Privacy Policy

Last update: April 30, 2025

This Privacy Policy governs your use of our application (collectively referred to as the “Product”). It outlines the types of data we collect, how we store it, how it may be used, with whom it may be shared, and your choices regarding these uses and disclosures. Please be sure to carefully read the entirety of this Privacy Policy when using our Product.

“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

“EEA” includes all current Member States of the European Union and the European Economic Area.

“CCPA” means California Consumer Privacy Act of 2018.

“Process”, in respect of personal data, includes to collect, store, use, and disclose to others.

1. PERSONAL DATA CONTROLLER

The controller of your personal data will be Hanna Dzmitryieva, NIP: 8943189802, 53-206 Wrocław, ul.Rusznikarska 3/11, Poland, email: 100wisheslist@gmail.com.

2. WHAT CATEGORIES OF PERSONAL DATA DO WE COLLECT?

We collect data you make available to us voluntarily (for example, email address, name, date of birth). We also collect data automatically when you use the Product (for example, your IP address, device type).

2.1. Data you give us

You provide us data about yourself when you register for and/or use the Product, for example, when you create a user profile (“Profile”), respond to our emails, or report a problem. The data that you give us includes: Profile data. This includes your email address and password.

2.2. Data we collect automatically:

Data about how you found us. We collect data about your referring URL (that is, the place on the Web where you were when you tapped on our ad).

Browser and Device data. We collect data from or about the devices from which you access the Product, depending on the permissions you’ve granted. We may associate the data we collect from your different devices, which helps us provide consistent Services across your devices. Examples of such data include language settings, IP address, location, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID.
We also collect your Apple Identifier for Advertising (“IDFA”). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).

Usage data. We record how you interact with our Product. For example, we log the features, and content you interact with, how often and long you use the Product, what sections you use, and other interactions.

3. FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA?

We process your personal data:

3.1. to provide services to you

This includes enabling you to use the Product in a seamless manner and preventing or addressing Product errors or technical issues. For example, we use your data to authenticate you and authorize access to our Product.

3.2. to research and analyze your use of the Product

This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Product and our new products. We conduct surveys, research, and test features in development. We analyze the data we have to evaluate our Product, and conduct audits and troubleshooting activities to improve our Product content and layouts. As a consequence, we often decide how to improve the Product based on the results obtained from this processing. For example, if we discover that users do not often use certain section of the Product, we may focus on improving this section.

3.3. to customize the Product for you

We select the payment processor available to you; we may also use your data to determine your eligibility for promotions, sweepstakes, and contests.

3.4. to enforce the Terms and to prevent, detect, investigate, and resolve disputes and/or remediate malicious activities, fraud, other cybercrimes, take legally-required actions, or make sure you are a real person and avoid the creation of fake accounts.

We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with the Terms).

3.5. to communicate with you regarding your use of our Product

We may communicate with you, for example, by email or directly on the Product, including through push notifications. As a result of such processing, we may send you messages about your statistics.

3.6. to show and/or send you marketing communications

We process your personal data for our marketing campaigns. We may add your email address to our marketing list. As a result, you will receive information about our Product, features, offers, promotions, contests, and events or provide other news or information about third party services that may be of interest to you. You can opt out of marketing communications by clicking the “Unsubscribe” button in one of the received emails.

3.7. to provide you customer service and support

As a result of such processing, we will send you messages about the availability of our Product security, payment transactions, status of your orders, legal notices, or other Product-related information.

3.8. to personalize our ads

We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time.

3.9. to comply with legal obligations

We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

4. LEGAL BASIS FOR DATA PROCESSING (EEA ONLY)

In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 2. This section applies only to EEA-based users.

