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1. Introduction
Welcome to Sam The Wise ("we," "us," "our," or "the App"). We are committed to protecting your privacy and ensuring transparency about how we collect, use, and protect your personal information.
This Privacy Policy explains:
- What personal information we collect
- How we use your information
- Who we share your information with
- Your rights and choices
- How we protect your information
By using Sam The Wise, you agree to the collection and use of information in accordance with this Privacy Policy.
Important: You must be at least 16 years old to use Sam The Wise. If you are under 16, you may not create an account or use our services.
2. Data Controller Information
Name: Hanan Hebibovic (operating Sam The Wise as an individual)
Email: [email protected]
Location: Eching, Germany
Contact: For privacy inquiries, email us at [email protected]
As Sam The Wise is operated from Germany, German and EU data protection laws apply to our processing of your personal information.
3. Information We Collect
3.1 Information You Provide
Account Information:
- Email address (required for account creation and recovery)
- Username (unique identifier, publicly visible by default)
- Password (encrypted using bcrypt, never stored in plain text)
- Profile photo/avatar (optional, stored in Firebase Storage)
- Bio/description (optional)
- Date of birth (for age verification only, not displayed publicly)
Study Content:
- Decks (collections of study cards) you create
- Questions and answers you input or generate
- Files you upload (images, PDFs) for AI quiz generation
- Study session results and progress
- Spaced repetition review history
- Exam sessions and performance data
Device Permissions (iOS):
- Photo Library Access: To upload images from your photo library for quiz generation
- Camera Access (Optional): To take photos of notes directly for quiz generation
- File Access: To upload PDFs and documents
Note: Permissions can be managed in device settings (iOS: Settings > Sam The Wise > Photos/Camera)
3.2 Information Collected Automatically
Usage Data:
- Study session metrics (questions answered, accuracy, time spent)
- Feature usage and interaction patterns
- App performance and crash data (only if you consent)
- Spaced repetition review patterns
- Offline mode usage and sync events
4. How We Use Your Information
We use your information to:
- Provide the Service: Create your account, generate quizzes, track progress, schedule reviews
- Improve the Service: Analyze usage patterns, fix bugs, develop new features
- Communicate with You: Send important updates, respond to support requests
- Ensure Security: Detect fraud, prevent abuse, enforce Terms of Service
- Comply with Law: Fulfill legal obligations, respond to valid legal requests
5. AI Processing and Third-Party Services
5.1 AI Providers
We use third-party AI services to generate quiz questions:
- Anthropic Claude: Primary AI for quiz generation and AI Tutor feature
- OpenAI GPT-4: Fallback AI for quiz generation
Zero Data Retention Policy:
Both Anthropic and OpenAI have committed to Zero Data Retention for API usage:
- Your uploaded files are NOT used to train their AI models
- Your content is NOT stored by AI providers beyond processing time
- We have Data Processing Agreements with both providers
5.2 File Processing and Storage
- Files you upload for AI quiz generation are temporarily stored in Firebase Cloud Storage
- Files are automatically deleted after 30 days
- You can manually delete uploaded files anytime in Settings > Data Management
Do NOT upload:
- Medical records or health information
- Government-issued IDs or passports
- Financial documents (bank statements, tax returns)
- Any sensitive personal information of others
6. Data Sharing and Disclosure
We do NOT sell your personal information.
We may share your information with:
- Service Providers: Firebase (hosting), Stripe (payments), Anthropic/OpenAI (AI processing)
- Legal Requirements: If required by law or to protect rights and safety
- Business Transfers: In event of merger or acquisition (you will be notified)
We share anonymized, aggregated data for:
- Analytics and research
- Public statistics (e.g., "10,000 quizzes generated this month")
7. Your Rights (GDPR & German Law)
You have the right to:
- Access: Request a copy of your personal data
- Rectification: Correct inaccurate or incomplete data
- Erasure: Delete your account and personal data ("right to be forgotten")
- Data Portability: Export your data in machine-readable format (JSON)
- Object: Object to processing based on legitimate interests
- Restrict Processing: Limit how we use your data
- Withdraw Consent: Revoke consent for data processing (may limit functionality)
To exercise these rights:
- Email [email protected] with your request
- Use in-app tools: Settings > Data Management > Export Data / Delete Account
Response Time: We will respond within 30 days as required by GDPR.
Right to Lodge a Complaint: You have the right to lodge a complaint with your local data protection authority (in Germany: Bundesbeauftragter für den Datenschutz und die Informationsfreiheit).
8. Data Retention
| Data Type |
Retention Period |
| Account Information |
Until account deletion |
| Study Content (Decks, Questions) |
Until account deletion or manual deletion |
| Uploaded Files (Images, PDFs) |
30 days (automatic deletion) |
| Usage Analytics |
2 years (anonymized after 90 days) |
| Payment Records |
7 years (German tax law requirement) |
| Support Communications |
2 years |
9. Security Measures
We protect your data using:
- Encryption: All data transmitted via HTTPS/TLS, passwords encrypted with bcrypt
- Firebase Security Rules: Strict access control on database
- Regular Security Audits: Ongoing monitoring and updates
- Minimal Data Collection: We only collect what's necessary
No system is 100% secure. While we implement industry-standard security measures, we cannot guarantee absolute security. You are responsible for keeping your password secure.
10. Cookies and Tracking
We use minimal tracking:
- Essential Cookies: Required for authentication and app functionality
- Analytics: Firebase Analytics (can be disabled in Settings > Privacy)
- No Advertising Trackers: We do not use cookies for advertising
How to Control Cookies:
- iOS: Settings > Sam The Wise > Limit Ad Tracking
- In-App: Settings > Privacy > Analytics (toggle off)
11. Children's Privacy
Sam The Wise is NOT intended for children under 16.
We do not knowingly collect personal information from anyone under 16. If we discover a user is under 16, we will immediately delete their account and data.
Parents: If you believe your child has created an account, contact [email protected] immediately.
12. International Data Transfers
Sam The Wise is operated from Germany (EU). Your data is primarily stored in EU data centers (Firebase Europe West).
For AI processing, data may be transferred to:
- Anthropic (US): Claude API processing - covered by EU-US Data Privacy Framework
- OpenAI (US): GPT-4 API processing - covered by EU-US Data Privacy Framework
We ensure appropriate safeguards (Standard Contractual Clauses, Data Processing Agreements) are in place for all international transfers.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time.
How we notify you:
- Material Changes: Email notification + in-app notice 30 days before
- Minor Changes: Update "Last Updated" date at top
Continued use after changes means you accept the updated Privacy Policy.
14. Contact Us
For privacy questions or concerns:
Email: [email protected]
Subject line: "Privacy Inquiry"
We will respond within 30 days.