EWIG
Privacy Policy
Last updated: October 4, 2026 · Effective date: October 4, 2026
This Privacy Policy explains, in plain English, how EWIG collects, uses, shares, and protects your personal data, and the rights you have over it. It is written to meet the requirements of the EU General Data Protection Regulation (GDPR), the UK GDPR and Data Protection Act 2018 (UK GDPR), and the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA). Section 17 contains additional disclosures for California residents.
Please read this alongside our Terms of Service.
1. Who we are (Data Controller)
EWIG is a travel app that turns your photos into trips, connects travelers, and lets you book and host experiences. EWIG is operated by Kairos Digital Labs LLC ("EWIG", "we", "us", "our"), which is the data controller for the personal data described in this policy (and, for CCPA/CPRA purposes, the "business").
c/o Northwest Registered Agent LLC, 522 W Riverside Ave Ste N, Spokane, WA 99201, USA
Contact for privacy matters
If you have any question about this policy or want to exercise your rights, email support@ewig.ai.
2. Scope
This policy covers the EWIG mobile app (iOS and Android) and the EWIG website at ewig.ai, and all related features, including:
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creating trips automatically from your photos;
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sharing stories and posts, following other users, and building a travel feed;
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direct messaging between users;
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the marketplace for booking and hosting paid activities and group trips;
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Solo Connect, which helps solo travelers find and meet other travelers;
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AI-assisted trip planning and story generation;
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ordering printed photo books.
It does not cover third-party services that have their own privacy policies (for example, Apple's App Store, Google Play, or a host's own website), even where you reach them through EWIG.
3. The personal data we collect
3.1 Data you give us
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Account and profile: email address, phone number, name and/or username, password or authentication credentials, home city and country, bio, avatar photo, and cover photo.
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Content you create: travel photos and videos, stories and posts, trip plans, messages you send to other users, marketplace and host listings, and reviews.
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Photo metadata: your travel photos typically contain GPS location coordinates and EXIF timestamps embedded by your device. Location data is a core part of how EWIG builds your trips, so this is a key data type for us.
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Bookings and hosting: trip and booking history, activities you host or attend, and the shipping name and address you provide for photo book orders.
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Identity verification (hosts and Solo Connect only): government-issued ID and related identity-verification data, and where required a selfie, processed through Stripe Identity. We do not store your ID document ourselves; Stripe processes it and returns a verification result to us. See Section 8.
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Communications with us: the content of support requests and other correspondence.
3.2 Data we collect automatically
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Device and technical data: device push-notification tokens, IP address, device and operating-system type, app version, and diagnostic information.
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Usage and analytics events: how you interact with the app (screens viewed, features used). Product analytics are opt-in — see Section 10.
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Precise and approximate location: from photo GPS/EXIF as above, and, where you grant the permission, from your device's location services.
3.3 Data from third parties
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Google Photos import: if you connect Google Photos via OAuth, we receive the photos and metadata you choose to import.
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Payment and payout data: transaction records from Stripe. We do not receive or store full payment card numbers.
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Subscription status: purchase and entitlement information from the app stores and RevenueCat when you subscribe to Solo Connect or another paid plan.
3.4 Sensitive data
Some data we handle is especially sensitive: government ID and identity-verification data (Section 3.1), face geometry from face detection (Section 8A), and precise location data derived from photos or your device. We apply extra protections to both (see Section 12 and our DPIA in dpia.md), collect them only where necessary, and rely on the appropriate lawful basis and, for special-category data, an Article 9 condition.
4. Why we use your data and our lawful bases
Under GDPR/UK GDPR we must have a lawful basis for each purpose. The table below maps each purpose to the data used and the lawful basis we rely on.