We process your personal data under the following legal grounds:

4.1. your consent;

4.2. to perform our contract with you;

Under this legal basis we:

• Provide the services
• Customize your experience
• Communicate with you regarding your use of the Product
• Verify your identity
• Manage your account and provide you with customer support
• Provide you customer service and support
• Process your payments

4.3. for our (or others’) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;

We rely on legitimate interests:

to communicate with you regarding your use of our Product
This includes, for example, sending you notifications. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Product more often. We also take into account the potential benefits to you.

to research and analyze your use of the Product
Our legitimate interest for this purpose is our interest in improving our Product so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the Product easier and more enjoyable, or to introduce and test new features).

to send you marketing communications
The legitimate interest we rely on for this processing is our interest to promote our Product in a measured and appropriate way. Depending on your jurisdiction, we may rely on your consent for this processing instead.

to personalize our ads
The legitimate interest we rely on for this processing is our interest to promote our Product in a reasonably targeted way. Depending on your jurisdiction, we may rely on your consent for this processing instead.

to enforce the Terms and to prevent and combat fraud
Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorized use of the Product, non-compliance with the Terms.

4.4. to comply with legal obligations. Under this legal basis we, in particular, verify your identity.

5. CALIFORNIA PRIVACY RIGHTS

This section provides additional details about how we process personal data of California consumers and the rights available to them under the California Consumer Privacy Act of 2018 (“CCPA”) and California’s Shine the Light law. Therefore, this section applies only to residents of California, United States.

If you are a resident of California, you may request that we provide you with the information that we have shared with third parties for electronic/online direct marketing purposes, if such sharing has occurred; such information can be provided to you once a year free of charge, and will cover information shared during the past twelve (12) months. Information will be provided within forty-five (45) days of your request, or we will inform you that we need additional time to fulfill your request.

If you are a California resident and wish to make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. You may make this request in writing to us at 100wisheslist@gmail.com. Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this address.

Information shared for purposes other than direct marketing will not necessarily be included in our response to such request. We reserve the right to request and confirm proof of identity as we determine necessary in our sole discretion, and retain your request for at least two years for auditing and user management purposes.

6. DATA RETENTION

We will retain personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

Please note that we have a variety of obligations to retain the data that you provide to us, including to ensure that transactions can be appropriately processed, settled, refunded, or charged-back, to help identify fraud and to comply with anti-money laundering and other laws and rules that apply to us and to our financial service providers. Accordingly, even if you disable/delete your Profile, we will retain certain data to meet our obligations.

7. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes indicated in Section 3 of this Privacy Policy. The types of third parties we share information with include, in particular:

7.1. Service providers

We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:

• data analytics providers (PostHog, Google);
• marketing partners (in particular, social media networks, marketing agencies, email delivery services);

7.2. Law enforcement agencies and other public authorities

We may use and disclose personal data to enforce the Terms, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

7.3. Third parties as part of a merger or acquisition

As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

8. INTERNATIONAL DATA TRANSFERS

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Product set forth in the Terms and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.

In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here ), or (ii) the EU-U.S. Data Privacy Framework (details available here ), or (iii) the European Commission adequacy decisions about certain countries (details available here ).

9. CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy at any time. If we decide to make material changes to this Privacy Policy, you will be notified through our Service or by other available means and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Product after those changes become effective, you agree to be bound by the revised Privacy Policy.

10. AGE LIMITATION

We do not knowingly process personal data from persons under 18 years of age. If you learn that anyone younger than 18 has provided us with personal data, please contact us at 100wisheslist@gmail.com.

11. PRIVACY RIGHTS

To be in control of your personal data, you have the following rights:

Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided to us. You control your Profile; thus, you may access your Profile data at any time and correct or update it at any time by logging in to the Product. You may also request a copy of your personal data collected during your use of the Product at 100wisheslist@gmail.com.

Deleting your personal data. You can request erasure of your personal data by sending us an email at 100wisheslist@gmail.com.

When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.

Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof by sending a request to 100wisheslist@gmail.com.

The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.

The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send a respective request to 100wisheslist@gmail.com.

You may submit requests through an authorized agent, in which case we will need to verify the agent’s identity, your identity, and their authority to act on your behalf before we can process the request.

12. HOW DO WE HANDLE “DO NOT TRACK” REQUESTS?

Except as otherwise stipulated in this Privacy Policy, the Product does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

13. CONTACT US

If you have any questions or concerns about this Privacy Policy or our collection, use, or storage of your data, please do not hesitate to contact us at:

E-mail: 100wisheslist@gmail.com.