In short
- Wherlyst processes the data needed to save your places, notes, folders and, if you choose, your photos and videos, and to share them with people you pick.
- We do not show ads, we do not sell your data, and we do not profile you based on the places you save. The app contains no advertising or tracking software.
- Your device's live location stays on your device; it is not sent to or stored on our servers.
- To find places, part of the content you share (without your account identity) is sent to a third-party AI service (Google - Gemini API); this applies to all accounts, free and paid. Details and how to object are in section 4.
- If you turn on a web link for a folder, anyone with the link can view that folder.
- Identity-free usage measurement (not linked to your account, email address or device; contains no content) and in-app crash reports are part of the Service; there is no off switch in the app. To object or withdraw, write to wherlyst@90pixel.com or delete your account.
- You can request a copy of your data and delete your account in the app or on the web.
1. Controller and contact
This policy applies to the Wherlyst mobile app and Wherlyst web view pages (the "Service").
- Controller: 90Piksel Bilgisayar Bilişim Elektronik Taş. Tur. Tic. Ltd. Şti., Mansuroğlu Mah. 288/4 Sok. No: 16 D: 27, Bayraklı, İzmir, Türkiye · Trade registry (MERSİS): 0001096226500001 · [TR] Registered e-mail (KEP): 90pikselbilgisayar@hs01.kep.tr
- Privacy contact: wherlyst@90pixel.com
2. What data we process
| Category | Examples | Source |
|---|---|---|
| Account data | Email address, your Apple or Google account identifier (for sign-in), display name, language preference; the time of your sign-up acceptance and the version of the text package you accepted (including the age declaration) | You or the sign-in provider you choose (Apple, Google) |
| Session and device data | Session information, device platform, app version, push token, time zone (e.g. Europe/Istanbul; used only on a free account, so that the daily place limit resets at local midnight; it is not location data; it is not processed or kept while you are on the paid plan or trial) | The app |
| Daily quota counter | The number of places your account created that day (a short-lived technical counter; no content) and media upload safeguard counters | The app / our servers |
| Content you save | Places (name, address, coordinates), notes, folders, source links, photos and videos you add | You |
| Sharing data | Folder memberships, roles (viewer/contributor), invitations, web links, who added each place | You and the actions of people you share with |
| Link resolution data | The address of a link you share; the caption or title of the post behind it; text provided by the share sheet (including text-only shares without a link); the title, description and address information of the page the link points to (only to suggest a place, transiently; not stored in Wherlyst's systems) | The share sheet, the platform's public/official interfaces, and the public information of the page the link belongs to (§4) |
| Place search | Your search text and, to rank nearby results, your approximate location (rounded to ~1 km) | You; not stored and not logged |
| "Same place" check | When you save a place from the share screen, the ID or coordinates (and name, if any) of the place you selected; used only to check whether that place is already among your saved places | You; not stored or logged for this check. If you complete the save, the place's coordinates are stored as "Content you save" |
| Subscription data | Plan status, store of purchase, store transaction identifiers, dates and amounts, version of the purchase screen text you confirmed | App Store / Google Play and the app. We never receive your card or payment details |
| Support and report correspondence | Emails you send us, content reports, requests | You |
| Technical and security logs | IP address, browser/device information, request time, error logs. Your IP address is not stored together with identity-free measurement data; it may appear in traffic logs we keep under a legal obligation, kept separately with restricted access (see Retention for the period) | The app, web view and our servers |
| Device installation ID | A random identifier generated at each installation of the app (not an advertising ID; a new one is generated if you uninstall and reinstall). Stored with your account to manage your session and sync between devices; not used in measurement or error reports | The app |
| Measurement data | (a) Aggregate counts of actions that happen on our servers (e.g. "place created"), without content. This includes an "account creation path" count, derived on our servers from data we already hold to provide the service (e.g. whether your account started with an invite or with a share you began before signing up), written only to a daily total and not linked to you; no extra information is taken from your device for this. (b) In-app usage events (screen and step transitions, e.g. whether you completed the welcome screens), not linked to your account, email address or device; your IP address is not written to the record; there is no off switch for this measurement in the app (to object, see §11) | Our servers / the app |
