When you access our Website and/or the App we automatically collect from your device language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, Information about user's interactions, events and actions with the product and ad campaigns and other unique identifiers (such as IDFA, AAID, IDFV, UUID). We need this data to provide our services, analyze how our customers use the Website and/or the App and to serve ads.  

For improving the Website and/or the App and serving ads, we may share this data with third parties. Such parties include Amazon, Snapchat, Facebook, Tiktok,  Google, Amplitude,Tableau, Firebase, Hotjar, Zendesk, Solid, Reteno. As a result of sharing this data with third parties we (1) analyze different interactions (what products our users have viewed); (2) serve ads (and show them only to a particular group of users, for example, to those who have clicked on some category of the Website and/or the App).

Please read our Privacy Policy below to know more about what we do with data (Section 3), what data privacy rights are available to you (Section 6) and who will be the data controller (Section 1). 

If you are a California resident, please review our California Notice at Collection (Section 10) and see the applicable state-specific section below. If you reside in a state with a comprehensive U.S. privacy law (for example, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia), please also see Section 10 for information about your privacy rights under applicable state law.

If any questions remain unanswered, please contact us at support@wisey.app or app.support@wisey.app.

This Privacy Policy explains what personal data is collected when you use any  Wisey mobile application (the “App”) and/or the Wisey website (the “Website”), the services and products provided through it (together with the App and the Website, the “Service”), how such personal data will be processed.

BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU) AND (III) ACCEPT OUR DATA COLLECTION AND PROCESSING PRACTICES DESCRIBED BELOW. 

If you do not agree, or are unable to make this promise, you must not use the Service. In such a case, you must (a) contact us and request deletion of your data; and (b) delete the App from your device or leave the Website and not access or use it.

Any translation from the English version is provided for your convenience only. In the event of any difference in meaning or interpretation between the English language version of this Privacy Policy available at Privacy Policy, and any translation, the English language version will prevail. The original English text shall be the sole legally binding version.

“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 Free Trade Association. For the purpose of this policy EEA shall include the United Kingdom of Great Britain and Northern Ireland.

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

1. PERSONAL DATA CONTROLLER
2. CATEGORIES OF PERSONAL DATA WE COLLECT
3. FOR WHAT PURPOSES WE PROCESS PERSONAL DATA
4. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)
5. WITH WHOM WE SHARE YOUR PERSONAL DATA
6. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
7. AGE LIMITATION
8. INTERNATIONAL DATA TRANSFERS
9. CHANGES TO THIS PRIVACY POLICY
10. U.S. STATES  PRIVACY NOTICE
11. DATA RETENTION
12. CONTACT US

We collect data you give us voluntarily (for example, email address).  We also may receive data about you from third parties (for example, when you sign in via Google and/or Apple).  We also collect data automatically (for example, your IP address)

We process your personal data:

3.1. To provide our Service

This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.

To host personal data and enable our Service to operate and be distributed we use Amazon Web Services, which is a hosting and backend service provided by Amazon.

3.2. To provide you with customer support

We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. For this purpose, we may send you, for example, notifications or emails about the performance of our Service, security, payment transactions, notices regarding our Terms and Conditions of Use or this Privacy Policy.

3.3. To communicate with you regarding your use of our Service

We communicate with you, for example, by email. These may include for example, emails with information about the Service. To opt out of receiving emails, you need to follow the instructions in the footer of the emails.

We use Zendesk ticketing system to handle customer inquiries. When you send us inquiries via contact form or via email, we will store the details provided by you via Zendesk ticketing system, which enables us to track, prioritize and quickly resolve your requests. To learn more, please visit this Privacy Policy.

We use Reteno, a product of eSputnik, to manage and automate our customer communication across channels such as push notifications, in-app messages, and emails. This allows us to improve your user experience and keep you informed about relevant updates. To learn more, please visit eSputnik’s Policy.

3.4. To research and analyze your use of the Service

This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what categories of users use our Service. As a consequence, we often decide how to improve the  Service based on the results obtained from this processing.

3.5. To send you marketing communications

We process your personal data for our marketing campaigns. As a result, you will receive information about our products, such as, for example, special offers or new products available on our Service. We may show you advertisements on our Service, and send you emails for marketing purposes. To opt out of receiving marketing emails from us, you need to unsubscribe following instructions in the footer of the marketing emails.

3.6. To personalize our ads

We and our partners, including Facebook, Snapchat, Tiktok and Google, use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have accessed our Service, you might see ads of our products, for example, in your Facebook’s feed.

How to opt out or influence personalized advertising

iOS: On your iPhone or iPad, go to Settings > Privacy > Apple Advertising and deselect Personalized Ads.

