Privacy Policy

1. Who We Are

The data controller responsible for Wealin is:

MyKolly Limited
84 Longcroft Rise
Loughton, England
IG10 3ND
United Kingdom

Website: wealin.app
Privacy and legal enquiries: legal@wealin.app
Support and moderation: support@wealin.app

MyKolly Limited is registered with the UK Information Commissioner’s Office (“ICO”).

2. Information We Collect

The information we process depends on how you use Wealin and which features you choose to use.

2.1 Account Information

When you create or maintain an account, we may process:

• your name;
• email address;
• username;
• user/account identifier;
• authentication information;
• date of birth;
• information provided through Sign in with Apple, where used;
• account settings; and
• preferences.

Your date of birth is used primarily to determine age eligibility and apply age-related protections and restrictions.

Your date of birth is not intended to be displayed publicly on your profile.

3. Profile Information

Depending on what you choose to provide, we may process:

• profile name;
• username;
• profile photograph;
• cover photograph or design;
• biography;
• cities or countries associated with your profile;
• places where you identify yourself as a local;
• favourite cities or countries;
• Books and Lists;
• Passport information;
• follower and following information; and
• other information you choose to add to your profile.

Some profile information may be visible to other users depending on the relevant feature and applicable settings.

4. Experiences and User Content

When you create, save or share content through Wealin, we may process information about:

• cities;
• countries;
• restaurants;
• cafés;
• bars;
• hotels;
• beaches;
• museums;
• attractions;
• nightlife venues;
• Events you add, such as concerts, festivals, theatre and other performances, sports matches and similar activities, including the event name, venue, city and date;
• other places and experiences;
• photographs and videos;
• descriptions;
• personal notes;
• recommendations;
• reviews;
• memories;
• comments;
• Books;
• Lists;
• saved content; and
• other content you choose to provide.

We may associate this information with your account, profile, Book, List, city, place or experience in order to provide the relevant functionality.

5. Passport and Experience History

Wealin may organise information associated with your experiences into a personal Passport.

Depending on your activity, your Passport may include:

• countries visited;
• cities visited;
• places recorded;
• Events attended;
• map representations;
• country stamps;
• favourite places;
• experience or travel statistics;
• stars or achievements; and
• other summaries based on information associated with your account.

These features are primarily generated from places and experiences that you add to or interact with through Wealin.

6. Place Information and Location

Wealin allows you to manually enter or select cities, countries, restaurants, venues, Events and other places.

We may process those place names and their geographic coordinates to provide features such as:

• Passport maps;
• city organisation;
• Books;
• place discovery;
• recommendations; and
• experience organisation.

We may use Apple mapping or geocoding functionality to convert a place name into geographic coordinates.

Device GPS

Wealin does not currently use your device’s GPS to determine your physical location for these features and does not request precise device-location permission for this purpose.

This is separate from approximate or coarse location information that may be processed by third-party advertising technology for eligible adult users, as described in the Advertising section below.

7. Photos and Videos

When you upload photographs or videos, we may process them to:

• store and display your content;
• associate media with places and experiences;
• create Books and memories;
• provide profile functionality;
• enable social and discovery features;
• provide creator features; and
• moderate or investigate content where necessary.

You should only upload media that you have the right to use and share.

8. Social Activity

Wealin includes social features.

We may process information about:

• accounts you follow;
• accounts following you;
• likes;
• saves;
• comments;
• blocks;
• Books you interact with;
• places and recommendations you interact with;
• content interactions; and
• creator interactions.

This information may be used to operate and personalise features including Home, Explore and personalised recommendations.

9. Saved Content and Lists

When you save or like relevant content, Wealin may organise it geographically or by category.

For example, saved places associated with London may be organised with other London-related content.

We may process saved-content information to:

• maintain your Lists;
• organise experiences;
• help you rediscover places;
• personalise recommendations;
• provide discovery features; and
• support personalised destination and trip recommendations.

Saved Lists are not currently a separate creator-sale product.

10. Books and Memories

Wealin allows users to organise places, experiences, photographs, recommendations and notes into Books.

We may process Book information to provide:

• Book creation and editing;
• sharing;
• discovery;
• memories;
• recommendations;
• creator functionality;
• paid access where applicable; and
• continued purchaser access to Paid Books.

The visibility of a Book depends on the relevant feature and applicable settings.

11. Wealin AI and Personalised Recommendations

Wealin provides AI-assisted functionality designed to help users discover destinations, places and experiences and to assist with trip planning.

