.
• Advertising identifiers, such as Apple’s IDFA or Google’s advertising ID, where available and where you permit their use;
• Cookie and analytics identifiers, such as Google Analytics client and session identifiers;

Where Wishew uses IP-derived information for platform safety, abuse prevention, or fraud-prevention purposes, the information may be hashed or otherwise transformed before further use. Where such information remains capable of being linked to an individual, we continue to treat it as personal data in accordance with applicable law.

3.5 Information From Third Parties

We may receive information about you from third parties, including:

Social login providers. If you sign in using a third-party login provider such as Google, Facebook, or Apple, we may receive information such as your name, email address, and an account identifier.

Referrals. If you access Wishew through another user's referral or share link, we may receive a pseudonymous referral or attribution identifier associated with that link.

Payment and verification providers. We may receive transaction status, verification status, risk indicators, and related identifiers necessary to operate payment, withdrawal, fraud-prevention, and compliance functionality.

We use personal information for the purposes described below and rely on an appropriate legal basis where required by applicable law.

4.1 Providing and Operating the Services

We may use information to:

• Create and manage your account;
• Enable you to create and manage Goals;
• Display and operate Journeys and Updates;
• Enable social and community functionality;
• Process or facilitate Support Payments and withdrawals;
• Provide requested features and functionality;
• Communicate with you about your account; and
• Provide customer support.

4.2 Platform Safety, Security and Fraud Prevention

We may use information to:

• Detect, investigate, and prevent fraud, abuse, and suspicious activity;
• Identify potentially prohibited activity;
• Monitor platform integrity and security;
• Protect users and the Services;
• Enforce our Terms and Conditions and other platform rules; and
• Investigate disputes, reports, chargebacks, and suspected misuse.

4.3 Payment and Compliance Support

We may process limited information to:

• Facilitate identity verification performed through our payment and verification providers;
• Support sanctions, fraud, and risk checks associated with payment functionality;
• Respond to requests from payment providers;
• Support payment-provider compliance processes;
• Resolve payment disputes and chargebacks; and
• Respond to valid legal or regulatory requests.

4.4 Service Improvement and Analytics

We may use information to:

• Analyze usage patterns and platform performance;
• Understand how users interact with the Services;
• Develop and test new features;
• Improve functionality, reliability, accessibility, and user experience; and
• Diagnose technical problems.

4.5 Marketing

Where permitted by applicable law, we may send you product updates, newsletters, and promotional communications.

You may unsubscribe at any time by using the unsubscribe mechanism included in the relevant communication or by contacting support@wishew.com.

Your consent to receive marketing communications is separate from your advertising choice described in Section 4.6.

4.6 Advertising, Measurement and Tracking

Wishew uses advertising and measurement technologies only in accordance with your choices and applicable law.

The rules that apply depend on where you are. We determine this from your approximate location, based on your IP address. If we cannot determine your location, we apply the rules for the United Kingdom and European Union.

Your advertising choice. Advertising measurement is controlled by your advertising choice, which is separate from your consent to receive marketing communications. If you are in the United Kingdom or European Union, or if we cannot determine your location, it is off unless you turn it on. If you are in the United States, it is on unless you turn it off through Your Privacy Choices, your account privacy settings, or a Global Privacy Control signal. On iOS, individual-level measurement also requires your permission under Apple’s App Tracking Transparency.

Website visitors. On the Wishew website, including when you are signed in, technologies such as pixels and tags operated by providers such as Meta, TikTok and Google may receive information such as your IP address, page URL, browser and device information, and cookie identifiers. If you are in the United Kingdom or European Union, or if we cannot determine your location, these technologies are activated only after you consent to them. If you are in the United States, they are activated when you visit the website unless you opt out through Cookie Settings, Your Privacy Choices, or a Global Privacy Control signal.

Your cookie choice on the website is not automatically applied to your Wishew account.

App and account activity. We may measure certain activities within the Services, including registration, creation of a Goal, completion of a Support Payment, starting a card checkout, creating a post, sharing content, a qualified view of a Goal, post or profile, and saving a Goal. We do this in line with your advertising choice. In the app, where permitted, this may also include the first time we observe the app being opened on a device and later opens before you sign in. A first observed launch is not a verified app-store download. This applies whether you use the app or the website. When an activity happens on the website, we send it to providers from our servers.

Depending on the activity, limited information shared with our advertising and measurement providers may include:

• Event or activity information;
• Payment amount and currency;
• Transaction or order identifiers;
• The Goal’s category, from a fixed list set by Wishew (for example, Creative Projects or Education & Skills);
• The address of the page where the activity took place (without parameters) and browser type;
• A hashed confirmed email address;
• A hashed Wishew user identifier;
• Where applicable, a hashed telephone number;
• For Meta and TikTok, the IP address and user agent of the request that triggered the activity;
• In the apps, an advertising identifier (IDFA or Google advertising ID), where available and permitted; and
• On the website, the Google Analytics client and session identifiers of your browser, where available and permitted.

