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Privacy Policy

Sam The Wise

Last Updated: December 11, 2025

Effective Date: December 11, 2025

Version: 1.0

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:

Study Content:

Device Permissions (iOS):

Note: Permissions can be managed in device settings (iOS: Settings > Sam The Wise > Photos/Camera)

3.2 Information Collected Automatically

Usage Data:

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:

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

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:

We share anonymized, aggregated data for:

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:

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:

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:

How to Control Cookies:

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:

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:

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.