Purpose
Create and manage your account
Data used
Email, phone, name/username, authentication data
Lawful basis (GDPR Art. 6)
Contract (Art. 6(1)(b))
Purpose
Build trips from your photos (incl. GPS/EXIF)
Data used
Travel photos, GPS coordinates, EXIF timestamps
Lawful basis (GDPR Art. 6)
Contract for photo metadata; device location via Consent (Art. 6(1)(a))
Purpose
Social features: posts, following, feeds
Data used
Profile, content, follow graph
Lawful basis (GDPR Art. 6)
Contract; visibility governed by your privacy settings and Consent
Purpose
Direct messaging between users
Data used
Message content, sender/recipient IDs
Lawful basis (GDPR Art. 6)
Contract
Purpose
Marketplace: group trips, bookings, hosting
Data used
Booking history, listings, attendee lists
Lawful basis (GDPR Art. 6)
Contract
Purpose
Process payments and payouts
Data used
Payment records, payout/bank details
Lawful basis (GDPR Art. 6)
Contract; Legal obligation (Art. 6(1)(c)) for tax and accounting records
Purpose
Identity verification for hosts and Solo Connect
Data used
Government ID, selfie, verification result
Lawful basis (GDPR Art. 6)
Contract; Legal obligation (fraud prevention where applicable); Consent/Art. 9 condition where the data is special-category
Purpose
Solo Connect: connect with other travelers
Data used
Profile, location, subscription status, matching preferences
Lawful basis (GDPR Art. 6)
Contract; matching preferences via Consent
Purpose
Photo book printing and fulfillment
Data used
Shipping name/address, selected photos
Lawful basis (GDPR Art. 6)
Contract
Purpose
Transactional email/SMS (receipts, one-time codes, service alerts)
Lawful basis (GDPR Art. 6)
Contract
Purpose
Marketing email and marketing push notifications
Data used
Email, push token, preferences
Lawful basis (GDPR Art. 6)
Consent (Art. 6(1)(a)) — opt-in, withdrawable at any time
Purpose
Service push notifications
Lawful basis (GDPR Art. 6)
Contract / Legitimate interest (Art. 6(1)(f))
Purpose
Security, fraud prevention, and abuse moderation
Data used
Usage, IP, content, device data
Lawful basis (GDPR Art. 6)
Legitimate interest (Art. 6(1)(f)); Legal obligation
Purpose
Product analytics and improvement
Data used
Usage/analytics events
Lawful basis (GDPR Art. 6)
Consent (analytics are opt-in — see Section 10)
Purpose
AI trip planning and AI-assisted stories
Data used
Trip data and the prompts you provide
Lawful basis (GDPR Art. 6)
Contract / Legitimate interest
Purpose
Comply with legal requests, disputes, chargebacks
Data used
Relevant records
Lawful basis (GDPR Art. 6)
Legal obligation; Legitimate interest
4.1 Legitimate interests
Where we rely on legitimate interests, we have weighed our interests against your rights and freedoms and concluded the processing is proportionate and expected. Our interests are running a secure, functioning, and improving service and preventing fraud and abuse. You can object at any time (see Section 9), and where you object to direct marketing we will always stop.
5. Who we share your data with (recipients and subprocessors)
We do not sell your personal data. We share it with service providers ("subprocessors") who process it on our behalf under data-processing agreements, and with other users where you choose to make content visible.
Our key subprocessors are listed below. A fuller register is maintained in subprocessors.md.
Purpose
Hosting, database, authentication
Data shared
Account, profile, content, messages, most personal data
Purpose
Payments, Stripe Identity (ID verification), Connect payouts
Data shared
Payment data, government ID, name, payout/bank details
Purpose
Subscription management
Data shared
Subscription and purchase identifiers, app user ID
Subprocessor
Cloudflare R2
Purpose
Photo and media storage
Data shared
Photos, videos, media (may contain GPS/EXIF)
Purpose
Video hosting and streaming
Data shared
Video content and playback data
Purpose
Print-on-demand photo book fulfillment
Data shared
Shipping name and address, selected photos
Subprocessor
Google (Google Photos)
Purpose
Photo import via OAuth
Data shared
Photos and metadata you choose to import
Subprocessor
Google (Gemini API)
Purpose
AI trip planning, AI trip stories, translating posts
Data shared
Trip details and notes you enter for AI planning; photos, stops and captions you choose for AI stories; text being translated
Purpose
Transactional and marketing email
Data shared
Email address, name, message content
Purpose
Product analytics (opt-in)
Data shared
Usage/analytics events, device data
Subprocessor
Apple APNs / Google FCM
Purpose
Push-notification delivery
Data shared
Push tokens, notification payloads
We may also disclose personal data to comply with law, respond to lawful requests from authorities, enforce our Terms of Service, protect our rights, users, or the public, and to a successor entity in the event of a merger, acquisition, or sale of assets (with notice where required).
Other users see the profile fields and content you choose to make visible through your privacy settings, plus any messages you send them and any listings, posts, or reviews you publish. Some vendors (for example Google for its platform, or an activity provider) may act as independent controllers for their own purposes; where that is the case, their own privacy terms apply.