| Crash reports | Technical information at the time of a crash (device model, OS, stack trace); no location, notes or link content; up to 90 days | The app (no off switch; to object write to wherlyst@90pixel.com). Error logs created on our servers do not read data from your device and fall under "Technical and security logs" |
| Web view visitors | IP address, browser language, page view count (not linked to a person) | The browser |
| Signup country | The country code (e.g. TR, DE) derived from your connection when you create your account; set once and never updated; your IP address is not stored for this. It does not mean your country of residence. For subscribers, also the country code reported by the purchasing store. Used only for data breach notification and non-personal aggregate country counts; not used for profiling, advertising or content personalisation. This field is not used for the age limit; the age check is described in the separate row ("Age check"). | Connection data and the store |
| Age check (before account creation) | At the start of account creation, before any account exists, we run a one-time, temporary check to apply the minimum age (16; 18 in the US). Your device derives only an age band (e.g. "16-17" or "18 and over") from the birth month and year you select; the month and year never leave your device. Your device also reads the country of your App Store/Google Play account and sends the server only a three-value signal ("US / non-US / unknown"), not the country code itself. The server reads the country of your connection in memory only, for that single request. The outcome is "allowed" or "not allowed"; this information is not stored or logged and is not written to your account. If you are declined, no personal record is created about you; we keep only a daily aggregate count of declines that identifies no one. If we cannot determine the limit (country unknown), the higher limit (18) applies | You, your device (store country) and connection data |
What we do not collect: We do not send your device's live location to our servers. Embedded data in your photos and videos, such as GPS location and device details, is removed on your device before upload and again on our servers. We do not collect advertising identifiers. We do not access your contacts, messages or other apps.
Special category data: We do not aim to collect special category data (health, religion, political opinions etc.). A place you save (e.g. a clinic or place of worship) might indirectly suggest such information. We do not draw such inferences and we do not profile you by categorising your places.
3. Why we process your data and on what legal basis
| Purpose | Data | [EU/UK] GDPR Art. 6 | [TR] KVKK Art. 5 |
|---|---|---|---|
| Create your account, sign you in, sync your devices | Account, session | Contract (6(1)(b)) | 5(2)(c) |
| Provide places, folders, map, search and sharing | Content, sharing, place search | 6(1)(b) | 5(2)(c) |
| Suggest a place from a link or text you share (including AI-assisted place detection) | Link resolution data | 6(1)(b); for third parties named on a page, in a post or in text you share, 6(1)(f) | 5(2)(c); for third parties named on a page, in a post or in text you share, 5(2)(f) |
| Provide the paid plan, verify plan status, process refunds and transfers | Subscription | 6(1)(b); legal obligation 6(1)(c) | 5(2)(c), 5(2)(ç) |
| Prove pre-purchase information and consent; send subscription documents | Subscription, email, delivery records | 6(1)(c); legitimate interests 6(1)(f) | 5(2)(ç), 5(2)(e) |
| Transactional notifications (invites, plan status, account warnings, security) | Email, push token | 6(1)(b) | 5(2)(c) |
| Keep the Service secure, prevent abuse, fix errors | Technical and security logs (including server error logs) | 6(1)(f); 6(1)(c) | 5(2)(f); 5(2)(ç) |
| Keep the app stable (crash and error reports) | Crash reports | Legitimate interests (6(1)(f)); [EU/UK] for ePrivacy Art. 5(3) / PECR scope see §11 (residual risk) | Legitimate interests (5(2)(f)) |
| Notify authorities and affected people of a personal data breach; identify the competent authority | Affected data, contact details, signup country | Notification: 6(1)(c) (Art. 33–34 GDPR). Storing the country code in preparation: 6(1)(f); you can object to the storage (§10) and the code is then deleted | Notification: 5(2)(ç) (KVKK Art. 12(5)). Storing the country code in preparation: 5(2)(f) |
| Review content reports, enforce the Community Guidelines, respond to authorities | Report correspondence, relevant content | 6(1)(c); 6(1)(f) | 5(2)(ç), (e), (f) |
| Improve the product using aggregate counts without content | Measurement (a) | 6(1)(f) | 5(2)(f) |
| Identity-free usage measurement (improving the product) | Measurement (b) | Legitimate interests (6(1)(f)); [EU/UK] for ePrivacy Art. 5(3) / PECR scope see §11 (residual risk) | Legitimate interests (5(2)(f)) - no identifier, no content, IP not stored with measurement data, our own servers (EU), no in-app switch (objection by email) |
| Answer support requests and rights requests | Support correspondence | 6(1)(b); 6(1)(c) | 5(2)(c), 5(2)(ç) |
You may object to processing based on legitimate interests (§10): there is no separate in-app switch; writing to wherlyst@90pixel.com or deleting your account is enough. We do not use consent as a basis.
