Privacy Policy

Last updated: August 11, 2026

1. Data Controller and Contact

The data controller responsible for data processing is:

Raslan Ismail

Bürgermeister-Kürten-Straße 38, 28779 Bremen

Phone: 015780914756

Email: raslan.ismail.business@gmail.com

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 non-personalized advertising and recording privacy 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 and the User Messaging Platform; 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 to display ads. The app requests non-personalized ads only and does not request permission to track you across other companies' apps or websites. Non-personalized ads are selected using contextual information rather than a profile of your past behavior.

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.

7. Storage, Retention, and Account Deletion

We retain account and learning data while your account is active and as needed to provide the service. Security and diagnostic records are retained only as long as reasonably necessary for their purpose. We may retain limited information longer where required by law or necessary to establish, exercise, or defend legal claims.

You can permanently delete your Witty account from the app under Profile > Delete account or submit a request through our account deletion page. This deletes the account and associated personal data from our active systems, except information that we are legally required to retain. Data controlled independently by Google or Apple must be managed through the privacy controls of those providers.

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.