Before we add a new subprocessor that materially affects how your data is processed, we will update this policy and, where required, give notice.
6. International data transfers
EWIG's backend (Supabase) is hosted in the United States (AWS us-east-1), and several other subprocessors are US-based. This means that personal data of users in the European Economic Area (EEA) and the UK is transferred to and stored in the United States, a country outside the EEA/UK.
Where we transfer EEA/UK personal data internationally, we protect it using:
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the European Commission's Standard Contractual Clauses (SCCs) and the UK's International Data Transfer Addendum (IDTA) or the UK Addendum to the SCCs; and
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supplementary technical and organisational measures, including encryption in transit and at rest and access controls.
Where a subprocessor is certified under the EU–US Data Privacy Framework, we may also rely on that mechanism. You can request a copy of the relevant transfer safeguards by emailing support@ewig.ai.
7. How long we keep your data (retention)
We keep personal data only as long as necessary for the purposes described above, then delete or irreversibly anonymise it. A summary is below; full detail is in data-retention.md.
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Account and profile: for the life of your account; deleted within 30 days after account deletion (residual copies purged from backups within our backup cycle).
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Photos, videos, and content: for the life of your account; deleted within 30 days of account deletion.
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Messages: deleted after account deletion, subject to the other participant retaining their own copy of the conversation.
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Payment and transaction records: retained for 7 years from the transaction to meet tax, accounting, and anti-fraud legal obligations, even after account deletion.
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Identity-verification records: the verification result is kept while your host or Solo Connect status is active; the ID document itself is held by Stripe under its own retention rules, not by EWIG.
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Analytics and usage logs: retained for up to 24 months, then aggregated or anonymised.
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Support communications: retained for up to 24 months after your matter is resolved.
When you delete your account, some records are retained under legal-hold obligations (chiefly financial records). We restrict that retained data to the legal purpose that justifies keeping it and delete it once the retention period expires. See data-retention.md, "Legal hold vs. full erasure".
8. Identity verification (Stripe Identity)
Hosts and Solo Connect subscribers must verify their identity before using those features. This uses Stripe Identity, which collects your government-issued ID and, where required, a selfie, to confirm you are who you say you are and to help prevent fraud, impersonation, and abuse — which is especially important because Solo Connect facilitates in-person meetings. Stripe processes the ID document and returns to EWIG only the verification outcome and limited associated details, not the raw document. This is higher-risk processing and is assessed in our DPIA (dpia.md). If an automated check fails, you can ask for human review by contacting support@ewig.ai (see Section 11).
8A. Face detection in your trip photos
EWIG can find the people in your trip photos so you can name them or tag friends and so your AI trip story can use their names. Face detection is ON by default when you accept these terms and this policy. You can turn it off for any trip with the "Faces" switch in that trip's "Who was on this trip?" section, or for all trips in Settings → Privacy → Face Detection. Turning it off deletes the face data (see Retention below).
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What we collect: when the feature is on, we detect faces in the photos you add to your trips and create a numerical "face template" (a face geometry measurement) for each detected face, plus the face's position in the photo. This may qualify as biometric information or biometric identifiers under laws such as the Illinois Biometric Information Privacy Act (BIPA), Texas and Washington biometric laws, the CCPA/CPRA, and special-category (Article 9) data under GDPR/UK GDPR. We also make a rough, automated estimate of each detected face's age range and gender, used only to avoid grouping clearly different people together (for example, an adult with a child). These estimates are never shown, shared, or used for any other purpose, and are deleted along with the face data.
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Why: only to group photos of the same person within your own trips so you can label them. We do not use face templates to identify strangers, to search for people across other users' accounts, for advertising, or for any other purpose.
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Lawful basis: your explicit consent (GDPR Art. 6(1)(a) and Art. 9(2)(a)) and your written release under BIPA, given when you accept these terms and this policy. You can withdraw consent at any time with the "Faces" switch on a trip or in Settings; withdrawing does not affect processing before withdrawal.
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Where it is processed and stored: face detection runs in the EWIG app and our web app on your device; resulting face templates are stored in our database (Supabase) attached to your trip, accessible only to your account. People you name on a trip may be shown to viewers of that trip only as names you chose — never the face templates.
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No selling or sharing: we never sell, lease, trade, or otherwise profit from face data, and we do not disclose it to third parties except our hosting providers acting on our instructions, or where required by law.