Automated processing and AI: To find a place from a link you share we use automated methods and, where needed, a language-model (AI) service (details in §4). The result is only a suggestion; a place is saved only once you confirm it. We do not make solely automated decisions with legal or similarly significant effects on you (Art. 22 GDPR). We use an automated word filter in text fields; it only shows a warning and masks the matched expression on web views, and does not block your place. Content removal and account suspension decisions are made by people.
4. Links you share and third-party platforms
- When you share a link from platforms such as Instagram, TikTok, X, YouTube or Google Maps, we use the link address, the text provided by the share sheet, and the post's title or caption obtained through the platform's official interfaces (e.g. oEmbed, YouTube Data API). In addition, for Instagram, TikTok, X and YouTube post pages, we may read the public title and description (meta) tags of the page of the post you shared, once from our servers, when you share it, to suggest a place. We do this honouring the platform's robots.txt, without signing in, sending cookies or trying to get around login or verification screens; if a platform's robots.txt cannot be retrieved we do not read the page. The target server's robots.txt rules are evaluated before the page content is requested; for short links (e.g. vm.tiktok.com, youtu.be) only the redirect request to the short-link address is made before that evaluation, and the page itself is not requested if robots.txt does not permit it. Our servers do not read pages that robots.txt does not permit (today, that is most Instagram and X pages); platform rules may change. We do not read pages of other social platforms such as Facebook, Threads, LinkedIn, Reddit, Pinterest and Snapchat from our servers. Platform pages are also processed in our servers in memory only and not stored. Instagram preview (on your device): For an Instagram post link that you added or opened yourself, the app may read the public og: tags (title, description and image address) of the post page from your device, once, and show them on the card. This read is made from your device, not from our servers, and Instagram (Meta) sees your IP address and standard request information in that request. The title and description that are read are not sent to our servers and are not stored; they may be cached on your device for up to 7 days. The image is shown directly from its address on Instagram's content network (that network sees your IP address); we do not copy it, host it on our servers or reuse it. For a link someone else added, the preview loads when you tap it. Because Instagram may restrict automated access, a preview may not always appear. This on-device read is not subject to the robots.txt rule that our servers apply; Instagram's terms may restrict automated access.
- Other websites (restaurants, hotels, blogs, news sites, etc.): When you share such a link, we read that page's title, description and address information (the page title, meta description, Open Graph fields, and the name, address and coordinates in schema.org structured data) once, from our servers, to suggest a place. We do not read the rest of the page, its images, reviews or contact details (phone, email, personal names). The site sees our server's IP address and standard request information; your IP address and device information are not sent to that site for this request. In Wherlyst's systems the page information is processed in memory only; it is not stored, not written to logs, error reports or analytics, and not sent back to you as a preview. We do not read pages that require sign-in, sit behind a paywall or are closed to automated access by robots.txt. Suggested places are suggestions only; a place is not final until you confirm it. The next bullet explains that this information may go to an AI service for place detection.
