Willowe
Privacy Policy
This Privacy Policy explains how Willowe ("we", "us", or "our"), operated by Andrei Yesipionak, Republic of Belarus, collects, uses, and protects information about you when you use the Willowe mobile application ("App"). By using the App you agree to this Policy.
1. Data Controller
Andrei Yesipionak
Republic of Belarus
Email: willoweappsupport@gmail.com
Phone: +375447288673
For users in the European Economic Area (EEA), Andrei Yesipionak is the data controller responsible for your personal data.
2. Data We Collect
We collect the following categories of personal data:
• Account data — name, email address, date of birth, gender, sexual preferences.
• Profile data — photos, biography, interests, height, education, relationship status, worldview, and other optional attributes you choose to provide.
• Location data — GPS coordinates, collected while the App is in use when you grant location permission (foreground / when-in-use only; we do not track location in the background). Used solely to show you nearby users and to store your last known position on our servers.
• Device & communications data — push notification token (FCM), device model, OS version.
• Usage data — in-app actions and feature interactions collected via analytics tools (processed by Amplitude Inc.; not for advertising).
• Verification data — a selfie photo taken during identity verification. Used only to confirm you are a real person.
• Subscription & billing data — product identifier, subscription plan, active status, start and expiry dates, and store-issued transaction or receipt tokens from Apple App Store or Google Play. We do not collect or store credit card numbers, bank account details, or other full payment credentials; those are processed solely by Apple or Google.
• AI feature content — messages you type in Love Agent and Trainer; Love Agent answers about you and the partner you describe (these can include relationship and intimacy preferences); and, when a reply depends on them, your sex and country. Profile photos, payment details, and your chats with other users are not sent for this purpose.
3. Legal Basis for Processing (GDPR)
• Performance of a contract (Art. 6(1)(b)) — creating and maintaining your account, enabling matches and messaging.
• Legitimate interests (Art. 6(1)(f)) — preventing fraud, ensuring platform safety, improving app performance.
• Consent (Art. 6(1)(a)) — location access, push notifications. You may withdraw consent at any time via device settings.
• Legal obligation (Art. 6(1)(c)) — responding to lawful requests from authorities.
• Performance of a contract (Art. 6(1)(b)) — generating replies in Love Agent and Trainer when you use those features. If an answer includes information about your sex life or sexual orientation, we process it because you chose to submit it in order to use that feature (Art. 9(2)(a)).
4. How We Use Your Data
• Show your profile to other users and display potential matches.
• Calculate distance between users.
• Deliver push notifications about matches, messages, and activity.
• Verify your identity and prevent fake accounts.
• Detect and prevent prohibited behaviour and abuse.
• Improve the App and diagnose technical issues.
• Provide, verify, and manage Willowe Premium subscriptions and premium features.
• Generate text replies in Love Agent and Trainer.
5. Third Parties
We share your data only with service providers necessary to operate the App:
• Google Firebase (Firebase Auth, Cloud Messaging, Remote Config, Firestore) — authentication, push notifications, configuration. Google LLC, USA. Standard Contractual Clauses apply.
• Hetzner Online GmbH — cloud servers located in the EU (Germany/Finland). Your photos and profile data are stored here.
• Amplitude Inc. — analytics; we transmit usage events to improve the app (not for advertising). USA. Standard Contractual Clauses apply.
• Apple Inc. (App Store) and Google LLC (Google Play) — in-app purchase and subscription billing. They process payments and provide us with transaction verification data needed to activate premium access. Their privacy policies apply to payment processing.
• Hangzhou DeepSeek Artificial Intelligence Co., Ltd. ("DeepSeek") — generates text replies for Love Agent and Trainer. We send the AI feature content described above so a reply can be produced. This processing takes place in the People's Republic of China. Open Platform terms: https://cdn.deepseek.com/policies/en-US/deepseek-open-platform-terms-of-service.html
We do not sell your personal data to third parties.
