Privacy Policy

Table of Contents

• Personal data and processing purposes
• Legal bases for processing (EEA-based users)
• Data sharing
• Exercising your privacy rights
• Age limitation
• International data transfers
• Changes to this Privacy Policy
• Supplemental notice for California residents
• Supplemental notice for Virginia residents
• Account deletion
• Data retention
• Personal data controller
• Contact us

1. Personal Data and Processing Purposes

We may collect the following information and personal data when you access Witsy, or otherwise use the Website, the Application, and/or the Services.

A. Personal Information and Contact Information

This may include your name, Apple account information, user ID, and email address. This information is used to manage your account, authenticate your access, communicate with you through or about Witsy, and provide account-related support.

B. Learning Profile and Preferences

This may include your selected topics, learning goals, aspirations, daily learning minutes, reminder preferences, notification settings, saved items, reading or lesson activity, recall answers, AI feedback, and flashcard or spaced-repetition progress. This information is used to personalize your learning path, recommend relevant books, articles, lectures, summaries, lessons, flashcards, and review sessions, and improve the Services.

C. Technical Data

This may include IP address, logs, device type and name, operating system, app version, time zone, crash data, error data, and time and date of use. These data are processed to ensure the functionality of the Application, detect crashes and errors, conduct technical analysis, maintain security, and operate the Services in accordance with applicable law.

D. Customer Transaction Data

This may include subscription status, subscription plan, billing cycle, purchase identifiers, entitlement status, and related purchase information. Witsy uses RevenueCat to manage subscriptions and purchase entitlements. Payment transactions are handled by the relevant app marketplace or payment provider, and Witsy does not store full payment card details.

E. Cookies and Website Data

The Website may use technical and functional cookies or similar technologies that are essential for basic website functions, security, remembering preferences, and improving the user experience. You may set your browser to block cookies and similar technologies, but this could prevent parts of the Website from functioning properly.

F. Artificial Intelligence

The Application uses Artificial Intelligence (AI) technologies to provide personalized learning features, recommendations, summaries, feedback, recall practice, and automated functionality. AI components may process user-provided data, learning preferences, reading activity, recall answers, and related learning data to deliver these features. AI processing is performed in accordance with this Privacy Policy and applicable laws.

G. Personalized Ads

Witsy does not sell your personal data. If Witsy uses personalized advertising or advertising identifiers in the future, we will do so only where permitted by law and, where required, with your consent, including through Apple's App Tracking Transparency framework on iOS. You can manage personalized advertising through your device privacy settings.

If your device is iPhone or iPad, go to Settings, select Privacy & Security, then Apple Advertising, and deselect Personalized Ads where available. If you are using an Android device, go to Settings, Privacy, Ads and enable opt out of ads personalization where available.

2. Legal Bases for Processing (EEA-Based Users)

We process personal data based on consent, contract performance, legitimate interests, and compliance with legal obligations. For example, we process account and subscription data to provide the Services, technical data to keep the Services secure and functional, and learning preferences to personalize the experience you request.

3. Data Sharing

Your personal data will not be sold, traded, or otherwise transferred to third parties for commercial purposes. Your data may be transferred for the reasons explained below.

Service Providers: We may share your personal information with third-party service providers who use that information to help us provide the Services. This includes providers for hosting, authentication, database services, app infrastructure, subscription management, crash diagnostics, customer support, cloud services, and technical operations. Witsy currently uses service providers including Expo, Supabase, and RevenueCat.

AI and Content Processing Providers:We may use AI, cloud, and content-processing providers to generate summaries, recommendations, flashcards, feedback, recall experiences, and personalized learning paths. These providers process information as needed to deliver Witsy's learning features.

Business and Communication Partners: We may share limited personal information with providers that help us communicate with users, respond to support requests, or provide a product or service you have requested.

APIs/SDKs: We may use third-party application program interfaces (APIs) and software development kits (SDKs) as part of the functionality of the Services. You may contact us for further information.

Law Enforcement and Public Authorities:We may access, preserve, and disclose information associated with you to external parties if we, in good faith, believe doing so is required or appropriate to comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Please note that the Application utilizes third-party services that have their own privacy policies:

• Expo
• Supabase
• RevenueCat

4. Exercising Your Privacy Rights

You have rights to access, review, update, correct, delete, or restrict the use of your personal data. EEA-based users may have additional rights under the General Data Protection Regulation (GDPR), including:

• Right to Access: You can request access to your personal data.
• Right to Rectification: You can request correction of inaccurate or incomplete data.
• Right to Erasure: You can request deletion of your personal data.
• Right to Restrict Processing: You can request restriction of processing your data.
• Right to Data Portability: You can request transfer of your data to another service provider.
• Right to Object: You can object to processing based on legitimate interests or direct marketing.
• Right to Lodge a Complaint: You can lodge a complaint with a supervisory authority.

To exercise any of these rights or to delete your account, please contact us at info@getwitsy.co.

5. Age Limitation

We do not knowingly collect or process personal data from children under the age of 13. If you are a parent or legal guardian and believe that your child has provided personal data to us without your consent, please notify us immediately at info@getwitsy.co. We will promptly take steps to delete such data and prevent any further processing.

We recommend that parents and guardians actively supervise their children's online activities and use parental control tools available on devices and platforms to prevent unauthorized access to the Services.

6. International Data Transfers

Since the Services may rely on global infrastructure and third-party service providers, we may transfer personal data globally. Where required, we use appropriate safeguards such as Standard Contractual Clauses, adequacy decisions, or other lawful transfer mechanisms.

7. Changes to This Privacy Policy

We may update this Privacy Policy periodically. Significant changes may be communicated through the Services, on this page, or via email. We encourage you to review this policy regularly. Continued use of the Services after updates constitutes acceptance of the revised policy.

8. Supplemental Notice for California Residents

California residents may have rights under the CCPA/CPRA, including the right to know what personal information is collected, used, and disclosed, the right to request deletion or correction, and the right to opt out of certain sharing or sale of personal information where applicable. Witsy does not sell personal data.

9. Supplemental Notice for Virginia Residents

Virginia residents may have rights under the VCDPA, including accessing, correcting, and deleting personal data, obtaining a copy of personal data, and opting out of targeted advertising, sale of personal data, or profiling where applicable.

10. Account Deletion

You can delete your account by sending a request to info@getwitsy.co. If account deletion is available inside the Application, you may also use the in-app account deletion flow.

11. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, provide the Services, maintain security, resolve disputes, enforce agreements, and comply with legal obligations. Once the retention period has expired, we will take appropriate measures to securely delete, dispose of, or anonymize your data.

12. Personal Data Controller

Jan Hedwig is the controller of your personal data for Witsy. You can contact the controller at info@getwitsy.co.

13. Contact Us

For any questions about this Privacy Policy or your personal data, contact us at info@getwitsy.co.