Privacy Policy

1. Introduction

WowBuddies ("WowBuddies", "we", "us", or "our") operates the platform accessible at www.wowbuddies.com (the "Platform"), which facilitates paid one-on-one video conversation sessions between registered users ("Users") and verified independent providers ("Buddies").

We are deeply committed to protecting the privacy, dignity, and safety of everyone who uses our Platform — with particular care for our Users, many of whom may be vulnerable individuals. This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, with whom we share it, and what rights you have in relation to it.

By accessing or using the WowBuddies Platform, you confirm that you have read and understood this Privacy Policy and agree to the collection and use of your information as described herein. If you do not agree, please do not use our Platform.

2. Who We Are & How to Contact Us

WowBuddies is the data controller responsible for the personal information collected through this Platform. If you have any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact us at:

Email: [email protected]
Website: www.wowbuddies.com

We aim to respond to all privacy-related inquiries within 5 business days.

3. Information We Collect

We collect different categories of information depending on whether you are a User, a Buddy, or simply a visitor to our website.

3.1 Information You Provide to Us

When you register, set up a profile, book a session, or interact with our Platform, you may provide us with:

• Identity and contact information: your name, email address, and profile photograph.
• Location information: your country, state, and city, which is used to facilitate platform functionality and payment processing.
• Profile content: for Buddies, this includes a written bio, introduction video, topic interests, and any additional images you choose to upload.
• Payment information: billing details for Users are processed directly by our third-party payment processor, Stripe. WowBuddies does not store full payment card details.
• Payment information: billing details and payment method information.
• Communications: any messages, reports, or support requests you send to us through the Platform.

3.2 Information Collected Automatically

When you access or use our Platform, we may automatically collect:

• Technical data: your IP address, browser type and version, device type, operating system, and internet service provider.
• Usage data: pages visited, features used, session durations, clickstream data, and interactions with the Platform.
• Cookie data: as further described in Section 10 of this Policy.

3.3 Information Collected During Sessions

WowBuddies facilitates live video sessions conducted entirely within the Platform. Please note the following:

• WowBuddies does not record or store the content of video sessions by default. All session content is transmitted in real time.
• Buddies and Users are strictly prohibited from recording, screenshotting, or capturing any session content in any form. Any violation of this prohibition constitutes a serious breach of the Buddy Code of Conduct and Terms and Conditions and may result in immediate removal from the Platform, forfeiture of earnings, and referral to law enforcement where applicable.
• Session metadata — such as session date, duration, and completion status — is collected for billing, quality assurance, and dispute resolution purposes.

3.4 Information We Collect About Vulnerable Users

Many of our Users may be classified as vulnerable adults under applicable law. We apply heightened data protection standards to all User information in recognition of this. We do not collect sensitive categories of personal data (such as health information or financial account details) unless strictly required for Platform operation, and we handle all such information with the utmost care and discretion.

4. How We Use Your Information

We use the personal information we collect for the following purposes, each supported by a lawful legal basis:

4.1 Providing and Operating the Platform

• To create and manage your account.
• To verify Buddy profiles and ensure they meet our safety and quality standards.
• To facilitate session bookings, match Users with suitable Buddies, and process payments.
• To send transactional communications, including booking confirmations, session reminders, and payout statements.

4.2 Safety and Protection of Vulnerable Users

• To monitor platform activity for signs of abuse, exploitation, boundary violations, or fraud — particularly in relation to vulnerable Users.
• To investigate and respond to reports of inappropriate conduct, financial exploitation, harassment, or safety concerns.
• To enforce the Buddy Code of Conduct and take appropriate disciplinary action where violations are identified.
• To facilitate escalation to emergency services or relevant authorities where a User discloses a safety emergency, threat of self-harm, or risk of harm to others.

4.3 Payments and Financial Compliance

• To calculate Buddy earnings, apply the platform commission, and process payouts via Stripe or approved alternative payment providers.
• To maintain accurate financial records and comply with applicable tax and financial reporting requirements.
• To place holds on or withhold payouts where a dispute, suspected policy violation, or fraud flag arises, in accordance with our Payment Policy.

4.4 Platform Improvement and Quality Assurance

• To analyze usage patterns and improve the functionality, safety, and user experience of our Platform.
• To conduct quality assurance reviews of Buddy performance and compliance.
• To address technical issues and improve platform stability.

