Privacy Policy

This Privacy Policy governs your use of the Wittio (the "Website") and describes the data we collect, how it is stored, how it may be used, with whom it may be shared, and your choices regarding such uses and disclosures. Please read this Privacy Policy carefully before using our Website.

For the purposes of this Privacy Policy:

"GDPR" means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of personal data and on the free movement of such data.

"EEA" includes all current Member States of the European Union and the European Economic Area.

"Process", in respect of personal data, includes collecting, storing, using, and disclosing to others.

Capitalized terms not defined in this Privacy Policy have the meanings given to them in our Terms of Use & Service (the "Terms").

1. PERSONAL DATA CONTROLLER

Wittio, with registered office at Georgiou A, 83, Shop 17, Germasogeia, 4047, Limassol, Cyprus.

2. WHAT CATEGORIES OF PERSONAL DATA DO WE COLLECT?

We collect data you provide to us voluntarily (for example, your name, email address, and quiz responses) as well as data collected automatically when you use the Website (for example, your IP address and device type).

2.1 Data You Give Us

You provide us with data about yourself when you register for and use the Website — for example, when you create a profile, complete a quiz or assessment, respond to our communications, or contact our support team. The data you give us includes:

Profile data. This includes your name, email address, date of birth, and any other information you choose to provide when setting up your account.

Quiz and assessment responses. When you complete our cognitive tests, mind profile assessments, or any other self-discovery tests available on the Website (including but not limited to Archetype, Personality Type, ADHD Screening, Love Style, Career Fit, and Emotional Intelligence assessments), we collect your responses and the results generated from them.

Please note that all test results and assessments are generated for educational and entertainment purposes only and do not constitute a professional psychological, medical, or clinical evaluation of any kind.

2.2 Data We Collect Automatically

Data about how you found us. We collect information about the source that directed you to our Website, including referring URLs and advertising campaign identifiers (including data from Meta and Google advertising platforms).

Cookies and similar technologies. As described in our Cookie Policy, we use cookies and similar tracking technologies to distinguish you from other users and to improve your experience. You can manage your cookie preferences through your browser settings.

Device and browser data. We collect information about the devices and browsers you use to access our Website, including: language settings, IP address, approximate location, time zone, device type and model, operating system, and Internet service provider.

We may also collect your Apple Identifier for Advertising (IDFA) or Google Advertising ID (AAID), depending on your device. You can typically reset these identifiers through your device's operating system settings.

Transaction data. When you make payments through the Website, your financial details (such as credit card information) are processed directly by our third-party payment processors. We do not collect or store full payment card numbers. We may receive limited transaction-related data, such as the date, time, amount, and payment method type.

Usage data. We record how you interact with the Website, including the features, content, games, articles, and courses you access, how frequently and for how long you use the Service, and other engagement data.

3. FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA?

3.1 To Provide the Service to You

We use your data to operate and deliver the Website and its features — including cognitive tests and assessments, brain training games, articles, courses, and your personalized Mind Profile — and to authenticate your account and authorize access to the Service.

3.2 To Research and Analyze Your Use of the Website

We use data to better understand how users engage with our platform, maintain and improve existing features, develop new content and functionality, conduct internal research and testing, and optimize the overall user experience.

3.3 To Personalize Your Experience

We use your data — including your quiz responses and usage patterns — to tailor the content, recommendations, and training plans shown to you, and to determine your eligibility for promotions or special offers.

3.4 To Process Your Payments

We use your data to facilitate subscription purchases and renewals through our third-party payment processors. We do not directly handle or store full payment card data.

3.5 To Enforce Our Terms and Prevent Fraud

We use personal data to enforce our Terms of Use & Service, detect and prevent fraudulent or unauthorized activity, verify that users are genuine, and take legally required actions where necessary. This may involve sharing data with law enforcement agencies where required by law.

3.6 To Communicate With You About the Service

We may contact you via email, push notification, or directly within the Website regarding your account, activity, results, and platform updates.

3.7 To Send You Marketing Communications

We may add your email address to our marketing list and send you information about new features, offers, promotions, and other content that may be of interest to you. You may opt out of marketing emails at any time by clicking the unsubscribe link in any such email or by contacting us directly.

3.8 To Provide Customer Support

We use your data to respond to your support requests, resolve technical issues, and communicate important information about your subscription or account.

3.9 To Personalize Advertising

We and our advertising partners (including Meta and Google), and we may use your data to deliver relevant advertisements to you on our Website and on third-party platforms.

3.10 To Comply With Legal Obligations

We may process, use, or disclose your data where required by applicable law, including in response to requests from regulatory or law enforcement authorities.

4. LEGAL BASIS FOR DATA PROCESSING (EEA USERS ONLY)

This section applies only to users based in the EEA. We process your personal data on the following legal grounds:

4.1 Your Consent

We rely on your consent when we send optional marketing communications or use non-essential cookies and tracking technologies.