- AI-assisted place detection: This section applies whatever your plan: free or paid (including the trial), and only when you use the feature. To understand where a place is in what you share, we use a language model; for shares that list several places the language model is the primary method. Rule-based methods run only as a fallback when this service is switched off, returns an error or a usage limit is reached; while the fallback runs, your text is not sent to a language model. Only the following goes to the model: the page title and description, the platform's oEmbed title or text, and the text from the share sheet (each is shortened; web addresses, email addresses and phone numbers in the text are removed before sending). Not sent: your account ID, your email address, your device information, your notes, your folder names and images. Because they are place clues, usernames (@...) and hashtags (#...) in the text or page may be sent as they are. This also applies when you share text only without a link (for example text copied from a messaging app); keep this in mind when you share text that contains other people's names or information. Link address and page: If the quick methods find no place and you use this feature, the address of the link you saved (query string and
#fragment removed; share-tracking codes are not sent) is also sent to Google, and Google's tool may read the public page at the link itself. This includes Instagram, TikTok and X post pages (YouTube is out of scope). The address sent and the page content Google reads fall under the no longer than 55 days retention above; we do not store the page content. Information about people named on the page or in the address (e.g. the post owner's username) may reach Google this way. Links that require sign-in or look like private tokens (e.g. private documents, invitation links) are not sent. Because platforms may restrict automated access, no result may be available for these pages; the platforms' own terms also apply. The model runs on Google's Gemini API (paid service); Google acts as a processor on our behalf. Processing may take place in the various countries where Google has facilities (including countries outside Türkiye and the European Union); we do not commit that processing will take place in the European Union. We do not store these texts. Under the paid-service terms Google does not use the texts to improve its products and does not share them with others; it keeps them for no longer than 55 days solely to detect abuse, security violations and legal obligations, and during that time only authorised Google staff can review content that has been flagged. The result is only a place suggestion. There is no separate permission screen or Settings switch for this feature; AI processing is part of the Service whatever your plan and is disclosed in the Terms of Use §3.3, which you accept at sign-up, and in this policy. To object or withdraw, write to wherlyst@90pixel.com or delete your account; on your objection AI-assisted place detection is switched off for your account (within 30 days at the latest). If you choose not to use the feature (you can add places manually), your text is not sent to the AI service. If the types of data sent, the provider, the processing region or retention change materially, the sign-up acceptance screen is shown again (Terms §14). - We do not store platform images, post text, or page information we read from platforms or other websites on our servers. Web views never show platform previews.
- Link previews: When the app shows a preview card for a link (title, image, short description), this information is fetched from your device directly from the platform's official interface (e.g. TikTok, X, YouTube oEmbed) or from the website the link belongs to. As with any standard web request, that platform or website can see your device's IP address and basic device/browser information. Preview information is not sent to our servers; it is kept only temporarily on your device (for up to 7 days) and deleted when you sign out or delete your account. In shared folders, each member's device loads previews itself.
- YouTube: For YouTube links we use YouTube API Services, subject to the Google Privacy Policy. Apart from the source link and the place you confirm, we do not store YouTube API data; if we must, we keep it for no more than 30 days.
- Place search and maps: When you search for a place, we send the text you type, your approximate (rounded) location, your language and a temporary search-session token through our servers to Google's Places service (Google LLC, USA). Your account ID, email, device information and IP address are not included; the request comes from our server. We do not store or log this data; Google acts as our processor under its Cloud Data Processing Addendum. The transfer is to the USA and relies on standard contractual clauses / an adequacy mechanism under KVKK art. 9 and GDPR Chapter V. On Android, the map is shown with Google Maps and your device requests map tiles directly from Google, which may process your IP address and device information independently under its own policy (Google Privacy Policy, Google Maps/Google Earth Additional Terms of Service). On iOS, the map is shown with Apple Maps, which processes data under Apple's policy (Apple Maps and Privacy). You can skip place search and drop a pin by tapping the map; no query is sent in that case.
- Shares that list several places: If a post you share lists several places (up to 10), we extract the place names (name and district/city) with the AI service and look each one up, without your account identity and without the link, through our servers in Google's Places service. We do not store the full text of the post; we keep only the extracted rows (place name, district, "verified/not found" status and the location data returned by Google) in your account. These rows, including places you do not pick, are kept until you delete the related record or share; only you can see them, and they do not appear in shared folders, web links, invitation previews or exports. The Google name of the place you pick is written as the name you own for the record (you can change it at any time); it is stored as your own record name, not as place data. On iOS, the Google-sourced coordinates in this list may be drawn on Apple Maps on your device to show the places; Apple processes the coordinate under its own policy. For Google's storage and display terms see the Google Maps Platform Terms of Service.
- Platforms you share from have their own privacy policies, which apply when you open their links.
5. Location
- Coordinates and addresses of places you save are stored in your account as the core of the Service.
- Device location is used only while you use the app and with your permission, on your device, to centre the map and sort places by distance. It is not sent to or stored on our servers. We do not collect background location.
- To rank nearby search results, your approximate location (~1 km precision) is sent with the search request to our server; it is not logged or stored.
- When you save a place from the share screen, the ID or coordinates of the place you selected are sent to our server so we can tell you whether the same place is already among your saved places. This information is used only during the check and is not logged or stored for it.