4.5 Legal and Regulatory Compliance

• To comply with applicable laws, regulations, and legal obligations.
• To respond to lawful requests from regulatory bodies, law enforcement agencies, or courts.
• To enforce our Terms and Conditions, Code of Conduct, Payment Policy, and other platform agreements.

5. Legal Basis for Processing Your Personal Data

Where applicable data protection legislation (such as the GDPR or equivalent laws) requires us to identify a lawful basis for processing personal data, we rely on the following:

• Contract performance: processing necessary to provide the services you have requested or entered into a contract for, including account management, session facilitation, and payment processing.
• Legitimate interests: processing necessary for our legitimate interests in operating a safe, reliable, and high-quality platform — provided those interests are not overridden by your rights and interests.
• Legal obligation: processing required to comply with applicable laws, regulations, or legal proceedings.
• Vital interests: in exceptional circumstances, processing necessary to protect the vital interests of a User, particularly where a safety emergency is disclosed during a session.
• Consent: where we rely on your consent for specific activities (such as marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

6. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties for their own marketing purposes. We may share your information in the following limited circumstances:

6.1 Payment Processors

We use Stripe as our primary payment processor for User transactions and Buddy payouts in supported countries. For Buddies in countries not supported by Stripe, we facilitate payouts through Payoneer, PayPal, or Wise. These providers process payment data on our behalf and are bound by their own privacy policies and applicable data protection standards. We share only the information necessary for payment processing.

6.2 Service Providers

We may engage trusted third-party service providers to assist with platform operations, including hosting, analytics, email delivery, identity verification, and customer support. These providers are contractually required to process your data only for the purposes we specify and in compliance with applicable privacy laws.

6.3 Safety and Legal Obligations

We may disclose personal information without your prior consent where we are required or permitted to do so by law, including:

• To comply with a legal obligation, court order, or lawful request from a government or regulatory authority.
• To protect the safety, rights, or well-being of a User, Buddy, or third party — particularly in circumstances involving a disclosed risk of self-harm, harm to others, or suspected elder abuse or financial exploitation.
• To investigate and take action in response to suspected fraud, platform abuse, or serious violations of our policies.
• To refer matters to law enforcement or regulatory authorities where required or appropriate.

6.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of our business, personal data may be transferred to the relevant successor entity. We will notify you of any such transfer and any material changes to this Privacy Policy that result from it.

6.5 Aggregated and Anonymized Data

We may share aggregated, anonymized demographic or usage statistics with our business partners or publish them publicly. Such data does not identify any individual.

7. Data Retention

We retain your personal data for as long as is necessary to fulfill the purposes described in this Privacy Policy, including:

• Account data: retained for the duration of your active account and for a reasonable period thereafter to allow for dispute resolution, legal compliance, and audit purposes.
• Session metadata: retained for a minimum period necessary for billing, quality assurance, and dispute resolution, and in accordance with applicable legal requirements.
• Payment records: retained as required by applicable financial and tax regulations, typically for a minimum of seven (7) years.
• Safety and incident reports: retained for as long as necessary to manage the report and comply with applicable legal obligations.

When personal data is no longer required, we take reasonable steps to securely delete or anonymize it.

8. Data Security

We implement appropriate technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security practices include:

• Encrypted transmission of data via secure protocols (HTTPS/TLS).
• Access controls limiting personal data access to authorized personnel only.
• Strict prohibition on Buddies recording, screenshotting, or capturing any session content.
• Regular review of our security practices and procedures.

While we take reasonable steps to protect your information, no method of transmission over the internet or electronic storage is entirely secure. We encourage you to use a strong, unique password and to contact us immediately if you suspect any unauthorized access to your account.

9. International Data Transfers

WowBuddies operates as a global platform, and your personal data may be transferred to, stored, or processed in countries other than the one in which you are located. In particular, because Buddies are independent contractors based in various countries around the world, your session may involve a Buddy located in a different jurisdiction.

Where we transfer personal data across international borders, we take steps to ensure that appropriate safeguards are in place in accordance with applicable data protection laws, including standard contractual clauses, data processing agreements, or other recognized transfer mechanisms.

10. Cookies and Tracking Technologies

Our Platform uses cookies and similar tracking technologies to enhance your experience and to collect usage data. Cookies are small text files placed on your device by your browser.