4.2 Performance of a Contract

We process your data as necessary to perform our contract with you, including to: provide the Service and all its features; process your payments; manage your account; and provide customer support.

4.3 Legitimate Interests

We rely on our legitimate interests (where not overridden by your rights and freedoms) to: analyze and improve the Website; communicate with you about the Service; send appropriately measured marketing communications; deliver reasonably targeted advertising; and enforce our Terms and prevent fraud.

4.4 Legal Obligations

We process certain data to comply with our legal obligations, including identity verification and record-keeping requirements.

5. CALIFORNIA PRIVACY RIGHTS

This section applies to residents of California, United States, and provides additional disclosures required under the California Consumer Privacy Act ("CCPA") and California's Shine the Light law.

We collect the categories of personal information described in Section 2 above, for the purposes described in Section 3. We do not sell personal information as that term is defined under the CCPA.

California residents have the right to: request access to the personal information we hold about them; request deletion of their personal information; opt out of any applicable "sale" of personal information; and not be discriminated against for exercising these rights.

To submit a request under the CCPA, please contact us at support@wittio.io. We will verify your identity before processing your request. You may also designate an authorized agent to submit requests on your behalf.

Shine the Light. California residents may request information once per year about any personal data we share with third parties for their direct marketing purposes. To make such a request, please email us at support@wittio.io with "Request for California Shine the Light Privacy Information" in the subject line, along with your state of residence and email address.

6. DATA RETENTION

We retain personal data for as long as necessary to fulfill the purposes described in this Privacy Policy, or as required by applicable law. Even if you close or delete your account, we may retain certain data to meet our legal, financial, and compliance obligations — including transaction records and fraud prevention data.

7. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

We share data with third parties who help us operate, deliver, improve, and promote the Service. We may share personal data with the following categories of recipients:

7.1 Service Providers

We share data with third-party service providers who perform functions on our behalf, including:

Cloud storage and infrastructure providers (e.g., Google Cloud Platform)
Data analytics providers (e.g., Google Analytics, Amplitude, Hotjar, Clarity)
Marketing and advertising partners (e.g., Meta Ads, Google Ads, Google Tag Manager)
Engineering and performance partners (e.g., Sentry, Cloudflare)
Customer support and communication tools (e.g., Zendesk, Customer.io)
Payment processing providers
Third-party game providers integrated into our brain training platform

7.2 Law Enforcement and Public Authorities

We may disclose personal data to courts, law enforcement agencies, regulators, or other public authorities where required by law or where necessary to protect our rights or the safety of our users or others.

7.3 Business Transfers

In the event of a merger, acquisition, sale of assets, or similar corporate transaction, personal data may be transferred as part of that transaction. We will notify affected users in accordance with applicable law.

8. INTERNATIONAL DATA TRANSFERS

We may transfer your personal data to countries outside the one in which it was originally collected to provide the Service. Where data originating from the EEA is transferred to countries that do not provide an equivalent level of data protection, we implement appropriate safeguards, including Standard Contractual Clauses approved by the European Commission or other lawful transfer mechanisms.

9. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. If we make material changes, we will notify you through the Website or by other appropriate means. Your continued use of the Website after such changes take effect constitutes your acceptance of the updated Privacy Policy.

10. AGE LIMITATION

We do not knowingly collect personal data from individuals under the age of 18. If you become aware that a person under 18 has provided us with personal data, please contact us at support@wittio.io, and we will take steps to delete such data promptly.

11. YOUR PRIVACY RIGHTS

You have the following rights in relation to your personal data:

Access, review, and correction. You may access and update your profile data at any time by logging into your account. You may also request a copy of your personal data by contacting us at support@wittio.io.

Deletion. You may request the erasure of your personal data by contacting us at support@wittio.io. We will honor your request to the extent permitted by law. In some cases, we may be required to retain certain data for a period of time before we can fulfill your deletion request.

Objection and restriction. You may ask us to stop processing all or some of your personal data, or to limit the purposes for which we use it, by contacting us at support@wittio.io.

Data portability. You may request a copy of your personal data in a structured, machine-readable format by contacting us at support@wittio.io.

Right to lodge a complaint. If you believe your data has been processed unlawfully, you have the right to lodge a complaint with the competent data protection supervisory authority in your country or EU Member State of residence.

You may exercise any of the above rights through an authorized agent, provided we can verify the identity of both you and your agent.

12. HOW DO WE HANDLE "DO NOT TRACK" REQUESTS?

Except as otherwise described in this Privacy Policy, our Website does not currently respond to "Do Not Track" browser signals. To understand how third-party services we use handle such signals, please refer to their respective privacy policies.

13. TRANSLATIONS

This Privacy Policy is provided in English. Any translation is for convenience only. In the event of any inconsistency between the English version and a translated version, the English version shall prevail.

14. CONTACT US

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

Email: support@wittio.io