Android: To opt-out of ads on an Android device, go to Settings > Privacy > Ads and enable Opt out of Ads personalization. In addition, you can reset your advertising identifier in the same section (this also may help you to see less personalized ads). To learn even more about how to affect advertising choices on various devices, please look at the information available here.

macOS: On your MacBook, you can disable personalized ads: go to System Preferences > Security & Privacy > Privacy, select Apple Advertising, and deselect Personalized Ads.

Windows: On your laptop running Windows 10, you shall select Start > Settings > Privacy and then turn off the setting for Let apps use advertising ID to make ads more interesting to you based on your app activity. If you have other Windows version, please follow the steps here.

To learn even more about how to affect advertising choices on various devices, please look at the information available here.

In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:

• • • Network Advertising Initiative – http://optout.networkadvertising.org
    • Digital Advertising Alliance – http://optout.aboutads.info
    • Digital Advertising Alliance (Canada) – http://youradchoices.ca/choices
    • Digital Advertising Alliance (EU) – http://www.youronlinechoices.com
    • DAA AppChoices page – http://www.aboutads.info/appchoices

Browsers: It is also possible to stop your browser from accepting cookies altogether by changing your browser’s cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser. The following links may be helpful, or you can use the “Help” option in your browser.

• • • Cookie settings in Internet Explorer
    • Cookie settings in Firefox
    • Cookie settings in Chrome
    • Cookie settings in Safari web and iOS
    • Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics

3.7. To process your payments

We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment, and we will be notified that the payment has been made.

We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors.

To enable purchases and to process your payments, we use Solid (Privacy Policy) as a payment processing provider.

3.8. To enforce our Terms and Conditions of Use and to prevent and combat fraud

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 our Terms and Conditions of Use).

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.

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 3. This section applies only to EEA-based users.

We process your personal data under the following legal bases:

4.1. your consent;

Under this legal basis we:

• • • • send you direct marketing communication.

4.2. to perform our contract with you;

Under this legal basis we:

• • • • Provide our Service (in accordance with our Terms and Conditions of Use)
      • Customize your experience
      • Provide you with customer support
      • Communicate with you regarding your use of our Service
      • 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 Service
        This includes, for example, sending you an email to notify you that we have released a new product or sending push notification reminding you that you have some products in your cart. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often.
      • to research and analyze your use of the Service
        Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the Website navigation easier and more user-friendly).
      • to personalize our ads
        The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.
      • to process your payments
        We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment for a certain product and we will be notified that the payment has been made. We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors.
      • to enforce our Terms and Conditions of Use and to prevent and combat fraud
        Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use.
      • to investigate and respond to any comments or complaints that you may send us.
      • In the event of a merger or acquisition of our business and/or all or any portion of its assets, your information may be disclosed to the prospective purchaser, our advisers, and any other prospective purchaser's advisers and will be one of the assets that is transferred to a new owner; and
      • in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of information in connection with government agency requests, legal process or litigation).

Where we process your information based on legitimate interests, you can object to this processing in certain circumstances. In such cases, we will cease processing information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. To exercise your right to object, please see Section 6 of this Privacy Policy.

4.4. to comply with legal obligations, including, but not limited to, responding to requests by government or law enforcement authorities conducting an investigation.

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 and with parties indicated in Section 3 of this Privacy Policy. The types of third parties we share information with include, in particular:

5.1. 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:

• • • cloud storage providers (Amazon)
    • data analytics providers (Facebook, Firebase, Amplitude, Hotjar, Tableau)
    • measurement partners
    • communication service providers (Zendesk, Reteno)
    • marketing partners (in particular, social media networks, marketing agencies, email delivery services; Facebook, Tiktok, Snapchat, Google)
    • payment service providers (Solid)

5.2. Law enforcement agencies and other public authorities

We may use and disclose personal data to enforce our Terms and Conditions of Use, 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.

5.3. 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.

5.4. Affiliates

We may share your personal information with our partner organizations that are part of our corporate group – these are companies that are owned by, own, or are jointly owned with us. These partner organizations will use the information in ways that align with this Privacy Policy.

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 while using our Service.

Deleting your personal data. You can request erasure of your personal data as permitted by law.

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 an 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.

Additional information for EEA-based users:

If you are based in the EEA, you have the following rights in addition to the above:

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 us as described below. 

To exercise any of your privacy rights, please send a request to support@wisey.app or app.support@wisey.app.

We do not knowingly process personal data from persons under 16 years of age. If you are under 16, do not use or provide any information to or on this Service  or through any of its features.

If you learn that anyone younger than 16 has provided us with personal data, please contact us and we will work to delete that information from our databases.

We are not liable for any damages that may result from a visitor’s misrepresentation of age.

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use 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, (ii) the European Commission adequacy decisions about certain countries (details available here), including to legal entities self-certified under EU-U.S. Data Privacy Framework (EU-U.S. DPF).

