Effective Date: 21/05/2025
Last Updated: 28/05/2025
1. INTRODUCTION
Welcome to Watosay (the "App"), a mobile application operated by Immediate Transformation Academy, a company registered in France and located at 6 rue d'Armaille, Paris 17, France ("Company," "we," "us," or "our").
This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you access or use the App. It also describes your rights and choices under applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 ("GDPR").
By using the App, you acknowledge that you have read and understood this Privacy Policy and agree to the data practices described herein. This Privacy Policy should be read in conjunction with our Terms of Service, which govern your use of the App and outline your responsibilities, including with respect to content you upload (e.g., screenshots of conversations).
User Responsibility Warning
You are solely responsible for ensuring that you have a lawful basis to upload any content to the App, including content that contains personal data of third parties. Do not upload sensitive or third-party information without appropriate legal consent. Misuse of the App in this regard may result in account suspension or legal liability. See Section 4 for more details.
If you have any questions about this Privacy Policy or our data practices, please contact us at [email protected].
If you do not agree with this Privacy Policy or our Terms of Service, please do not use the App.
What We Don't Do
• We do not sell or rent your personal data
• We do not display third-party ads
• We do not track you across other apps or websites without explicit consent
• We do not profile you for marketing purposes without explicit consent
• We do not use your content for AI training without explicit consent
• We do not access your photo library, contacts, or location without permission
2. INFORMATION WE COLLECT
We collect the following categories of personal data to operate, personalize, and improve the App:
A. Information You Provide Directly
Screenshots
You may choose to upload screenshots containing conversations or other content. These images may include personal data relating to both yourself and third parties (e.g., individuals appearing in chat messages).
Important: You are solely responsible for ensuring that you have a lawful basis to upload such content, including obtaining any required consent from third parties whose personal data may appear. Uploading data without proper authorization may violate applicable privacy laws and could result in suspension of your account under our Terms of Service.
User Inputs
When using the App, you may provide contextual details (e.g., conversation goals, tone preferences, or additional clarifying information) to help generate more relevant AI suggestions.
Contact Information
If you contact us (e.g., via email or in-app support), we collect your name, email address, and any additional information you provide in your message or support request.
B. Information Collected Automatically
Device & Usage Data
We automatically collect certain technical information from your device and your interactions with the App, including:
• Device type and model, operating system, and anonymized device identifiers (e.g., IDFV)
• IP address (used for approximate geolocation and security measures)
• Feature usage and session metrics (e.g., which screens or tools you interact with)
Crash reports and performance data
This data may be collected directly or through analytics services such as Firebase Analytics and Mixpanel. We apply data minimization techniques and, where appropriate, pseudonymization to reduce privacy risk.
EU Users - Tracking Notice: Where legally required (e.g., under the ePrivacy Directive), we request your consent before collecting or accessing information from your device. You may manage your preferences in your device settings.
Subscription Information
We collect technical and status-related information required to manage your in-app purchases, including:
• Anonymized device identifiers
• Subscription tier and renewal status
• Metadata provided by platforms such as RevenueCat, Firebase, and the App Store or Google Play
This information allows us to verify your subscription and ensure continued access to paid features.
C. Payment Data
We do not collect or store your full payment card numbers, billing addresses, or financial credentials. All payments are processed through trusted external platforms:
• Apple App Store (Apple Inc.)
• Google Play Store (Google LLC)
We may receive limited payment metadata from these providers, such as:
• Transaction IDs Subscription activation or renewal status
• Payment success or error notifications
This data is used solely for subscription fulfillment and customer support.
For further details, please refer to Apple's Privacy Policy and Google's Privacy Policy.
3. HOW WE USE YOUR INFORMATION & LEGAL BASIS (GDPR)
We process your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"). Each processing activity is based on one or more legal bases under Article 6(1) of the GDPR, as outlined below:
To Provide the Core Service (AI Suggestions)
• Data Used: Screenshots, extracted text, user inputs
• Purpose: Analyze conversation context to generate personalized, AI-powered message suggestions
• Legal Basis: Performance of Contract (Art. 6(1)(b)) - Necessary to deliver the service functionality requested by the user
Important: Users must ensure they have a lawful basis to upload any personal data involving third parties. The controller disclaims liability for user-submitted data uploaded without appropriate consent or legal justification. See Section 4 and our Terms of Service for more.