- You can turn location permission off at any time in your device settings; the app works without it.
6. Sharing: who can see your data
- Folder members: People you share a folder with (viewers or contributors) see its places, notes, visible photos and videos, the member list (display name + role) and who added each place. Contributors can add places.
- Web link: When you turn on a web link for a folder, anyone with the link can see the folder name, the owner's display name ("X's list"), place names, addresses and locations, notes, source links and visible photos and videos. People who receive the link can pass it on. Web views do not show who added a place. Web pages are excluded from search engines (
noindex) and links are unguessable. When you turn the link off, access ends; due to caching a page may remain visible for a few minutes. - Content you add to someone else's folder: Notes and media you add to a folder with an active web link are visible to anyone with the link; the app tells you this when you add. If a folder's web link is turned on later, existing members are told in the app and can remove their places from the folder. You can ask our support to remove your places from a folder you left (§10, right to object).
- Media visibility and plans: Whether a photo or video is visible in shared folders and web links depends on the paid plan of the person who added it. When that person's plan ends, the media they added is hidden from everyone until the plan is renewed; others are not shown the reason or the person's plan status (§8).
- Our service providers (processors): We use providers acting only on our instructions for hosting and database, content delivery and file storage, email delivery, notification infrastructure, error monitoring, identity-free product analytics, AI-assisted place suggestions and our support mailbox. Current list: wherlyst.com/subprocessors.
- Independent controllers: When you sign in with Apple or Google, make a purchase or receive notifications, Apple and Google process data under their own privacy policies. Payments and refunds are handled by the store.
- Authorities: Where legally required (e.g. a court order or a request from a competent authority), or where someone's life or safety is at risk, we may disclose information to the extent necessary.
- Corporate transactions: In a merger, acquisition or asset sale, data may be transferred to the acquirer with the safeguards of this policy; we will notify you in advance.
We do not sell your data or share it for advertising.
7. International transfers
- Our servers are located in the European Union (Germany, Frankfurt); file storage and backups are kept in an EU jurisdiction. Our content delivery network operates globally. Some providers (e.g. sign-in, notifications) are located in the US or operate globally. For the AI service we use Google's Gemini API (paid service); texts may be processed in Google's facilities in various countries and we do not limit processing to the European Union; the provider is part of a US-headquartered group.
- [EU/UK] Data collected directly from EU/UK users is provided to us as controller. Transfers to providers outside the EU/UK rely on the European Commission's Standard Contractual Clauses (SCCs), the EU-US Data Privacy Framework (DPF) certification or, [UK], the UK International Data Transfer Agreement/Addendum (IDTA/Addendum) or the UK Extension. You can request a copy of the safeguards at wherlyst@90pixel.com.
- [TR] Transfers to any provider outside Türkiye rely on the standard contracts published by the Turkish Personal Data Protection Board under Art. 9 KVKK, notified to the Authority within 5 business days.
8. How long we keep data
| Data | Period |
|---|---|
| Account data, places, notes, folders, media | While your account is open or until you delete them |
| Hidden media (photos and videos hidden when a plan ends) | Not deleted; kept while your account is open. Restored if you renew. You can delete hidden media or request a copy at any time. Deleted if your account is deleted (including inactive account deletion) |
| When an account is deleted | Removed from live systems within 30 days and from backups through the backup cycle within 35 days. Data remaining in backups is not used; if a backup is restored, the deletion is re-applied |
| Your traces in other people's folders (e.g. "former member", "added by") | Anonymised as "deleted user" when your account is deleted |
| Session information | Session lifetime + 30 days |
| Technical logs (IP etc.) | 30 days |
| Security and access logs | 1 year |
| Aggregate measurement data (pseudonymous) | 13 months |
| Identity-free usage measurement events | Up to 13 months (then deleted or turned into aggregate values that cannot be linked to you) |
| Crash reports | Up to 90 days |
| Subscription and purchase records (transaction ID, date, amount, store) | For statutory tax and commercial retention periods (5–10 years), only for that purpose |
| Delivery records of subscription documents and mandatory warnings (delivery metadata, not content) | At least 3 years after the subscription ends or the account is deleted |
| Evidence copy of removed content and report contents | 6 months from the decision; longer if legal proceedings are pending |
| Moderation decision record (no content: date, type of restriction, ground, appeal outcome) | 3 years from the decision |
| Signup country | Kept with your account; deleted within 30 days of account deletion. Store country is kept with the subscription record |