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

For a detailed summary of key updates, please refer to the Change Log available at CHANGE LOG — Updates to Our Terms of Service and Privacy Policy. It provides an overview of all recent modifications and helps you track updates over time.

Applicability

If you reside in a state that has enacted consumer privacy laws, this section applies to you. This U.S. States Privacy Notice (“Notice”) supplements our Privacy Policy and provides disclosures required by laws in states with a comprehensive U.S. privacy law, such as California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia.

This Notice is designed to supplement our Privacy Policy to ensure compliance with state-specific laws and applies to the collection, use, and sharing of your Personal Information through our websites, mobile applications, and other online or offline services (collectively, the “Services”).

For California residents, this also serves as our California Notice at Collection.

The definition of “Personal Information” may vary by state law. Generally, it refers to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

10.1. Categories of Personal Information We Collect and For What Purposes

The table below outlines the categories of Personal Information we collect, along with the purposes of such collection. For more details, refer to other sections of our Privacy Policy.

Category - Identifiers

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)

Examples of Personal Information in this Category - Name, email address, and answers to the quiz questions, including medical data.

Purpose of collection

• To provide and maintain our Services, including account creation, authentication, and access management.
• To improve user experience through personalized content, recommendations, and service customization.
• To serve and measure ads
• To communicate with users, including customer support, service updates, and promotional offers.

Category - Protected classification characteristics under California or federal law

Examples of Personal Information in this Category - Gender

Purpose of collection

• To provide and maintain our Services, including account creation, authentication, and access management.
• To conduct analytics and research for product development and service enhancements.

Category - Sensitive Information

Examples of Personal Information in this Category - When we process sensitive personal information (as defined by State Privacy Laws), such as account login credentials or credentials allowing access to an account, we do so only for legally permitted purposes and do not use such data to infer characteristics about you.

Purpose of collection

• To provide and maintain our Services, including account creation, authentication, and access management.
• To secure your account. 

Category - Commercial Information

Examples of Personal Information in this Category

• Purchase history 
• Content provided during your use of the Service 
• Any information you may share during conversations with our support agents, including your feedback, complaints, etc.

Purpose of collection

• To provide and maintain our Services, including account creation, authentication, and access management.
• To improve user experience through personalized content, recommendations, and service customization.
• To serve and measure ads.
• To process payments, subscriptions, and transactions
• To conduct analytics and research for product development and service enhancements.

Category - Geolocation

Examples of Personal Information in this Category - Internet protocol (IP) address, country, and/or region.

Purpose of collection

• To provide and maintain our Services, including account creation, authentication, and access management.
• To improve user experience through personalized content, recommendations, and service customization.

Category - Internet or other electronic network activity information

Examples of Personal Information in this Category - Information regarding a consumer’s interaction with an internet website, application or advertisement (Usage Data).

Purpose of collection

• To improve user experience through personalized content, recommendations, and service customization.
• To serve and measure ads.
• To process payments, subscriptions, and transactions.
• To conduct analytics and research for product development and service enhancements.

Category - Inferences drawn from any of the above information categories

Examples of Personal Information in this Category - We may collect data and draw inferences based on that data; however, these inferences are used solely to determine which features you use more or less and are not used to deduce other specific personal characteristics.

Purpose of collection

• To improve user experience through personalized content, recommendations, and service customization.

For additional details on the purposes of processing and third parties with whom data is shared for each specific purpose, please refer to Section 3 of this Privacy Policy.

We may also process de-identified data, ensuring it cannot reasonably be linked back to you. We commit to maintaining and using de-identified data responsibly and will not attempt to re-identify such data unless required to validate our de-identification measures.

10.2. What Personal Information We Share

Certain state privacy laws, such as those in California, require us to disclose the categories of Personal Information that we have shared with third parties for business purposes over the past 12 months. During this period, we have disclosed all categories of Personal Information outlined in the “Categories of Personal Information We Collect” section for business purposes. For example, we may share IP addresses and device identifiers with service providers that assist us with crash monitoring and reporting.

Some U.S. states grant residents the right to opt out of sharing their Personal Information with third parties in exchange for valuable consideration (which may be classified as a “sale” or “share” under state privacy laws, even if no monetary transaction occurs). If you reside in one of these states and would like to limit the disclosure of your Personal Information to third parties for advertising or marketing purposes, please refer to  Section 10.4. below.

For details regarding the categories of third parties with whom we share Personal Information, please refer to  Section 3 and Section 5 of this Privacy Policy.

10.3. Your Privacy Rights Under State Laws

Certain U.S. state privacy laws grant residents specific rights regarding their personal information. If you reside in a state with such laws, you may have the following rights:

Your Right - Right to Know 

Description - You may be entitled to receive information regarding the categories of Personal Information we collected, the sources from which we collected Personal Information, the purposes for which we collected and shared Personal Information, the categories of Personal Information that we sold and the categories of third parties to whom the Personal Information was sold, and the categories of Personal Information that we disclosed for business purposes in the 12 months preceding your request.