• Disclaimer Regarding AI Suggestions: Our AI-generated suggestions are based on your inputs, uploaded content, and extracted context. While we use reputable providers and continuously improve the quality of our service, the outputs are automatically generated and may occasionally include content that is inaccurate, inappropriate, biased, or otherwise unsuitable for your situation.
We do not manually monitor or moderate every AI response. You are solely responsible for reviewing and using the suggestions appropriately. If in doubt, please exercise personal judgment and refrain from using any output that may be offensive, misleading, or harmful. The AI is intended to support, not replace, your own thinking or decision-making.
Automated Decision-Making Notice (GDPR Article 22): The App does not make automated decisions that produce legal or similarly significant effects as defined under Article 22 of the GDPR. All AI-generated suggestions are non-binding and intended to support, not replace, your personal judgment.
To Maintain Conversation Context & History
• Data Used: Extracted text (pseudonymized), AI suggestions, stored screenshots
• Purpose: Allow users to access historical conversations and maintain context continuity
• Legal Basis: Performance of Contract (Art. 6(1)(b)) - Legitimate Interest (Art. 6(1)(f)) - To improve user experience and usability
• Safeguards: Users may delete their conversation history at any time via app settings. A Legitimate Interest Assessment (LIA) supports this processing, based on data minimization, user control, and pseudonymization. A Legitimate Interest Assessment supports this processing, based on data minimization, user control, and pseudonymization. Third-party data is processed only when uploaded voluntarily by the user and may be removed at any time.
To Improve AI Model Performance (Training)
• Data Used: Screenshots and/or extracted text (not anonymized by default unless specified)
• Purpose: Improve the performance, relevance, and safety of AI-generated suggestions through periodic model updates
• Legal Basis: Explicit Consent (Art. 6(1)(a)) - Required prior to using any content for training purposes
• Consent Mechanism: EU Users: Explicit opt-in via a default-off toggle in app settings
• Other Regions: May use opt-out (default-on) only where legally permitted
• Data Retention: Data is used only for the duration of the training cycle (maximum 12 months). Deleted or anonymized upon withdrawal of consent or at end of cycle.
To Manage Subscriptions & Orders
• Data Used: Subscription metadata, payment status (via App Store / Play Store)
• Purpose: Process user purchases, renewals, and manage billing
• Legal Basis: Performance of Contract (Art. 6(1)(b))
To Provide Customer Support
• Data Used: Contact information, device and usage data
• Purpose: Assist users with technical issues, account management, or general inquiries
• Legal Basis: Performance of Contract (Art. 6(1)(b)) - Legitimate Interest (Art. 6(1)(f)) - Ensures high-quality user experience
• LIA Justification: Processing is low risk, limited in scope, and directly benefits users. A Legitimate Interest Assessment confirms that this processing is proportionate, limited in scope, and directly beneficial to the user. Support interactions are initiated by the user and not used for profiling or marketing.
To Ensure Security & Prevent Fraud
• Data Used: Device data, subscription activity, usage behavior
• Purpose: Detect and prevent unauthorized access, security threats, or fraud
• Legal Basis: Legitimate Interest (Art. 6(1)(f)) - Safeguarding users and the platform - Legal Obligation (Art. 6(1)(c)) - Compliance with security, consumer protection, or fraud prevention regulations. This processing is supported by both a Legitimate Interest Assessment and legal obligations under applicable fraud prevention and cybersecurity regulations. Only behavioral and device-level signals are used.
To Analyze Usage Trends & Improve the App
• Data Used: Anonymized or aggregated usage data (e.g., via Mixpanel, Firebase)
• Purpose: Understand user behavior, identify trends, and improve features
• Legal Basis: Legitimate Interest (Art. 6(1)(f))
• Safeguards: Data is anonymized or aggregated where possible. LIA confirms minimal risk and strong user protections. A Legitimate Interest Assessment supports this processing based on the use of aggregated or anonymized data, low privacy impact, and clear user-facing benefits for app performance and experience.
To Comply with Legal Obligations
• Data Used: Account records, consent logs, communications, invoices
• Purpose: Fulfill legal duties such as tax reporting, record-keeping, and responding to lawful requests
• Legal Basis: Legal Obligation (Art. 6(1)(c))
In-App Privacy Controls
Users can manage their privacy preferences at any time via the App's in-app settings.