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Retention and destruction: face templates are permanently deleted (a) when you turn "Faces" off or tap "Delete all" on a trip (that trip is then not scanned again unless you ask), (b) immediately for all your trips when you turn Face Detection off, (c) when you permanently delete the trip or your account, and (d) in any event no later than 3 years after your last interaction with EWIG. This retention schedule and destruction guideline is publicly available in this policy.
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Other people in your photos: your photos may include people who have not used EWIG. Only turn this feature on for photos where you have the right to do so, and honour anyone's request not to be named or grouped. Anyone may ask us to delete face data about them by contacting support@ewig.ai.
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Security: face data is protected with the same or stronger safeguards we use for other sensitive data (encryption in transit and at rest, access limited to your account).
9. Your rights
Under GDPR/UK GDPR you have the right to:
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Access — obtain confirmation that we process your data and a copy of it.
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Rectification — correct inaccurate or incomplete data.
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Erasure ("right to be forgotten") — have your data deleted, subject to legal-retention exceptions (see Section 7).
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Restriction — limit how we process your data in certain circumstances.
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Portability — receive your data in a structured, commonly used, machine-readable format and, where technically feasible, have it transmitted to another controller.
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Object — object to processing based on legitimate interests, and to direct marketing at any time.
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Withdraw consent — where processing is based on consent, withdraw it at any time (this does not affect the lawfulness of processing before withdrawal).
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Not be subject to solely automated decisions producing legal or similarly significant effects (see Section 11).
9.1 How to exercise your rights — in the app
You can exercise most rights directly in EWIG:
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Access and portability: Settings → Privacy & Data → Download my data. This produces a structured export of your personal data.
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Rectification: edit your profile fields directly in the app (profile editing).
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Erasure: Settings → Delete My Account. This deletes your account and associated personal data, subject to the legal-retention exceptions in Section 7.
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Consent: manage marketing and notification preferences with the notification toggles in Settings, and manage analytics and other consent via the consent banner / privacy controls. You can withdraw any consent at any time.
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Visibility: adjust who can see your profile and content with your per-field privacy settings.
9.2 How to exercise your rights — by email
You can also email support@ewig.ai for any request, including restriction and objection. We respond within one month, extendable by two further months for complex or numerous requests (we will tell you if we need the extension). We may need to verify your identity before acting. Exercising your rights is free unless a request is manifestly unfounded or excessive.
If we cannot fulfil part of a request (for example, because a legal-retention obligation applies), we will tell you why.
10. Cookies, tracking, and analytics
Product analytics (PostHog) are opt-in. We use PostHog to understand how the app and website are used so we can improve them. We only collect analytics events after you have opted in through the consent banner or privacy controls, and you can withdraw that consent at any time. If you do not opt in, EWIG still works.
On the ewig.ai website we use:
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Strictly necessary cookies and similar technologies (login/session, security) — these are required for the site to function and do not need consent.
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Analytics/performance technologies (PostHog) — used only with your consent, requested via a cookie/consent banner in the EEA and UK.
We do not use cookies or SDKs for cross-context behavioural advertising, and we do not sell or share your personal data for advertising (see Section 17). In the mobile app, push tokens and diagnostic data are described in Sections 3 and 4.
11. Automated decision-making and profiling
EWIG does not make decisions that produce legal or similarly significant effects about you based solely on automated processing. Identity verification via Stripe Identity may include automated checks, but a failed check does not permanently bar you without a route to human review — contact support@ewig.ai. Our AI features (trip planning and story generation) produce suggestions only and do not make significant decisions about you.
12. How we protect your data (security)
We use technical and organisational measures appropriate to the risk, including: encryption in transit (TLS) and at rest; access controls and least-privilege; row-level security in our database; secure authentication; and minimising the sensitive data we hold ourselves by relying on reputable providers (for example, Stripe for card data and ID verification). No system is perfectly secure, but we maintain an incident-response process (breach-response.md) and will notify you and the relevant authorities of a personal-data breach where the law requires.
13. Children
You must be at least 13 years old to create an EWIG account, or older if the law where you live sets a higher age for using online services without a parent's consent (up to 16 in some EEA countries). Some features are for adults only: you must be at least 18 to use Solo Connect, which connects you with other users and can lead to meeting in person, and to book or host activities. We do not knowingly collect personal data from children under 13. If you believe a child under 13 is using EWIG or has provided us data, contact support@ewig.ai and we will close the account and delete the data.
