Privacy Policy

1. Data Controller and Contact

The data controller responsible for data processing is:

2. Scope and Data We Process

You can use parts of Witty as a guest. If you create or use an account, or use features that connect to our servers, we may process:

• Account and profile data, such as email address, username, display name, profile image, language level, and the account provider you choose
• Authentication credentials from Google Sign-In or Sign in with Apple that are required to verify your identity; Apple may provide a private relay email address if you choose to hide your email
• Learning data, such as saved flashcards, dialogues, stories, ratings, preferences, and learning progress
• Technical and security data, such as IP address, device and app information, request timestamps, and diagnostic or error information
• Advertising and consent data described in Section 6

3. Purposes of Data Processing

Data processing is carried out for the following purposes:

• Providing guest access and secure authentication through email, Google Sign-In, or Sign in with Apple
• Managing accounts and profiles
• Saving and restoring learning content, preferences, and progress
• Serving advertising in accordance with your privacy choices and recording those choices
• Preventing abuse, diagnosing faults, and maintaining the security and reliability of the app and its services

4. Legal Basis

Processing is based on the following legal grounds:

• Your consent, including advertising and privacy choices (Art. 6 para. 1 lit. a GDPR)
• Performance of our agreement with you when we provide an account and app features (Art. 6 para. 1 lit. b GDPR)
• Our legitimate interests in security, fraud prevention, reliability, and service improvement (Art. 6 para. 1 lit. f GDPR)
• Compliance with legal obligations where applicable (Art. 6 para. 1 lit. c GDPR)

5. Service Providers and Data Sharing

We share data only when needed to provide the app, comply with law, protect our services, or honor your choices. Our providers include Google for Google Sign-In, Google AdMob, the User Messaging Platform, Google Analytics for Firebase and Firebase Remote Config; Apple for Sign in with Apple; and infrastructure providers that host and secure our app services. We require providers acting on our behalf to protect personal data consistently with this policy and applicable law. Their own privacy terms also apply, including the Google Privacy Policy and Apple Privacy Policy. Data may be processed outside your country, subject to appropriate legal safeguards where required. We do not sell personal data.

6. Advertising and Privacy Choices

Witty uses Google AdMob for native ads in discovery screens, banners on selected browsing and practice screens, interstitial ads at practice completion points, and optional rewarded ads. The story reader, saved-card practice and due reviews remain ad-free in the revised version. Depending on your app version, consent choices and applicable platform permissions, ads may be personalized, non-personalized, limited, or unavailable. Where required, we request your consent before advertising processing. On iOS, tracking across other companies’ apps or websites requires Apple’s tracking permission. Refusing consent or tracking permission does not block access to learning content. Earlier app versions may continue to request only non-personalized ads.

Google and participating advertising providers may still process technical information such as IP address, coarse location derived from IP, device or app information, mobile advertising identifiers where available and permitted, ad interactions, and diagnostic data for ad delivery, frequency capping, aggregated reporting, security, and fraud prevention.

Where required, Google's User Messaging Platform asks for your consent or opt-out choice before ads are requested. You can review or change an available choice later under Profile > Ad privacy choices. If consent is required and the app cannot establish that ads may be requested, Witty does not load ads.

Optional Analytics and Remote Configuration

If you separately opt in to analytics, Witty uses Google Analytics for Firebase to measure app usage, learning engagement, and advertising performance. Events may include screen categories, engaged foreground time, ad placement and format, practice checkpoints, eligible or skipped ad opportunities, loading errors, impressions, reward completion, and ad value/currency, together with the technical app, device and installation information processed by the SDK. We do not send your account details, lesson text, or search text in these events and do not use learning events for advertising audiences.

Analytics collection is disabled until you opt in. You can decline or withdraw this separate choice in Profile using “Help improve Witty”. Withdrawal stops future analytics collection; it does not automatically erase information already processed. Contact us about access or deletion requests. Your analytics choice does not grant advertising or tracking consent.

Firebase Remote Config delivers operational settings, including advertising limits and disablement, using technical app and installation information. Witty can use cached settings when offline. Remote settings cannot remove consent requirements or restrict access to free learning content.

Session limits, local practice-time counters, completed-dialogue identifiers used to prevent repeat ad opportunities, a random rollout bucket, and short ad-free rewards are stored on your device. These local advertising controls operate independently of your analytics choice. In Witty version 1.5.0 and later, an optional completed rewarded ad grants 10 minutes without ads on that device. Earlier versions offer 30 minutes. The offer shows the duration before you choose to watch, and rewards already earned keep their original expiry. This reward is stored locally, has no monetary value, and does not synchronize through your Witty account. Operating-system backup or device-transfer features may restore local preferences, including rewards. Learning does not require watching an ad. Clearing app data or reinstalling may remove local preferences and rewards.

8. Your Rights

Depending on your location, you may have rights to access, correct, delete, restrict, or receive a copy of your personal data, and to object to processing or withdraw consent. Withdrawing consent does not affect processing that was lawful before withdrawal. To exercise your rights, use the in-app controls or contact us using the details in Section 1. You may also lodge a complaint with your local data-protection authority.

9. Data Security

We use appropriate technical and organizational measures designed to protect personal data against unauthorized access, loss, alteration, or misuse. No method of transmission or storage can be guaranteed to be completely secure.

10. Children

Witty is not directed to children and we do not knowingly collect personal data from children who are below the minimum age required to consent to data processing in their country. If you believe a child has provided personal data, please contact us so we can take appropriate action.

11. Changes to This Privacy Policy

We may update this policy when the app, our providers, or legal requirements change. We will update the date above and provide additional notice in the app or by email when appropriate.