Wealin AI is not currently a general-purpose chat service.

Users do not currently submit free-form chat messages or prompts to Wealin AI. Depending on the feature, you may select a city, destination or one of the available recommendation options.

To personalise recommendations, Wealin may use information associated with your activity, including:

• accounts you follow;
• your Books;
• your saved content and Lists;
• content you have liked;
• places and experiences associated with your account; and
• the city, destination or available recommendation option you select.

This information may be used to:

• recommend destinations;
• recommend places or experiences;
• suggest where you might travel next; and
• create personalised trip recommendations.

These recommendations are intended to assist discovery and planning and are not intended to make legal or similarly significant decisions about you.

Where an external AI service provider processes personal information on behalf of Wealin in the production Service, we will provide information about that processing where required by applicable law.

12. Creator Information

Eligible users aged 18 or over may access creator monetisation features.

Where you participate in these features, we may process information including:

• creator eligibility;
• age eligibility;
• follower count;
• Books submitted for paid publication;
• selected Book price;
• approval status;
• sales;
• estimated creator earnings;
• payout-related status;
• transaction records; and
• creator moderation or eligibility information.

Users under 18 cannot participate in creator monetisation.

Wealin does not currently require creators to upload a passport or other government-issued identity document directly to Wealin as part of the existing seller eligibility process.

Additional information may become necessary for payments, identity verification, tax reporting or other legal requirements if creator payouts become operational. Where this introduces additional processing, appropriate privacy information will be provided.

13. Purchases and Subscriptions

Digital purchases made through the Wealin iOS application are processed using Apple In-App Purchase.

Wealin does not receive your complete payment-card information from Apple.

We may process information including:

• product purchased;
• transaction identifier;
• transaction date;
• purchase status;
• subscription status where applicable;
• entitlement status;
• refund or revocation status;
• purchase history associated with Wealin; and
• information required to restore or maintain purchased access.

We use RevenueCat to help manage purchase validation, subscriptions and digital entitlements.

14. Paid Books and Creator Transactions

Where Paid Books are available, we may process information necessary to:

• determine seller eligibility;
• enforce applicable pricing rules;
• submit Books for approval;
• approve or reject Paid Books;
• process purchaser entitlements;
• maintain purchased access;
• record creator sales;
• calculate estimated creator earnings;
• manage transaction and payout status;
• process refunds or adjustments;
• reconcile financial records; and
• prevent fraud or manipulation.

Certain financial records may need to remain after an account is deleted for accounting, tax, refund, payout, fraud-prevention, dispute-resolution or other legal purposes.

Where appropriate, identifiers linking those records to the deleted user may be removed or de-identified while the underlying financial record is retained.

15. Commercial Relationships and Disclosures

Where you recommend or feature a business or place, Wealin may ask whether you have a commercial or material relationship with that business.

We may process information indicating:

• no commercial relationship;
• paid or sponsored;
• gifted or complimentary;
• affiliate;
• own or connected business; or
• another material commercial relationship.

We may use this information to provide appropriate disclosures and support compliance with advertising and consumer-protection requirements.

Selling access to a Wealin Book does not, by itself, mean that every business or place included in the Book is an advertiser or sponsor.

16. Advertising

Wealin may display advertising to eligible adult users who do not have an applicable ad-free entitlement.

We currently use Google Mobile Ads for advertising.

Advertising may include banner and interstitial advertisements.

Users Under 18

Wealin does not display advertising to users whose account date of birth identifies them as under 18.

For these users, Wealin’s age-gated advertising system is designed not to request or display Google advertising and not to request Apple App Tracking Transparency permission solely for advertising purposes.

Where age eligibility cannot reliably be determined, advertising is not displayed until eligibility is established.

Users Aged 18 or Over

For eligible adult users, advertising technology may process information such as:

• device identifiers;
• advertising data;
• product interactions;
• approximate or coarse location;
• diagnostic information;
• crash information; and
• performance information,

depending on your device, region, permissions, consent choices and the operation of the advertising service.

Advertising technology does not give Wealin access to your device’s precise GPS location through the place features described in Section 5.

17. Advertising Consent and Privacy Choices

We use Google User Messaging Platform (“UMP”) to manage applicable advertising privacy and consent choices.

Depending on your location and applicable law, you may be presented with a privacy or consent message before eligible advertising requests are made.

Advertising requests are subject to:

• age eligibility;
• applicable consent requirements;
• your advertising privacy choices; and
• relevant device permissions.