| Daily quota counter, time zone, media upload safeguard counters | Counters up to 3 days (media safeguard counters use the UTC day); time zone only while the account is free (deleted when you move to the paid plan or trial; no history kept); deleted when the account is deleted |
| Shares waiting on your device to be added tomorrow when the daily limit is reached | On your device only; up to 30 items; after 14 days we ask whether it should still be added, nothing is deleted until you delete it; removed from the device on sign-out, account deletion or app uninstall; does not reach us until sent to the server |
| Rows extracted from a share that lists several places (place name, district, status, location data returned by Google; including places you do not pick) | Until the related record or share is deleted; only you can see them; on account deletion within 30 days (35 days in backups). The full text of the post is not stored |
| Caption, location tag and hashtags of a share left with "Find later" | On your device only; deleted when the place is confirmed, when you delete the record or discard the share, when you sign out, delete your account or uninstall the app, and in any case no later than 30 days |
| Record of an account deletion request (who and when, not content) | 3 years |
| Revoked invitations and web link records | 90 days |
| Support correspondence | 2 years after the request is closed |
8.1 Inactive accounts
If you do not use your account on any device for 12 months (no app opening, sign-in or sync), we will email you, and send a notification if available, 30 days and 7 days before the deletion date. Opening the app during that time is enough. Otherwise your account and all content (including hidden media and shared folders you own) are deleted under §8. Other people opening your web link or activity by folder members does not count as use.
- The deletion date is at least 30 days after the first warning; if a warning is delayed, the date moves accordingly. We keep a record that warnings were sent (delivery data, not content). If your email permanently bounces and no notification channel exists, deletion may still go ahead.
- Your account will not be deleted for inactivity while you have a valid paid subscription (including a trial, a cancelled subscription running to the end of its period and the store's billing grace period; not the store's on-hold period after the grace period). If, when your subscription ends, your account has already been inactive for more than 12 months, the deletion date will be at least 30 days after the subscription end, and warnings follow that schedule.
- If a shared folder you own is going to be removed, its active members receive an in-app notice 30 days in advance ("This folder will be removed on [date]; places you added stay in your account"). The reason is not disclosed. If you come back, the notice is withdrawn and members are told in the app that the folder will not be removed.
9. Security
We protect your data with technical and organisational measures such as encryption in transit and at rest, access controls, password-free secure sign-in, unguessable sharing links, least-privilege access and logging. No system is completely secure. If a personal data breach occurs, we notify the competent authority (in Türkiye the Personal Data Protection Board, in the EU the supervisory authorities of the countries where affected people are, in the UK the ICO) within 72 hours where required by law, and affected individuals without undue delay. We use your email address and in-app notices for these notifications.
10. Your rights
[EU/UK] Under Articles 15–22 GDPR / UK GDPR
You have the right of access, rectification, erasure, restriction of processing, data portability, to object to processing based on legitimate interests, and to withdraw consent.
[TR] Under Article 11 KVKK
You have the right to learn whether your data is processed and request information about it; learn the purpose and whether data is used accordingly; know the third parties in Türkiye or abroad to whom it is transferred; request correction and, under Art. 7 KVKK, erasure or destruction; request that such actions be notified to recipients; object to a result against you arising exclusively from automated analysis; and claim compensation for damage caused by unlawful processing.
[US] US state privacy notice
- No sale, no sharing, no targeted advertising. We do not sell personal information, do not "share" it for cross-context behavioural advertising, and do not process it for targeted advertising or for profiling that produces legal or similarly significant effects. We have not done so in the past 12 months. Because we do not sell or share, there is nothing to opt out of; we nevertheless treat a Global Privacy Control signal as a request not to sell or share.
- Categories we collect and their sources, purposes and recipients are described in §2, §3 and §6; retention periods are in §8. The categories are: identifiers (email, account ID), account and subscription records, content you create (places, notes, photos and videos), approximate region data (signup and store country, time zone), and identity-free usage analytics and crash reports (not linked to your account, email address or device). We do not collect your device's precise location on our servers (§5).
- Sensitive information. We do not use or disclose sensitive personal information to infer characteristics about you. Places you choose to save are your content; we do not use them to infer health, religion or other sensitive traits.