Meta may also receive, where available, your first name, last name, date of birth, city, state and country, after normalisation and hashing, and the identifier returned by Facebook Login for the Wishew app. We do not send these additional profile fields to TikTok or Google. Hashed information is still personal information.

We do not include Goal titles, Goal descriptions, Goal images, or your interests in these advertising measurement events.

If an advertising identifier is not available or you have not given permission, we do not use another device identifier in its place. Advertising identifiers are not used in our internal product analytics. Wishew does not send Google a hashed telephone number.

Mobile applications. On iOS and Android, Wishew may use Google Firebase for measurement. Firebase may use an app-instance identifier associated with the relevant installation. In the United Kingdom and European Union, this happens only if you turn on your advertising choice. In the United States, it happens unless you turn it off. On iOS, it also requires your permission under Apple’s App Tracking Transparency.

Firebase may also collect automatic app-usage events, such as first_open or session_start, once measurement is enabled. On iOS, use of the app-instance identifier for this measurement is also subject to ATT permission.

Apple aggregate measurement. On iOS, Wishew also uses Apple’s SKAdNetwork and AdAttributionKit. These provide aggregated, privacy-preserving reports on the first observed app launch and selected activities (registration, publishing a first Goal and a first successful Support Payment). They can operate without App Tracking Transparency permission, and the updates we send through them contain no email addresses, IP addresses or advertising identifiers. If you turn off advertising measurement in Wishew’s settings, we stop sending these updates. Apple’s reports may be delayed or limited to protect privacy.

Wishew does not upload customer lists to these providers. In line with your choices, providers may use the measurement information they receive to help Wishew reach people who may be interested in the Services, including people with similar activity or characteristics. Where Meta receives information through its pixel or Conversions API, Wishew and Meta may act as joint controllers for the collection and transmission of that information. Meta’s subsequent use is governed by its own privacy policy.

You can change your choices at any time through Cookie Settings on the website or the privacy settings in your account. U.S. users can also use the Your Privacy Choices link on the website.

Wishew may use automated systems, machine learning, and artificial intelligence to support and improve the Services.

Depending on the feature you use, these technologies may assist with:

• Content moderation and detection of potentially prohibited or harmful content;
• Processing user-provided audio in connection with Goal or content creation;
• User-requested text improvement or writing assistance;
• Search functionality and semantic matching, including the use of embeddings;
• Personalization of content, interests, and recommendations;
• Fraud, abuse, and platform-risk detection;
• Platform safety and accessibility; and
• AI-assisted customer support.

When you use AI-assisted customer support, information processed may include information you provide in your support conversation, such as your first name, messages, and files or images you choose to upload. Where necessary to resolve your request, authorized support functionality may also retrieve limited account information relevant to the issue, such as your email address or transaction-related information.

We limit the information used for these purposes to what is reasonably necessary for the relevant functionality and apply appropriate access and security controls.

Certain verification, sanctions, fraud, or risk checks associated with payment functionality may be performed automatically by our payment or verification providers under their own compliance frameworks and privacy notices.

Where Wishew's internal systems generate fraud, risk, or moderation signals, those signals may assist our teams in identifying activity requiring review. Where required by applicable law or Wishew's internal procedures, significant account-level enforcement actions are subject to appropriate human review.

If you have questions about an automated outcome or believe an automated system has incorrectly affected your account, you may contact support@wishew.com.

We do not sell your personal information for monetary consideration. Some disclosures to advertising and measurement providers may count as "sharing" or targeted advertising under U.S. state privacy laws, as described in Sections 12 and 13.

We may share personal information in the following circumstances:

Payment Providers

We may provide information necessary for third-party payment providers to facilitate Support Payments, withdrawals, refunds, fraud prevention, and related payment operations.

Identity Verification and Compliance Providers

Information may be processed by identity verification, fraud prevention, risk management, sanctions screening, or similar providers involved in supporting payment or account functionality.

Service Providers

We may use third-party providers for services such as:

• Hosting and cloud infrastructure;
• Analytics;
• Communications;
• Customer support;
• Security;
• Content processing;
• Artificial intelligence and machine-learning functionality; and
• Technical infrastructure.

Where those providers process personal information on Wishew's behalf, they are subject to contractual and legal obligations governing their use of that information.

Professional Advisors

We may disclose information to lawyers, auditors, accountants, consultants, insurers, and other professional advisors where reasonably necessary.