14. Third-party services and links
EWIG integrates with and links to third-party services (for example Stripe, Google Photos, activity providers, and the app stores). Those services are controlled by others and have their own privacy policies. This policy does not apply to them, and we are not responsible for their practices. Please review their policies before using them.
15. Changes to this policy
We may update this policy from time to time. We will post the new version with an updated "Last updated" date and, for material changes, notify you in-app or by email. Your continued use of EWIG after an update means you accept the revised policy, except where we are required to obtain your consent.
16. Contact and complaints
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Privacy questions or requests: support@ewig.ai
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Postal address: Kairos Digital Labs LLC, c/o Northwest Registered Agent LLC, 522 W Riverside Ave Ste N, Spokane, WA 99201, USA
If you are in the EEA or UK and believe we have not handled your data lawfully, you have the right to lodge a complaint with a supervisory authority:
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UK: the Information Commissioner's Office (ICO), ico.org.uk.
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EEA: your national data protection authority (a list is available at edpb.europa.eu). Complaints may generally be made to the authority in the member state where you live or work.
We would appreciate the chance to address your concerns first, so please consider contacting us before or alongside any complaint.
17. California privacy notice (CCPA/CPRA)
This section applies to California residents and supplements the rest of this policy. Under the CCPA/CPRA, terms like "personal information", "sell", and "share" have the meanings given in that law.
17.1 Notice at Collection
We collect the categories of personal information described in Section 3. Mapped to the CCPA/CPRA categories, these are:
CCPA/CPRA category
Identifiers
Examples we collect
Name, username, email, phone, IP address, account and device identifiers
Purpose
Account, service delivery, security
CCPA/CPRA category
Biometric information (sensitive personal information)
Examples we collect
Face templates from Face Detection (on by default; switch off per trip or in Settings)
Purpose
Grouping people within your own trips (Section 8A); never sold or shared
CCPA/CPRA category
Customer records
Examples we collect
Shipping name/address, payment/transaction records
Purpose
Bookings, payments, photo book fulfillment
CCPA/CPRA category
Commercial information
Examples we collect
Bookings, purchases, subscriptions
Purpose
Provide and manage the marketplace and subscriptions
CCPA/CPRA category
Internet/network activity
Examples we collect
Usage and analytics events (opt-in), diagnostics
Purpose
Improve and secure the service
CCPA/CPRA category
Geolocation data
Examples we collect
Precise location from photo GPS/EXIF and (with permission) device location
Purpose
Build trips, location features
CCPA/CPRA category
Audiovisual information
Examples we collect
Photos and videos you upload
Purpose
Core service, content you create
CCPA/CPRA category
Sensitive personal information
Examples we collect
Government ID and identity-verification data; precise geolocation
Purpose
Identity verification; trip/location features
CCPA/CPRA category
Inferences
Examples we collect
Trip and content suggestions
Purpose
Personalise and improve the service
We collect this information from you, your device, and the third parties described in Section 3.3. We use it for the business purposes described in Section 4 and disclose it to the service providers in Section 5.
17.2 Sensitive personal information
We collect certain sensitive personal information (government ID / identity-verification data and precise geolocation) solely to provide the service you request — for example to verify your identity or build your trips. We do not use or disclose sensitive personal information for purposes other than those permitted under the CCPA/CPRA, so the right to limit its use does not give you additional options beyond what we already do.
17.3 We do not sell or share your personal information
EWIG does not sell your personal information, and does not share it for cross-context behavioural advertising, as those terms are defined under the CCPA/CPRA. We have not sold or shared personal information in the preceding 12 months. Because we do not sell or share, there is nothing to opt out of, but we honour any opt-out preference signals (such as Global Privacy Control) that we receive.
17.4 Your California rights
California residents have the right to:
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Know / access the personal information we have collected about you, including categories and specific pieces.
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Delete personal information we hold about you, subject to legal exceptions.
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Correct inaccurate personal information.
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Opt out of the sale or sharing of personal information (not applicable — we do neither).
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Limit the use of sensitive personal information (we already limit it to permitted purposes — see 17.2).
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Non-discrimination — we will not discriminate against you for exercising your rights.
To exercise these rights, use the in-app controls in Section 9.1 (Settings → Privacy & Data → Download my data for access/portability; Settings → Delete My Account for deletion; profile editing for correction) or email support@ewig.ai. You may use an authorised agent to submit a request on your behalf; we may ask the agent for proof of authorisation and may verify your identity directly. We will not discriminate against you for exercising any of these rights.
© 2026 Kairos Digital Labs LLC · ewig.ai