6. Artificial Intelligence (Love Agent and Trainer)
Love Agent and Trainer use a generative language model from Hangzhou DeepSeek Artificial Intelligence Co., Ltd. to write replies. The model is not a person. A reply is produced automatically from the text sent for that step.
What is sent:
• Trainer — the messages in that topic's conversation. Your profile, name, age, city, and chats with other users are not included.
• Love Agent — the answers and follow-up messages needed for that step (about you and the partner you describe), plus your sex and country when the reply depends on them. Your photos and chats with other users are not included.
The text is sent to DeepSeek at api.deepseek.com in the People's Republic of China. China is not covered by a European Commission adequacy decision. We send this content only when you use the feature, so the reply you asked for can be generated. Trainer replies and Love Agent pair replies are sent from your device. The Love Agent interview, when the model is used, is sent from our servers.
By using these features you ask us to send that content. You can stop further sending by not using the feature. Trainer conversations stay on your device until you clear the topic, sign out, or remove the app data. Love Agent answers stay with your account until you erase that questionnaire or delete your account.
DeepSeek describes its chat API as stateless: it does not keep the conversation as a stored history. Unused cached prefixes of a request are cleared, usually within hours or days. We do not control DeepSeek's systems, and we do not use these chats to train our own models.
Replies can be wrong, incomplete, or unsuitable. They are not professional, medical, legal, or mental-health advice. Do not type passwords, payment details, or private information about other people into these chats.
7. Data Retention
We retain your personal data for as long as your account is active. When you delete your account in App Settings, we delete your profile, photos, chats associated with your account, and other personal data within 30 days, except where we are required to retain it by law (e.g. legal claims or accounting).
If your account was permanently banned (platform ban) and you then delete it, we keep a limited security record so we can stop the same person from creating a new account. That record may include the email address used on the banned account, linked sign-in identifiers (such as Apple or Google account IDs), a face embedding from verification (not your photos), and the ban status. We keep this record for as long as needed to protect users and enforce bans. Verification selfies and profile photos are still deleted with the account.
Verification photos of active accounts are deleted after the review is complete.
Trainer conversations are stored on your device, not on our servers. Love Agent answers are kept with your account as described in section 6.
8. Your Rights (GDPR)
If you are in the EEA, you have the following rights:
• Access — request a copy of the data we hold about you.
• Rectification — ask us to correct inaccurate data.
• Erasure ("right to be forgotten") — request deletion of your personal data.
• Restriction — ask us to limit processing in certain circumstances.
• Data portability — receive your data in a machine-readable format.
• Objection — object to processing based on legitimate interests.
• Withdraw consent — for location and notifications at any time via device settings.
To exercise any right, email us at willoweappsupport@gmail.com or delete your account in the App Settings. Account deletion instructions (including without the app): https://willowe.love/delete-account. You also have the right to lodge a complaint with your local data protection authority.
9. Data Security
We implement industry-standard security measures including HTTPS/TLS encryption for data in transit, JWT-based authentication, and access controls. No method of transmission is 100% secure; we cannot guarantee absolute security.
10. Children and Child Safety
Willowe is for adults only (18+). We do not knowingly collect personal data from anyone under 18. If we learn that a minor has created an account, we will delete the account and related personal data as soon as reasonably practicable.
Willowe prohibits child sexual abuse and exploitation (CSAE), including child sexual abuse material (CSAM). Our published Child Safety Standards describe how we prevent, review, remove, and report such content:
https://willowe.love/child-safety
If you believe a minor is using Willowe or you see CSAE/CSAM, contact us immediately at willoweappsupport@gmail.com (Child Safety Point of Contact) and use in-app Report/Block where available.
11. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes through the App or by email. Continued use of the App after changes constitutes acceptance of the updated Policy.
12. Contact
For any privacy-related questions or requests:
Email: willoweappsupport@gmail.com
Phone: +375447288673
Child Safety Point of Contact (CSAE/CSAM):
Email: willoweappsupport@gmail.com
Phone: +375447288673
Child Safety Standards: https://willowe.love/child-safety