Your Right - Right to Access

Description - You have the right to request access to the specific pieces of personal information we have collected about you in the 12 months preceding your request. 

Your Right - Right to Delete

Description - You have the right to request that we delete the personal information we have collected from you. We will use commercially reasonable efforts to fulfill your request, subject to applicable laws. However, we may be required to retain certain information for legitimate business purposes or as required by law.

Your Right - Right to Correct

Description - You have the right to request that we correct inaccurate personal information we maintain about you.

Your Right - Right to Opt-Out of Sales, Sharing, and Targeted Advertising

Description - You may have the right to opt out of certain uses of your personal information, including:

• The “sale” or “sharing” of your personal information as defined under state privacy laws.
• The use of your personal information for targeted advertising.

Your Right - Right to Data Portability

Description - You can request a copy of your personal data in a structured, portable format.

Your Right - Right to Non-Discrimination

Description - You have the right to exercise your privacy rights without fear of discrimination.

Your Right - Right to Withdraw Consent

Description - Where applicable, you have the right to withdraw your consent for data collection and sharing.

Your Right - Right to Limit the Use of Sensitive Personal Information

Description - Certain states provide the right to restrict how businesses use sensitive personal information. In order to opt-out, please contact us at support@wisey.app or app.support@wisey.app with the subject line “Limit the Use of Sensitive Personal Information.” We will process such requests in accordance with applicable laws.

To exercise any of these rights, submit a request to our customer support team via email:

📧 support@wisey.app or app.support@wisey.app

Verification

To ensure that we properly handle the requests you make regarding your rights, we are required to verify those requests. Depending on the type of request, this may include your email, date of subscription purchase, date of last activity, date of account creation or some other Service use data that will reasonably identify you as an owner of the account. We may also ask you for additional proof of identity, if necessary.

Right to Appeal

If we deny your request, you may have the right to appeal our decision. To do so, please contact us and explain your concerns. If you are dissatisfied with the result of the appeal, you may escalate the matter by contacting the Attorney General’s office in your state of residence.

Authorized Agents

If you are an authorized agent acting on behalf of a consumer, you may submit an opt-out, access, deletion, or correction request by contacting us. If you are making a request on behalf of a California resident, you may be required to submit proof of authorization, such as:

• A valid power of attorney
• Written permission signed by the consumer, along with identity verification from the consumer

California “Shine the Light” Law

California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties’ direct marketing purposes. Learn more about what is considered to be personal information under the statute.

To obtain this information from us, please send an email message to support@wisey.app or app.support@wisey.app, which includes “Request for California Privacy Information” on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.

Retention of Personal Information

We retain the categories of personal information listed above as reasonably necessary to fulfill the purposes outlined in this notice, unless a longer retention period is required or permitted by law. In many situations, we must retain all, or a portion, of your personal information to comply with legal obligations, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, or illegal activity, or for another one of our business purposes.

10.4. Sales, Sharing, and Targeted Advertising

Privacy laws in some U.S. states broadly define the term “sale” to include the sharing of information via cookies, pixels, and similar tracking technologies for certain targeted advertising activities. We do not sell Personal Information for monetary compensation. However, when you visit our websites, we and our advertising partners may collect device data and behavioural insights through tracking technologies, which could be interpreted as a “sale” or “sharing” under state laws, even if no money is exchanged.

We do not knowingly engage in sales, sharing, or targeted advertising using the personal information of individuals under 18.

More information about our data-sharing practices is available in the table below.

Category of Personal Information Disclosed

• Identifiers (such as pseudonymous cookie IDs, IP address, or if you have an account, a hashed version of your email address).
• Internet or other electronic network activity information (such as links you click or pages you visit on our website or your interactions with the Service).
• Commercial information (such as whether you bought a subscription).

Category of Third-Party Recipient

• Advertising networks. 
• Social networks.

Opt-Out Rights

You may opt out of sales, sharing, or targeted advertising by contacting us at support@wisey.app or app.support@wisey.app.

Your opt-out settings apply per device and browser. If you switch devices, clear cookies, or use a different browser, you may need to reapply your opt-out settings.

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you, complying with our legal obligations, and enforcing Terms of Use and our other agreements). For example, to prevent abuse of trials, introductory offers, or discounts, we will retain records that you have previously initiated such trials as long as these offers remain available in our Service.

Please note that personal information may be retained for longer if it becomes the subject of a legal claim or is somehow relevant for litigation or other proceedings.

You may contact us at any time for details regarding this Privacy Policy and its previous versions. 

For any questions concerning your account or your personal data please contact us at support@wisey.app or app.support@wisey.app.

Effective as of: 12 June 2025