Where required, Wealin provides eligible users with access to advertising privacy choices through the application settings.

You may be able to change or withdraw applicable advertising choices later.

18. App Tracking Transparency

On Apple devices, certain advertising activities may require permission through Apple’s App Tracking Transparency (“ATT”) framework.

Where relevant, eligible users aged 18 or over may be presented with Apple’s ATT permission request.

If you refuse tracking permission:

• you can continue using Wealin;
• ordinary Wealin functionality remains available; and
• advertising may operate using more limited information where legally permitted.

Known users under 18 are not asked for ATT permission solely for Wealin advertising.

19. Reports, Blocking and Moderation

We may process information necessary to protect users and enforce Wealin’s rules.

This may include:

• reports submitted by users;
• reported accounts;
• reported content;
• report reasons;
• supporting information;
• blocked-user relationships;
• moderation decisions;
• enforcement actions;
• relevant account or content history; and
• appeal information where applicable.

Certain moderation records may remain after an account or content is deleted where reasonably necessary for:

• user safety;
• abuse prevention;
• fraud prevention;
• enforcement;
• legal compliance; or
• establishing, exercising or defending legal claims.

20. Technical Information

We and our service providers may process technical information necessary to operate, secure and troubleshoot the Service.

Depending on the relevant service, this may include:

• device or application information;
• authentication records;
• server or request logs;
• technical errors;
• crash information;
• performance information;
• transaction-related technical information; and
• security information.

Advertising-related processing is described separately above.

21. How We Use Personal Information

We may use personal information to:

• create and maintain accounts;
• authenticate users;
• determine age eligibility;
• provide profiles and Passport functionality;
• store and display experiences;
• organise Books, Lists and memories;
• operate social functionality;
• provide Home and Explore;
• provide local recommendations;
• personalise content and discovery;
• provide Wealin AI recommendations;
• process digital purchases;
• maintain purchaser entitlements;
• administer creator features;
• review Paid Books;
• maintain necessary financial records;
• enforce age restrictions;
• provide advertising to eligible adults;
• manage advertising consent and privacy choices;
• provide commercial disclosures;
• respond to support requests;
• moderate content;
• investigate reports;
• prevent fraud and abuse;
• maintain security;
• enforce our Terms and policies;
• comply with legal obligations;
• establish, exercise or defend legal claims; and
• operate, maintain and improve Wealin.

22. Legal Bases for Processing

Where UK GDPR or EU GDPR applies, we process personal information under an appropriate lawful basis.

Performance of a Contract

We may process information where necessary to provide features you request, including:

• creating and maintaining your account;
• storing your experiences and Books;
• providing social functionality;
• providing purchased content; and
• maintaining digital entitlements.

Legitimate Interests

Where appropriate, we may rely on legitimate interests including:

• operating and improving Wealin;
• maintaining security;
• preventing fraud and abuse;
• moderating content;
• protecting users;
• enforcing our policies;
• maintaining marketplace integrity; and
• resolving technical problems.

We consider the potential impact on users before relying on legitimate interests.

Legal Obligation

We may process information where necessary to comply with applicable legal obligations, including relevant:

• accounting;
• tax;
• regulatory;
• consumer-protection; and
• safety requirements.

Consent

We rely on consent where applicable law requires it, including for certain advertising or tracking activities.

Where processing relies on consent, you may withdraw your consent as permitted by applicable law.

Withdrawal does not affect processing lawfully carried out before withdrawal.

23. Public Information

Wealin contains social and user-generated content.

Information you choose to make public may be visible to other users or other audiences indicated by the relevant feature.

This may include:

• username;
• profile photograph;
• Books;
• experiences;
• recommendations;
• photographs;
• reviews;
• comments;
• follower information; and
• other information you choose to publish.

You should not publish information you do not want the relevant audience to see.

24. Service Providers and Recipients

We use third-party services where necessary to operate Wealin.

Supabase

We use Supabase for backend infrastructure, including authentication, database and storage services.

Account information, User Content, social activity and other application data may therefore be processed through Supabase infrastructure.

Our primary Supabase database region is currently configured in London, United Kingdom.

Apple

Apple may process information in connection with services including:

• Sign in with Apple;
• Apple In-App Purchase;
• subscription functionality;
• App Tracking Transparency;
• mapping or geocoding functionality; and
• other Apple platform functionality used by Wealin.

Where Apple independently determines its processing, Apple’s applicable privacy terms apply.

