Effective Date: April 21, 2024
Last Updated: April 21, 2024

This Privacy Policy describes how Wisely (“Application”, “App”, “we”, “us”, or “our”) collects, uses, and shares your personal data when you use our mobile application and related services (together, the “Services”).

By using the Services, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree, please do not use the App.

1. Categories of Personal Data We Collect

We collect the following types of data:

a. Data You Provide Voluntarily

• Name (optional)
• Email address (for login, syncing, and communication)
• Reading preferences and goals
• Feedback and support messages

b. Data Collected Automatically

• Device and app usage data (e.g., app screens viewed, session time)
• IP address
• Language settings
• Device type and OS version
• Mobile carrier and Internet service provider
• Unique device identifiers (IDFA for iOS, AAID for Android)
• Crash logs and diagnostics

c. Data from Third Parties

• Social login services (e.g., Apple, Google)
• Attribution data from ad platforms (e.g., Facebook, Adjust)

We do not collect or store any payment information directly. All purchases are handled by the App Store and tracked via RevenueCat.

2. How We Use Your Data

We use your personal data for the following purposes:

• To provide and operate the App and its features
• To manage subscriptions and unlock premium content (via RevenueCat)
• To personalize book recommendations and user experience
• To send motivational reminders and educational nudges (via push notifications or email)
• To analyze usage patterns and improve our product (via Firebase, Amplitude)
• To serve personalized ads (if applicable and consented)
• To prevent fraud and ensure app security
• To comply with legal obligations

3. Legal Basis for Processing (EEA Users)

For users in the European Economic Area (EEA), we process your data under the following legal bases:

• Your consent (e.g., email marketing, personalized ads)
• Contractual necessity (e.g., access to subscription content)
• Legitimate interests (e.g., improving services, in-app messaging)
• Legal obligations (e.g., fraud prevention, regulatory compliance)

4. Sharing Your Data

We may share your data with trusted third-party service providers for specific purposes:

Partner	Purpose
RevenueCat	Subscription tracking and entitlement management
Firebase (Google)	Analytics, crash reporting, push notifications
Amplitude	Product analytics and feature usage tracking
Adjust	Attribution and install tracking
Facebook SDK	Ad performance measurement and audience targeting
Apple / Google	Payment processing (App Store / Play Store)
Zendesk / Iterable	Customer support and communication

These partners process data on our behalf according to strict data protection agreements.

We may also disclose your data:

• To comply with legal obligations or law enforcement
• To prevent fraud or abuse
• In the event of a merger, acquisition, or sale of assets

5. Your Privacy Rights

You have the right to:

• Access, update, or delete your personal data
• Request data portability (in machine-readable format)
• Withdraw consent for marketing or tracking
• Object to or restrict certain types of processing
• Delete your account and all associated data

To exercise any of these rights, contact us at: 📧 [email protected]

6. Personalized Advertising & Tracking

We may use your data (e.g., IDFA, app usage) for personalized advertising. This includes showing relevant ads on platforms like Facebook, Google, or TikTok.

You can opt out of personalized ads:

• iOS: Settings > Privacy > Apple Advertising > Turn off Personalized Ads
• Android: Settings > Privacy > Ads > Opt out of Ads Personalization

Note: We comply with Apple’s App Tracking Transparency (ATT) framework and request permission before using the IDFA.

7. Opt-Out Options

You can opt out of:

• 📧 Marketing emails: Click “Unsubscribe” at the bottom of any email
• 🔔 Push notifications: Disable in your device settings
• 📊 Analytics & tracking: Use in-app privacy settings (if available) or contact us

8. Data Retention

We retain your data:

• As long as your account is active
• As required to provide the Services
• As needed to comply with legal obligations or resolve disputes

Once you delete your account or request deletion, we will remove your personal data within 30 days, unless a longer retention period is required by law.

9. Children’s Privacy

Wisely is not intended for children under 13 (or 16 in the EU). We do not knowingly collect data from children. If we become aware that we have collected personal data from a child, we will take steps to delete it immediately.

If you are a parent or guardian and believe your child has provided us with data, contact us at [email protected].

10. International Data Transfers

We may transfer your data to countries outside your jurisdiction (e.g., the United States) where data protection laws may differ. When we do, we use appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission.

11. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you via the App or email. Continued use of the App after updates means you accept the revised policy.

12. Contact Us

For any questions or requests regarding your privacy, please contact us:

📧 Email: [email protected]
🌐 Website: https://growthwise.app

Last Update: 20 April 2025