Available controls include:
• Enabling/disabling AI training participation
• Managing analytics and tracking preferences
• Deleting saved conversation history
Other Processing Activities
We may process your personal data for additional purposes that are compatible with those above or legally permitted under applicable laws. Where a new purpose arises that requires a different legal basis, we will inform you and, where necessary, seek your consent.
4. PROCESSING OF USER-UPLOADED CONTENT (SCREENSHOTS/TEXT)
As part of the Service, we process content that you voluntarily upload, including but not limited to screenshots and manually submitted text that may contain private conversations or messages.
Role of the App under GDPR
For the purposes of data protection laws such as the General Data Protection Regulation (GDPR), we act as a data controller with respect to the processing of personal data required to operate and deliver our core services (e.g., generating AI suggestions, maintaining conversation history).
However, for user-submitted content such as uploaded screenshots or manually entered text, we act as a joint controller or, where applicable, as a data processor on behalf of the user, who remains primarily responsible for the legality of the content uploaded.
You acknowledge and agree that by uploading such content, you are authorizing us to process it in accordance with this Privacy Policy and applicable data protection laws.
This processing is essential to enable core functionality, such as:
• Contextual analysis and message suggestion generation
• Optional features like chat history and conversation tracking
Processing may involve automated systems and third-party AI providers, acting as our data processors. Where legally permissible and subject to a valid legal basis, including your explicit consent, as detailed in Section 3, we may also use portions of this content, in pseudonymized or aggregated form, for the purpose of improving model performance and enhancing our services.
USER RESPONSIBILITY FOR UPLOADED CONTENT
By uploading any content to the App, you expressly acknowledge and agree to the following:
• You are solely and fully responsible for the legality of the content you submit, including any personal data or sensitive data relating to third parties (e.g., individuals involved in a conversation).
• You represent and warrant that you have obtained all necessary rights, permissions, and legal bases, including freely given, specific, informed, and unambiguous consent, where required to submit such content for processing under applicable laws.
• You must not upload any content containing third-party personal data unless a valid legal basis exists under applicable data protection laws, including but not limited to Regulation (EU) 2016/679 (GDPR) and the ePrivacy Directive.
• We do not actively monitor, validate, or vet user-submitted content. Accordingly, we disclaim all liability for any unlawful or unauthorized processing of personal data resulting from user uploads.
Any misuse of the Service in a way that violates data protection law, our Terms of Service, or the rights of others may result in:
• Immediate suspension or termination of your account
• Notification to the relevant supervisory authorities
You remain solely responsible for ensuring the legality of the content you upload. Use of the App in violation of this section may expose you to legal liability under national and international laws.
5. DATA SHARING AND DISCLOSURE
We do not sell your personal data.
However, we may share your information with trusted third parties in the following limited circumstances:
A. Service Providers and Data Processors
We engage third-party service providers to assist in delivering, securing, and improving the App.
These providers process personal data on our behalf, under written contracts and subject to strict confidentiality and data protection obligations.
Categories include:
• AI Processing
• Cloud Hosting & Infrastructure (AWS)
• Customer Support Platform
Analytics & Usage Monitoring
Mixpanel & Firebase (by Google LLC) - Usage and crash analytics, session performance.
Subscription & Payment Management
• Apple App Store (Apple Inc.)
• Google Play Store (Google LLC)
These platforms handle all in-app purchase processing and share limited payment metadata with us (e.g., transaction status, IDs).
RevenueCat used to manage subscription validation and entitlements. Shares anonymized billing metadata to confirm access rights. Does not store full payment details.
Data Processing Agreements & International Safeguards
We maintain up-to-date Data Processing Agreements (DPAs) with all third-party service providers who process personal data on our behalf, in accordance with Article 28 of the GDPR.
For international data transfers outside the European Economic Area (EEA), including transfers to the United States, we implement Standard Contractual Clauses (SCCs) approved by the European Commission and apply supplementary technical and organizational measures where necessary. These contracts ensure that your personal data receives a level of protection essentially equivalent to that guaranteed within the EU.
If you would like more information about our data protection safeguards, you may contact us at [email protected].