RevenueCat

We use RevenueCat to support:

• purchase validation;
• subscription status;
• digital entitlements;
• transaction-related functionality; and
• restoration of eligible purchases.

Google

For eligible adult users, we use Google Mobile Ads to provide advertising.

We also use Google User Messaging Platform to manage applicable advertising consent and privacy choices.

Google may process advertising and technical information as described in Sections 15–17, subject to applicable consent requirements, device permissions and privacy choices.

25. Other Disclosures of Information

We may disclose personal information where reasonably necessary:

• to service providers acting on our behalf;
• to professional advisers;
• to regulators or authorities where legally required;
• to comply with valid legal process;
• to investigate unlawful activity;
• to prevent fraud or serious harm;
• to protect users, our rights or our property;
• to establish, exercise or defend legal claims; or
• in connection with a merger, acquisition, financing, restructuring or sale of all or part of our business, subject to applicable law.

26. International Data Transfers

MyKolly Limited is established in the United Kingdom and Wealin may be accessed from multiple countries.

Some service providers or their subprocessors may process information outside your country of residence.

Where UK or EEA personal information is transferred internationally, we use or rely on appropriate safeguards where required, which may include:

• adequacy regulations or decisions;
• Standard Contractual Clauses;
• the UK International Data Transfer Agreement or applicable UK Addendum; or
• another legally recognised transfer mechanism.

Our primary Supabase database region is currently located in London. Other service providers and their subprocessors may use infrastructure in other jurisdictions.

27. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected and for applicable legal, accounting, tax, safety and dispute-resolution requirements.

How long information is retained may depend on:

• the type of information;
• whether your account remains active;
• the feature involved;
• completed purchases;
• creator transactions and payouts;
• legal requirements;
• accounting and tax requirements;
• safety and moderation needs;
• fraud prevention; and
• actual or potential disputes.

Where information is no longer required, we may delete or de-identify it.

28. Account and Content Deletion

You may initiate deletion of your Wealin account through the account-deletion functionality available within the application.

When an account is deleted, personal information that is no longer necessary is deleted or de-identified, subject to information that we are permitted or required to retain.

Uploaded media associated exclusively with deleted content is designed to be removed from active storage where it is no longer required.

When certain uploaded profile media is replaced, Wealin may remove the previous media file where it is no longer used.

Limited information may remain where necessary for:

• completed transactions;
• purchaser entitlements;
• creator sales and payouts;
• refunds;
• accounting;
• tax;
• fraud prevention;
• moderation and safety;
• legal obligations; or
• legal claims.

Retention of these limited records does not mean that your deleted public profile remains active.

29. Financial Records After Account Deletion

Deleting an account does not necessarily delete the underlying record that a financial transaction occurred.

Where necessary, we may retain limited information such as:

• transaction amount;
• transaction date;
• purchase or payout status;
• transaction identifiers; and
• information required for reconciliation.

Where appropriate, the account identifier linking a financial record to a deleted user may be removed while the underlying financial record remains.

We do not retain unnecessary profile information solely because a financial transaction occurred.

30. Children and Teen Users

Wealin is intended for users aged 13 and over.

Under 13

Users under 13 are not permitted to maintain a Wealin account.

Where the date of birth supplied during registration indicates that a user is under 13, the account is not permitted to continue.

Ages 13–17

Users aged 13–17 may access eligible Wealin functionality but:

• cannot sell Paid Books;
• cannot access creator monetisation;
• cannot access creator payout functionality;
• are not served Wealin advertising through the age-gated advertising system; and
• are not asked for ATT permission solely for Wealin advertising.

Creator monetisation and advertising are restricted to eligible users aged 18 or over.

We aim to apply age-appropriate privacy protections where required by applicable law.

31. Age Information

We currently use the date of birth supplied during registration to determine age eligibility.

We do not currently require users to provide government-issued identification to Wealin solely to prove their age.

We may introduce proportionate additional age-assurance mechanisms where required by law or reasonably necessary for safety.

If additional age-assurance processing is introduced, appropriate privacy information will be provided.

32. Your Privacy Rights

Depending on where you live and applicable law, you may have rights to:

• access your personal information;
• correct inaccurate information;
• request deletion;
• restrict certain processing;
• object to certain processing;
• receive certain information in portable form;
• withdraw consent where processing relies on consent;
• opt out of certain regulated advertising or sharing activities where applicable; and
• complain to a competent data-protection authority.