We use cookies for the following purposes:

• Essential cookies: necessary for the Platform to function, including session management and security.
• Functional cookies: enable personalization and remember your preferences.
• Analytics cookies: help us understand how the Platform is used so we can improve it.

You may configure your browser to refuse cookies or to alert you when cookies are being sent. Please note that refusing cookies may affect the functionality of certain parts of the Platform.

11. Children's Privacy

The WowBuddies Platform is intended for adults aged 18 and over. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that we have inadvertently collected personal data from a minor, we will take prompt steps to delete it. If you believe we may have collected data from a minor, please contact us immediately at [email protected].

12. Your Privacy Rights

Depending on your location and applicable data protection law, you may have the following rights in relation to your personal data:

• Right of access: to request a copy of the personal data we hold about you.
• Right to rectification: to request correction of inaccurate or incomplete personal data.
• Right to erasure: to request deletion of your personal data in certain circumstances.
• Right to restriction: to request that we limit the processing of your personal data in certain circumstances.
• Right to data portability: to receive your personal data in a structured, machine-readable format where technically feasible.
• Right to object: to object to certain types of processing, including processing based on legitimate interests or for direct marketing purposes.
• Right to withdraw consent: where processing is based on your consent, to withdraw that consent at any time without affecting prior lawful processing.
• Right to lodge a complaint: to lodge a complaint with your local data protection supervisory authority if you believe your rights have been violated.

To exercise any of these rights, please contact us at [email protected]. We will respond to all verified requests within the time-frame required by applicable law (typically 30 days). We may need to verify your identity before processing your request.

13. Buddy-Specific Privacy Provisions

Buddies registered on the WowBuddies Platform are independent contractors, not employees of WowBuddies. The following provisions apply specifically to Buddy data:

13.1 Profile Data

Your profile information — including your name, photograph, introduction video, bio, and selected topics — is displayed to Users on the Platform to facilitate bookings. By registering as a Buddy, you consent to this public display of your profile.

13.2 Performance and Compliance Data

WowBuddies may collect and retain data relating to your session history, reliability record, quality assurance reviews, reported incidents, and compliance with our policies. This information is used for platform management, dispute resolution, and enforcement of the Buddy Code of Conduct.

13.3 Payment and Tax Data

We collect the financial and identity information necessary to facilitate payouts via Stripe or approved alternative platforms (Payoneer, PayPal, or Wise). As an independent contractor, you are solely responsible for your own tax obligations. WowBuddies does not withhold taxes on Buddy earnings unless required to do so by applicable law.

13.4 Confidentiality Obligations of Buddies

All Buddies are bound by strict confidentiality obligations as set out in the Buddy Code of Conduct. Buddies must:

• Treat all User information disclosed during sessions as strictly confidential.
• Never record, screenshot, or capture any session content without express written authorization from WowBuddies.
• Never disclose User information to any individual or entity outside the Platform.
• Never discuss, reference, or share information about Users on social media or any external channel.

Violation of these obligations constitutes a serious breach of the Buddy Agreement and may result in suspension, permanent removal, forfeiture of earnings, and referral to law enforcement.

14. Third-Party Websites and Services

Our Platform may contain links to third-party websites, including our payment partners and other services. We are not responsible for the privacy practices or content of those sites. We encourage you to review the privacy policies of any third-party sites you visit. This Privacy Policy applies solely to information collected by WowBuddies through our own Platform.

15. Changes to This Privacy Policy

WowBuddies reserves the right to update or amend this Privacy Policy at any time to reflect changes to our practices, legal requirements, or Platform features. Where we make material changes, we will notify you by email and/or by posting a prominent notice on the Platform at least 14 days before the changes take effect. The updated policy will display the revised effective date at the top of this document.

Your continued use of the Platform after the effective date of any changes constitutes your acceptance of the updated Privacy Policy. If you do not agree to any updated terms, you should cease using the Platform and may request deletion of your account.

16. Your Acceptance of This Policy

By registering on, accessing, or using the WowBuddies Platform, you signify your acknowledgment and acceptance of this Privacy Policy. If you are a Buddy, you further acknowledge that your data handling obligations under the Buddy Code of Conduct and Buddy Agreement operate alongside and are consistent with this Policy.

If you have questions about this Privacy Policy or your data rights, please do not hesitate to contact us at [email protected].