Corporate Transactions

Information may be disclosed or transferred in connection with an actual or proposed merger, acquisition, financing, restructuring, sale of assets, or similar corporate transaction, subject to appropriate safeguards.

Legal Authorities and Protection of Rights

We may disclose information where required by applicable law, court order, legal process, or regulatory requirement, or where reasonably necessary to protect the rights, safety, or security of Wishew, our users, or third parties.

Advertising and Measurement Providers

In line with your choices and applicable law, as described in Section 4.6, we may share technical and event information, device and advertising identifiers, IP address, account-matching information (including, for Meta, hashed profile information) and transaction-related information with advertising and measurement providers such as Meta, TikTok and Google.

This information may be used to measure the effectiveness of Wishew's advertising, understand how users interact with the Services, attribute activity to advertising campaigns, improve our marketing, and help us reach people who may be interested in the Services.

The information shared is limited as described in Section 4.6 and does not include Goal titles, Goal descriptions, Goal images, or complete payment card information.

Wishew operates internationally. Your personal information may therefore be transferred to or processed in countries outside your country of residence, including the United Kingdom, European Economic Area, United States, and jurisdictions in which our service providers operate.

Where international transfers are subject to applicable data protection law, we use appropriate safeguards as required. These may include:

• Adequacy decisions;
• Standard Contractual Clauses approved by the European Commission;
• The UK International Data Transfer Agreement or UK Addendum, where applicable; or
• Other legally recognized transfer mechanisms.

If you are located in the EEA or UK and would like more information about safeguards applicable to your personal information, contact support@wishew.com.

Advertising and measurement providers such as Meta, TikTok and Google may process information in the United States and other countries. Where required, these transfers rely on the safeguards described above.

Wishew will comply with any applicable requirement to appoint a representative in the European Union or United Kingdom where such appointment is required under applicable data protection law.

If you are located in the EEA or United Kingdom, we process personal information under one or more of the following legal bases:

Contract. Where processing is necessary to provide the Services you request or perform our contractual obligations to you.

Legal obligation. Where processing is necessary for Wishew to comply with an applicable legal obligation.

Legitimate interests. Where processing is necessary for our legitimate interests or those of a third party and those interests are not overridden by your rights and freedoms. These interests may include platform security, fraud prevention, abuse prevention, service improvement, protecting our users, and operating an effective online platform.

Consent. Where we ask for and obtain your consent for a particular processing activity, including where consent is required for certain marketing communications or technologies. This includes advertising measurement and related technologies described in Section 4.6. You may withdraw consent at any time, without affecting processing lawfully carried out before withdrawal.

Identity verification and any biometric processing performed directly by a third-party payment or identity verification provider are subject to the legal bases and privacy arrangements applicable to that provider.

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including legitimate business, security, dispute-resolution, and applicable legal requirements.

Indicative retention periods include:

• Account information: for the duration of your account and, where necessary, for a period following closure to meet applicable record-keeping, dispute-resolution, tax, accounting, or legal requirements;
• Transaction and payment records: generally for at least 5 years where necessary for payment, accounting, dispute-resolution, or related purposes;
• Identity verification documents: retained by the relevant payment or identity verification provider according to its own applicable retention requirements; Wishew does not separately store the underlying documents submitted through the provider's verification interface;
• Platform monitoring signals, including hashed or transformed network or device indicators used for fraud and risk detection: generally up to 90 days on a rolling basis unless associated with an investigation or compliance case;
• Fraud, risk, and platform-integrity case records: generally up to 2 years following case closure where reasonably necessary;
• Marketing communications information: until you unsubscribe, withdraw consent where applicable, or the information is no longer required;
• Advertising measurement data: IP address and user-agent information used for measurement is deleted within 24 hours; registration measurement records are kept for up to 60 days; advertising identifiers are not stored in our databases;
• Records linking your account to analytics identifiers: kept while your account exists and deleted once any related deletion request has been sent to the provider;
• Records of deletion requests sent to analytics providers: kept until the provider confirms deletion and for up to 12 months afterwards;
• Technical delivery queues for measurement events: retained only for the short period needed to deliver events and retry failed deliveries;
• Customer support communications: generally up to 3 years following resolution;
• System and application logs: generally approximately 30 days, subject to security and operational requirements; and
• Temporary technical or authentication information: retained only for the period reasonably necessary for the relevant technical or security purpose.

Wishew's fraud and platform-integrity monitoring is operated as part of our voluntary risk-management and platform-safety framework. References to retention for these purposes should not be interpreted as a representation that Wishew itself is a regulated financial institution or AML-obliged entity.

Following a valid deletion request, information within Wishew's systems will be erased or de-identified as required by applicable law, subject to permitted exceptions.