B. Legal Obligations
We may disclose personal data where required to do so by law, subpoena, legal process, or governmental request, such as for:
• Compliance with tax, accounting, or regulatory obligations
• Protection of legal rights, safety, and property (ours, yours, or others')
• Responding to law enforcement or data protection authorities
C. Business Transfers
In the event of a merger, acquisition, financing, sale of assets, reorganization, or bankruptcy, your personal data may be disclosed or transferred as part of the transaction. We will notify users where legally required.
We take care to ensure that any third parties who receive your data provide an equivalent level of data protection and only process your personal data as instructed, in compliance with applicable law.
6. INTERNATIONAL DATA TRANSFERS
Your information, including Personal Data, is primarily stored and processed on servers located within the European Union, specifically in the AWS (Amazon Web Services) data center.
However, in certain circumstances, your personal data may be transferred to, or made accessible by, service providers located outside the European Economic Area (EEA), including countries that may not provide an equivalent level of data protection as required by EU law, most notably, the United States.
How We Protect Your Data During International Transfers
Whenever your personal data is transferred outside the EEA, we ensure that adequate safeguards are implemented to maintain an equivalent level of protection in line with Article 46 of the GDPR:
Standard Contractual Clauses (SCCs)
Transfers are conducted pursuant to the European Commission's approved SCCs, which are incorporated into our contracts with service providers. These include supplementary technical and organizational measures where necessary.
Due Diligence on Processors
We only engage with third-party processors who commit to processing personal data in compliance with the GDPR and have passed internal and external data protection assessments.
Transfer Impact Assessments (TIAs)
Where required, we assess the laws and practices of the recipient country and their potential impact on data subjects' rights, consistent with the European Data Protection Board (EDPB) recommendations following the Schrems II decision.
By using the App, you acknowledge that such international transfers may occur and that appropriate protection measures are in place.
In jurisdictions where it is required by law (such as the European Economic Area), we request your explicit consent before using non-essential tracking technologies. You can manage your preferences through in-app settings or device-level privacy controls.
We do not track your activity across third-party websites or apps, and we do not use third-party advertising networks.
If you would like more information about the safeguards we apply or a copy of the relevant Standard Contractual Clauses, please contact us at [email protected].
7. DATA RETENTION
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, in accordance with the principle of storage limitation under Article 5(1)(e) of the GDPR and in line with applicable French commercial and tax laws.
Retention periods vary based on the type of data, purpose of processing, and relevant legal obligations, as described below:
Conversation History Data
• Purpose: User access to previous conversations and continuity of service
• Data: Stored images, pseudonymized extracted text
• User Control: You can delete individual histories via in-app settings. You may request full data deletion at any time (see Section 9).
• Retention Policy: Retained for the duration of your active account plus 12 months after account closure
Automatically deleted or anonymized after this period, unless deleted earlier by the user
Users are responsible for ensuring that any uploaded content, especially involving third parties, is lawful for retention.
AI Training Data
• Purpose: Improve model performance and suggestion quality
• Data: Screenshots and/or extracted text (Pseudonymization applied where feasible)
• User Control: Used only with user's explicit opt-in consent (see Section 3)
Consent may be withdrawn at any time via app settings
• Retention Policy: Retained only during the active consent period and necessary training cycle
Deleted or fully anonymized at the end of the quarterly training cycle, or upon consent withdrawal, whichever comes firstIn no case retained (in identifiable or pseudonymized form) beyond 12 months from the date of collection
Usage and Analytics Data
• Purpose: Product improvement and user trend analysis
• Data: Pseudonymized usage data collected via tools such as Firebase and Mixpanel
• Retention Policy: Retained for 24 months from the date of collection
After this period, either deleted or aggregated into a fully non-identifiable format
Aligned with standard analytics practices and GDPR minimization principles.
Account & Subscription Data
• Purpose: Legal, financial, and tax compliance
• Data: Email, subscription history, invoices, payment-related metadata
• Retention Policy: Retained for the life of the account and for 10 years following the end of the relevant accounting period
Required under French commercial and tax law (e.g., Code de commerce Art. L123-22)
Customer Support Communications
• Purpose: Service quality, issue tracking, and legal record-keeping
• Data: Emails, chat messages, support transcripts
• Retention Policy:
Prospective users: Retained for up to 3 years after last contact (per CNIL guidance)
Active customers: Retained for up to 5 years after the end of the customer relationship
Supports potential claims, dispute resolution, and fraud prevention.
We periodically review all retention schedules to ensure compliance with applicable laws and business needs. Where retention is no longer necessary, we delete or irreversibly anonymize the data.
