EEA & UK Privacy Notice

Lawful bases, representatives, transfers and your GDPR rights.

Version 2 · in force since 9 October 2026 · what changed. Drafted in good faith; not legal advice.

This notice supplements the Privacy Policy for people in the European Economic Area, the United Kingdom and Switzerland. Where it differs from the general policy, this one applies to you.

1. Who the controller is

Pontelon LLC, of 306 W Redwood St, Ste 201, Baltimore, MD 21201 (United States), is the controller of your personal data.

EU representative (GDPR Art. 27)[not yet published: EU representative (GDPR Art. 27)]
UK representative[not yet published: UK representative]
Data protection officer Not appointed. We are not a public authority, and our core activities are not large-scale monitoring or large-scale processing of special category data, so Art. 37 does not require one. Write to legal@whinchat.app and it reaches the person who does this work.

2. Our lawful basis for each purpose

Article 6 requires a basis for every purpose, not one for the service as a whole.

PurposeLawful basis
Carrying your messages, calls and files Art. 6(1)(b) — performance of the contract you entered into
Account, sign-in and securityArt. 6(1)(b) — contract
Marketplace orders, escrow and payoutsArt. 6(1)(b) — contract
Keeping tax and payment records Art. 6(1)(c) — legal obligation
Sanctions screeningArt. 6(1)(c) — legal obligation
Preventing abuse, fraud and spam Art. 6(1)(f) — legitimate interests. Ours and other users’ interest in a service that is not used to defraud or harass them. Balanced against your interests and recorded; you may object under Art. 21.
Diagnosing faults from error reports Art. 6(1)(f) — legitimate interests in a service that works
Measuring how the app performs and which parts are used Art. 6(1)(f) — legitimate interests in a service that works and is worth using. No advertising or profiling; no third-party analytics; nothing you typed. You can switch it off in Settings, we honour Global Privacy Control and Do Not Track, and you may object under Art. 21.
Reporting child sexual abuse material Art. 6(1)(c) and Art. 6(1)(d) — legal obligation and the vital interests of another person

We do not process your data for advertising or profiling, so no basis is claimed for it. Special category data (Art. 9) is not requested and not inferred.

3. Your rights

You may ask for a copy of your data, correct it, delete it, restrict or object to processing, and receive it in a portable form. Access, export and deletion are built into the app under Settings — you do not have to ask us. Write to legal@whinchat.app for the rest.

You may complain to your supervisory authority. In the UK that is the Information Commissioner’s Office; in the EEA it is the authority for the country you live in. We would rather you told us first, but that is your right and not a precondition.

4. Sending data outside the EEA and the UK

Our servers and subprocessors are listed in Subprocessors & Transfers, with the country each one holds data in. Transfers outside the EEA or the UK rely on the European Commission’s Standard Contractual Clauses together with the UK Addendum, and on an adequacy decision where one is in force for that country.

5. How long we keep it

Every category and its period is in Data Retention. Nothing is kept “indefinitely” without a period being stated there.

6. Automated decisions

These automated checks can act before a person has looked:

Two more only put something in front of a person: a new account that shares a device or phone number with a banned account is held from buying and selling until staff look, and the photo check of listings, lives and shared places only flags a picture. None of these produces an effect that cannot be reviewed by a person — reply in your chat with us, or write to legal@whinchat.app, and a human will look. We do not profile you for advertising.

7. Digital Services Act contact

Our point of contact for users, and for authorities acting under the DSA, is legal@whinchat.app. Notices may be sent in English. How we handle reports of illegal content, and how to challenge a decision about your own content, is described in Acceptable Use and Dispute Resolution.

What has changed

9 October 2026 · version 2

30 August 2026 · version 1

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