Some information may remain temporarily in backup systems before being overwritten in accordance with our backup rotation. Information associated with an active dispute, security investigation, fraud case, legal claim, or other permitted retention purpose may also be retained for the applicable period.

Where relevant information is held independently by a payment or verification provider, requests concerning that information may need to be handled by or coordinated with the relevant provider.

Information received by advertising and measurement providers is retained according to their own policies.

When personal information is no longer required, we delete or de-identify it in accordance with applicable law.

We implement appropriate technical, organizational, and administrative safeguards designed to protect personal information against unauthorized access, disclosure, alteration, loss, and destruction.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

If you believe your account or personal information has been compromised, please contact us at support@wishew.com.

Depending on where you live, you may have rights relating to your personal information.

These may include the right to:

• Request access to personal information we hold about you;
• Request correction of inaccurate or incomplete information;
• Request deletion of your personal information, subject to applicable exceptions;
• Object to certain processing;
• Request restriction of processing in certain circumstances;
• Request portability of certain personal information;
• Withdraw consent where processing is based on consent; and
• Exercise applicable rights relating to automated decision-making.

To exercise your rights, contact support@wishew.com. This also applies if you do not have a Wishew account and want to make a request about information collected from your browser.

We may need to verify your identity before completing a request and will respond within the timeframe required by applicable law.

EEA and UK Users

EEA and UK users may also have the right to lodge a complaint with their applicable data protection authority.

UK users may contact the Information Commissioner's Office (ICO).

EEA users may contact the supervisory authority responsible for data protection in their EU Member State.

Where applicable under GDPR or UK GDPR, you may also have rights relating to decisions based solely on automated processing that produce legal or similarly significant effects, including the right to obtain human intervention in circumstances provided by law.

Residents of U.S. states with comprehensive privacy laws may have additional rights depending on the law applicable to them.

These may include rights to:

• Access personal information;
• Correct inaccurate information;
• Delete personal information;
• Obtain a portable copy of certain information;
• Opt out of certain sales, sharing, targeted advertising, or qualifying profiling activities; and
• Appeal certain decisions concerning privacy requests.

Wishew does not sell personal information for monetary consideration. However, some disclosures to advertising and measurement providers described in Section 4.6 may count as a "sale", "sharing" or targeted advertising under certain state laws.

You can opt out of these activities at any time through the Your Privacy Choices link on the Wishew website.

Where required by applicable law, Wishew honours Global Privacy Control (GPC) and similar opt-out preference signals as a valid opt-out request for the browser or device that sends them. If you are signed in, we also apply it to your account.

To exercise an applicable U.S. state privacy right, contact support@wishew.com.

Wishew does not sell personal information for monetary consideration.

As described in Section 4.6, Wishew may disclose limited identifiers and activity information to advertising and measurement providers. On the website, in your Wishew account and in the app, this happens unless you turn it off. Where this counts as "sharing" or targeted advertising under California law, you can opt out at any time through the Your Privacy Choices link on the Wishew website, your account privacy settings, or Cookie Settings. Wishew also honours Global Privacy Control (GPC) signals as described in Section 12.

To exercise an applicable California privacy right, contact support@wishew.com.

Wishew uses cookies and similar technologies to operate the Services, remember preferences, maintain security, and, in line with your choices, measure advertising performance. Our internal product analytics do not use cookies or similar technologies to store or access information on your device.

Cookies and similar technologies that are necessary to operate the Services may be used without your consent where permitted by applicable law.

Marketing and advertising cookies on the Wishew website are activated as described in Section 4.6: in the United Kingdom and European Union only after you consent, and in the United States unless you opt out. Where activated, technologies operated by providers such as Meta, TikTok and Google may collect or receive information as described in Section 4.6.

You can accept, reject, or manage non-essential cookies through the cookie consent controls made available on the website, and you may change your preferences at any time.

During payment, verification or withdrawal processes, you may interact with interfaces operated by third-party providers. Those providers may use their own cookies or similar technologies subject to their respective privacy policies.

The Services may also store limited information locally on your device, such as language preferences or onboarding progress.

For more information about the cookies and similar technologies used by Wishew and your available choices, please refer to our Cookie Policy at wishew.com/cookie-policy.

We may update this Privacy Policy from time to time.

Where required by applicable law, we will provide appropriate notice of material changes, which may include notification by email or through the Services.

The “Last Updated” date at the top of this Policy identifies the most recent revision.

If you have questions, concerns, or requests relating to this Privacy Policy or Wishew's privacy practices, contact:

Wishew
Email: support@wishew.com

If you are located in the EEA or UK and are not satisfied with our response, you may have the right to lodge a complaint with the applicable data protection authority.

UK: Information Commissioner's Office (ICO)
EEA: Your applicable supervisory authority in your EU Member State