These international transfers may involve the third-party service providers listed in Section 5.
To request deletion of your data or clarification regarding any specific retention period, please contact us at [email protected] (see Section 9).
Where necessary, we implement supplementary technical and organizational measures to ensure that your personal data receives an equivalent level of protection, including encryption, access controls, and data minimization.
8. DATA SECURITY
We take data security seriously and implement appropriate technical and organizational measures to protect the personal data we process from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access, in accordance with Article 32 of the GDPR.
Our security measures are designed to ensure the confidentiality, integrity, and availability of your data, and include (but are not limited to):
Encryption of data in transit and, where applicable, at rest
Where appropriate, we also use pseudonymization or data minimization techniques, especially when processing screenshots, extracted text, or training data, to reduce the identifiability of the information.
We periodically test our infrastructure for vulnerabilities and review access permissions to minimize the risk of unauthorized data exposure.
Access controls to restrict data access to authorized personnel based on job function and least-privilege principles
Regular system updates, vulnerability scanning, and security patching
Secure software development practices, including internal testing and code reviews
We require all service providers who process personal data on our behalf to implement comparable technical and organizational security measures through contractual obligations.
Audit logging and monitoring for unusual activity or unauthorized access attempts
Cloud Infrastructure: All data is hosted within a secure Amazon Web Services (AWS) environment with strict access management and encryption controls enabled.
Limitations & User Responsibility
While we maintain strong security protocols, no electronic transmission or digital storage method can be guaranteed 100% secure. As such, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized actors will be unable to breach our safeguards and improperly access your data.
You are also responsible for maintaining the confidentiality of your own device and login credentials. You should only access the App through secure connections and avoid using the Service on compromised or public devices.
By using the App, you acknowledge that transmission of personal data is at your own risk, and that we cannot guarantee absolute protection against evolving cybersecurity threats.
9. YOUR PRIVACY RIGHTS (GDPR)
If you are located in the European Economic Area (EEA), the United Kingdom (UK), or another region with similar data protection laws, you have certain rights over your personal data under applicable legislation, including the General Data Protection Regulation (GDPR) and equivalent UK laws.
Subject to legal conditions and limitations, your rights may include:
• Right of Access: You have the right to request a copy of the personal data we hold about you, along with certain information about how and why we process it.
• Right to Rectification: You can request correction of any inaccurate or incomplete personal data concerning you.
• Right to Erasure ("Right to Be Forgotten"): You can request the deletion of your personal data when:
It is no longer necessary for the purposes for which it was collected
You withdraw your consent (if processing is based on consent)
You object to processing and there are no overriding legitimate grounds
The data has been unlawfully processed
You may delete individual conversation histories directly within the app, or request full account and data deletion by contacting us at [email protected].
• Right to Restrict Processing: You can request that we limit the way we use your personal data, for example, during a dispute about accuracy or lawfulness.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller where technically feasible.
• Right to Object: You can object to processing that is based on our legitimate interests (Art. 6(1)(f)), particularly if you believe your fundamental rights and freedoms outweigh our interests.
• Right to Withdraw Consent: If we rely on your consent to process your personal data (e.g., for AI training purposes), you have the right to withdraw your consent at any time. You can manage your preferences via the toggle switch in the app settings. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
• How to Exercise Your Rights: To exercise any of your rights not available through app settings (e.g., access, restriction, objection, portability), please send a written request to: [email protected]. To protect your data, we may need to verify your identity before acting on your request. We aim to respond within one month, as required under the GDPR, and will inform you if additional time is needed due to complexity or volume.
• Right to Lodge a Complaint: If you believe we have violated your data protection rights, you have the right to lodge a complaint with your local data protection authority. In France, this is: Commission Nationale de l'Informatique et des Libertés (CNIL).
10. CHILDREN'S PRIVACY
Our Service is not directed to, and is not intended for use by, individuals under the age of 18 (or the age of legal majority in their jurisdiction, if higher).
We do not knowingly collect or process personal data from children under the age of 18.
If we become aware that we have inadvertently collected personal data from a minor without appropriate parental or legal guardian consent, we will take immediate steps to:
• Delete the personal data from our systems
• Disable or restrict access to the associated account (if applicable)
If you are a parent or legal guardian and believe your child has provided us with personal data without your consent, please contact us immediately at [email protected] so that we may take appropriate action.
