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WHIRL

Privacy Policy

This Privacy Policy sets out how Whirl (“we”, “us”, “our”) collects, uses, and protects your personal information when you use our website and services. We are committed to protecting your privacy and complying with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who We Are

Whirl is a registered company in England and Wales.

Our contact email for privacy matters is: hello@whirl-ai.co

2. What Data We Collect

We collect the following information:

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  • Email address – when you submit a form to connect with an AI companion

  • Companion selection – the name of the AI you choose to engage with

  • Usage analytics – anonymised data about site interactions (e.g. button clicks, session time)

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We do not collect or store your Telegram messages. All conversations with AI companions occur directly through the Telegram platform and are subject to Telegram’s own privacy policy.

3. How We Use Your Data

We use your data to:

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  • Send you your Telegram access link to the companion you selected

  • Communicate with you about your use of the service (e.g. onboarding, updates)

  • Offer you upgrades or premium features, with your consent

  • Monitor usage patterns on the website to improve performance and experience

4. Legal Basis for Processing

We rely on the following lawful bases:

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  • Consent – for email communication and marketing

  • Legitimate interest – for service delivery and basic analytics

  • Contract – when you use paid services or access specific features

5. How We Store & Protect Your Data

We store data securely on GDPR-compliant platforms.
We retain your email and companion selection for no longer than necessary and delete it upon request.

We have implemented appropriate technical and organisational measures to safeguard your data.

6. Sharing Your Data

We do not sell or share your personal information with third parties for marketing purposes.

We only share limited data with trusted service providers such as:

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  • Telegram – for messaging (subject to their privacy policy)

  • Stripe - for secure payment processing

  • Email providers – to send you service-related communications

All third-party services are GDPR-compliant or governed by similar protections.

6. Sharing Your Data

We do not sell or share your personal information with third parties for marketing purposes.

We only share limited data with trusted service providers such as:

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  • Telegram – for messaging (subject to their privacy policy)

  • Stripe - for secure payment processing

  • Email providers – to send you service-related communications

All third-party services are GDPR-compliant or governed by similar protections.

7. Your Rights (Under UK GDPR)

You have the right to:

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  • Access the personal data we hold about you

  • Request correction or deletion of your data

  • Withdraw consent for marketing at any time

  • Lodge a complaint with the Information Commissioner’s Office (ICO)

To exercise these rights, email: hello@whirl-ai.co

8. Cookies and Analytics

Our website uses essential cookies and anonymised analytics to monitor traffic and improve usability. You can manage cookies via your browser settings. We do not use tracking cookies for advertising.

9. International Data Transfers

We primarily store and process your data within the UK and EEA. If we use services outside these regions (e.g. US-based tools), we ensure appropriate safeguards are in place such as Standard Contractual Clauses (SCCs).

10. Updates to This Policy

We may update this policy from time to time. When we do, we’ll revise the “Effective Date” at the top and notify users of material changes.

11. Contact Us

If you have any questions or requests about your data, please contact: hello@whirl-ai.co

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