These rights may be subject to applicable legal limitations and exceptions.

To make a privacy request, contact:

legal@wealin.app

We may take reasonable steps to verify that a request relates to you before fulfilling it.

33. United Kingdom

Where UK data-protection law applies, you may exercise applicable rights under the UK GDPR and Data Protection Act 2018.

You also have the right to complain to the Information Commissioner’s Office (“ICO”).

You may contact us first at legal@wealin.app, but you are not required to do so before exercising your right to complain to the ICO.

34. European Economic Area

Where EU GDPR applies, you may exercise applicable rights under the GDPR.

Our EU representative is:

Candan Uzun
Meister-Bertram-Straße 2
22309 Hamburg
Germany
Email: candanuzunn@gmail.com

You may also have the right to lodge a complaint with the competent supervisory authority in your country.

35. Türkiye

Where Türkiye’s Personal Data Protection Law No. 6698 (“KVKK”) applies, personal data is processed in accordance with applicable KVKK requirements.

Our Türkiye data controller representative is:

Ezgi Terzi
Arnavutköy Mah.
Arnavutköy Dere Sok. No: 58 D:2
Beşiktaş, İstanbul
Türkiye
Email: ez.terzi@gmail.com

Eligible individuals may exercise applicable rights under Article 11 of the KVKK, including the rights to:

• learn whether personal data is processed;
• request information about processing;
• learn the purpose of processing and whether data is used accordingly;
• learn the third parties to whom personal data is transferred;
• request correction of incomplete or inaccurate personal data;
• request deletion or destruction where the applicable legal conditions are satisfied;
• request notification of applicable correction or deletion operations to relevant recipients;
• object to certain results arising exclusively through automated analysis; and
• request compensation where legally available for unlawful processing.

Requests may be submitted in accordance with applicable KVKK procedures.

A separate KVKK Aydınlatma Metni provides or may provide additional information specifically required under Turkish law.

VERBİS registration information will be included where appropriate once registration has been confirmed as completed.

36. United States

Users in the United States may have additional privacy rights under applicable state or federal law.

Depending on the law that applies to Wealin and your state of residence, these may include rights concerning:

• access;
• correction;
• deletion;
• portability; and
• opting out of certain forms of targeted advertising, sale or sharing.

Where applicable law requires additional notices or controls, we will provide them as required.

Wealin does not knowingly permit children under 13 to maintain accounts.

37. Canada

Where Canadian privacy law applies, Wealin processes personal information in accordance with applicable requirements relating to:

• accountability;
• appropriate purposes;
• meaningful consent where required;
• limiting collection, use, disclosure and retention;
• safeguards;
• openness;
• access and correction; and
• complaint handling.

Canadian users may contact legal@wealin.app regarding applicable privacy rights.

38. Security

We use reasonable technical and organisational measures designed to protect personal information.

These may include measures relating to:

• authentication;
• access controls;
• database permissions;
• backend security;
• administrative access;
• secure communications; and
• storage controls.

No internet or electronic-storage system can guarantee absolute security.

You are responsible for keeping your account credentials secure and should contact us if you believe your account has been compromised.

39. Automated and Personalised Features

Wealin may use account activity and experience information to organise and personalise parts of the Service.

For example, your:

• follows;
• Books;
• saved content;
• likes;
• selected destination; and
• experiences

may influence the recommendations presented to you.

These recommendations are intended for discovery and trip planning and are not designed to make decisions producing legal or similarly significant effects concerning you.

40. Sale, Sharing and Targeted Advertising

MyKolly Limited does not sell personal information to data brokers in exchange for money.

However, the use of third-party advertising technology may be considered “sharing”, “targeted advertising”, “cross-context behavioural advertising” or a similar regulated activity under certain privacy laws.

Where applicable law gives you a right to consent, withdraw consent or opt out of such processing, Wealin will provide and honour the applicable mechanism.

Users under 18 are not served advertising through Wealin’s age-gated advertising system.

41. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to:

• Wealin features;
• our processing activities;
• service providers;
• advertising practices;
• legal requirements;
• safety practices; or
• business operations.

Where required by applicable law, we will provide appropriate notice of material changes.

The Last Updated date at the beginning of this Policy indicates when it was most recently revised.

42. Contact Us

For privacy, data-protection and legal enquiries:

legal@wealin.app

For support and moderation:

support@wealin.app

MyKolly Limited
84 Longcroft Rise
Loughton, England
IG10 3ND
United Kingdom

Website: wealin.app