- Your rights. Depending on your state of residence, you may have the right to know/access, correct, delete and obtain a portable copy of your personal information, and to appeal our decision on your request. We offer these rights to all users regardless of state, using the methods below. If we decline your request, you can appeal by replying to our decision at wherlyst@90pixel.com; if the appeal is denied, you may contact your state Attorney General. We do not discriminate against you for exercising your rights. An authorised agent may submit a request on your behalf with your signed permission; we may verify your identity directly.
- Do Not Track. Our app and web pages do not track you across third-party websites or services, and we do not allow third parties to do so; we therefore do not respond differently to browser "Do Not Track" signals.
- California "Shine the Light". We do not disclose personal information to third parties for their own direct marketing purposes.
- [WA/NV] Consumer health data. We do not collect, use or sell consumer health data.
How to exercise your rights
- In the app: Settings > Account & privacy: correct your display name, "Request a copy of my data" (all your media including hidden media, plus place and folder data, free of charge and regardless of plan, within 30 days at the latest, via a secure time-limited download link), "Delete account".
- On the web: Account deletion request: wherlyst.com/support#delete
- Email: wherlyst@90pixel.com
- We verify your identity (e.g. via the email registered to your account). We respond free of charge within 30 days at the latest. [EU/UK] For complex or numerous requests this may be extended by two further months; we will tell you if so.
- Even if your account is suspended, you can request deletion or a copy of your data via the web form or email.
Right to complain
- [EU] You may lodge a complaint with the supervisory authority of the EU Member State where you live, work, or where the alleged infringement took place.
- [UK] Information Commissioner's Office (ICO) — ico.org.uk.
- [TR] Personal Data Protection Board (Kişisel Verileri Koruma Kurulu), within 30 days of learning our response and in any case within 60 days of your request.
- [US] Your state Attorney General (and, in California, the California Privacy Protection Agency).
11. Analytics, permissions and information stored on your device
- Strictly necessary: session token, the app's local database and offline queue, and (if you enabled notifications) the push token. These are required for the service you request and need no consent.
- Identity-free usage measurement: Measurement events are not linked to your account, email address or any device identifier. While offline, events may be held on your device for up to 7 days and are sent once you are online; events not yet sent are removed from your device if you uninstall the app. Where the rules of your country require permission (e.g. storing information on a device in the EU/UK), our basis for this measurement is legitimate interests, not consent; you can object to measurement at wherlyst@90pixel.com or delete your account (there is no off switch in the app).
- No consent switch: No processing, including crash reports, relies on consent and there is no consent switch in Settings; the sign-up acceptance is not consent. Crash reports rely on legitimate interests (§3); the objection route is as above.
- Web view: Our web pages use no non-essential cookies or tracking tools, so no cookie banner is shown. Functional information such as language is read from your browser settings.
- Marketing: We do not send marketing emails, SMS or promotional notifications. If we ever do, we will ask for your separate prior consent. Transactional messages (invites, plan status, account and security warnings, subscription documents) are part of the Service.
12. Age limit
Wherlyst is not for people under 16, and in the United States not for people under 18. When creating an account you confirm that you meet this age limit. If we learn that an account belongs to someone below it, we close the account and delete the data. You can tell us at wherlyst@90pixel.com. [US] Wherlyst is not directed to children under 13, and we do not knowingly collect personal information from children under 13 (COPPA). If you believe a child under 13 has given us personal information, contact us at wherlyst@90pixel.com and we will delete it. Where state law requires it (for example, Texas), we receive age range information from the app store and use it only to apply the 18 age limit; we do not store it and keep only a record that the check took place. [UK] For users aged 16–17 content is private by default and location is used only while using the app and with permission. Because age is not stored, identity-free usage measurement is the same for all users (no identifiers; no content).
13. Changes to this policy
We may update this policy. We will announce material changes within the app and/or by email a reasonable time before they take effect. For changes that materially widen the scope of data processing the sign-up acceptance screen is shown again (Terms §14). Previous versions are archived at wherlyst.com/legal-archive.
14. Contact
90Piksel Bilgisayar Bilişim Elektronik Taş. Tur. Tic. Ltd. Şti. · Mansuroğlu Mah. 288/4 Sok. No: 16 D: 27, Bayraklı, İzmir, Türkiye · wherlyst@90pixel.com