By using the App, you confirm that you are at least 18 years old, or that you are of the age of majority in your country or territory.
11. SENSITIVE INFORMATION
We do not intentionally collect or require sensitive personal data to use the App.
This includes data revealing:
• Racial or ethnic origin
• Political opinions or religious/philosophical beliefs
• Trade union membership
• Genetic or biometric data
• Health or medical data
• Sexual orientation or sex life
• Criminal convictions or offenses
However, due to the nature of the App, we acknowledge that screenshots or text you voluntarily upload may inadvertently contain sensitive information relating to yourself or third parties.
Important: Your Responsibility
You remain fully responsible for any content you choose to upload.
We strongly advise against uploading content that includes unnecessary sensitive personal data, especially when it concerns other individuals.
If your content includes third-party sensitive data, you must have a valid legal basis, such as explicit consent under Article 9(2)(a) of the GDPR.
While we implement robust technical and organizational safeguards (see Section 8), we do not use sensitive data for:
• Automated profiling
• Targeted advertising
• Behavioral prediction
Use in AI Training (if consented)
If you opt in to allow your data to be used for AI model training, and that content happens to contain sensitive personal data:
• We apply pseudonymization techniques (where technically feasible) to reduce re-identification risk
• Training data is processed in accordance with Section 7 and deleted or anonymized within the stated retention period
• You may withdraw your consent at any time (see Section 9)
Nonetheless, users should exercise extreme caution in consenting to the use of sensitive data for training purposes. When in doubt, redact or remove it before uploading.
12. ADDITIONAL INFORMATION
12.1 Cookies and Tracking Technologies
While the core App does not use traditional browser-based cookies, we may use software development kits (SDKs), local storage, and other mobile tracking technologies that function similarly to cookies.
These may be deployed directly in the app or through embedded services and webviews (e.g., support platforms or analytics dashboards).
Examples include:
• Authentication and session management
• Analytics and crash reporting
• Performance optimization
• Marketing attribution (if applicable)
Consent Requirement for EU Users:
In accordance with the ePrivacy Directive and GDPR, we request your explicit consent before using non-essential tracking technologies within the app or any associated web-based features (where required by law).
You can manage your tracking preferences via in-app settings or device-level privacy controls.
For more information about how Firebase or Mixpanel use tracking data, please refer to their respective privacy policies.
12.2 Do Not Track (DNT) Signals
Some browsers offer a "Do Not Track" feature. Currently, our App does not respond to DNT signals, as there is no industry standard for interpreting them.
We respect your privacy through other means, including explicit consent mechanisms and opt-out features where required.
12.3 California Privacy Rights (CCPA/CPRA)
As of the date of this Privacy Policy, our business does not meet the thresholds for mandatory compliance under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).
However, we are committed to transparency and privacy best practices. We do not sell or share your personal information, and we do not use it for profiling, targeted advertising, or other activities restricted under California law.
If you are a California resident and would like to make a request concerning your personal information, you may still contact us at [email protected], and we will do our best to honor it consistent with applicable law and our internal policies.
We continuously review our obligations under CCPA/CPRA and will update this section if our eligibility status changes in the future.
12.4 Policy Updates
We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or technology. When we do:
• We will revise the "Last Updated" date at the top of this policy
• We may notify you through the App or via email where required by law
• We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information.
13. PERMISSIONS AND DEVICE ACCESS
To provide key functionality, the App may request access to certain device permissions. These are requested only when necessary and are not activated without your explicit consent:
• Camera Access: Used only when you choose to capture a photo or screenshot directly within the App. This allows you to upload conversations for analysis. The camera is not accessed in the background and no images are captured without your action.
• Photo Library Access: Requested when you manually choose to upload an existing screenshot or image. Access is limited to the image you select and does not include bulk access or browsing your media unless authorized.
• Storage Access (Android only): Required to enable saving or uploading screenshots from your device to the App.
You can manage these permissions at any time through your device settings.
Refusal to grant access may limit some features (e.g., uploading conversation images), but it will not prevent use of the rest of the App.
We do not access your camera, photos, or files without your knowledge or consent.
14. Contact Details
If you have any questions, requests, or concerns about this Privacy Policy or our data practices, you can contact us at:
Immediate Transformation Academy
6 rue d'Armaille, Paris 17, France
Email: [email protected]