Privacy Policy — wiser.
Effective date: 2026-09-24 Last updated: 2026-09-25
In this document, "App" means the iOS app listed on the App Store as wiser: call your shots and shown on your home screen as wiser. (previously "Wiser"), including its updates. Any mention of wiser, wiser. or Wiser refers to the same app.
This Privacy Policy explains how personal data is handled when you use the wiser. iOS app (the "App"). It is written to meet the EU General Data Protection Regulation (GDPR), the UK GDPR and Türkiye's Personal Data Protection Law No. 6698 (KVKK). This policy also serves as the information notice (aydınlatma metni) under Article 10 of KVKK.
1. Short version
- Your bets stay on your device. Everything you write in the App (predictions, probabilities, reasoning, evidence, notes, resolutions, reflections) is stored only on your iPhone. We have no server that receives it and we cannot see it.
- We don't run ads, sell data, or track you across other apps or websites.
- Subscriptions are processed by Apple. Our subscription provider, RevenueCat, receives purchase records linked to a random ID, not your name or email.
- No AI service receives your content. The App does not send your entries to any language model or cloud service.
- You can ask us to access, correct or delete the limited data we (through RevenueCat) hold. See §10.
2. Who is responsible (data controller)
Dilara Karabey, sole proprietor (şahıs şirketi) Address: Segmenler Mah. 932 Sokak 4/5, 06830 Gölbaşı, Ankara, Türkiye Email: email us
3. Data that stays on your device
The following is stored locally on your device in the App's private storage and is not transmitted to us or to any third party by the App:
- your bets: claims, probabilities, resolution criteria and dates, reasoning, evidence, belief updates, resolutions, bias tags and postmortems;
- your training goal, level, XP, statistics and settings;
- notification schedules (reminders are scheduled locally on your device).
Because this content may include sensitive information you choose to write (for example about your health, relationships or finances), we have designed the App so that we never receive it. We do not process it and have no access to it.
Device backups. If you use iCloud Backup or computer backups, Apple or your computer may include App data in your device backup under your own settings. That processing is governed by Apple's privacy policy or your own device settings, not by us.
Sharing. If you create a share card, the image is generated on your device and shared only through the iOS share sheet to the destination you choose. By default share cards do not include the text of your bets.
Deleting it. You can erase all of it at any time in the App (You → Settings → Delete all my data), or by deleting the App. We cannot recover it for you.
4. Data processed when you subscribe
4.1 Apple
Purchases are made through the Apple App Store. Apple processes your payment details, Apple ID and billing information as an independent controller under the Apple Privacy Policy. We do not receive your payment card details, name or email address from Apple. We receive aggregated sales and financial reports from Apple.
4.2 RevenueCat (our processor)
We use RevenueCat, Inc. to validate purchases and manage your subscription status. When you open the App or make a purchase, RevenueCat processes:
- a random App User ID generated by the App (not linked to your name, email or Apple ID by us);
- purchase and subscription data: product, price, currency, purchase and renewal dates, transaction identifiers, trial/offer status, cancellation and refund status, App Store country/storefront;
- technical data: device model, operating system version, App version, language and IP address (used for security, fraud prevention and approximate country).
RevenueCat never receives the content of your bets.
| Purpose | Legal basis (GDPR) | Legal basis (KVKK) |
|---|---|---|
| Unlock and restore Premium, verify purchases, send the trial-end reminder at the right time | Art. 6(1)(b) — performance of a contract | Art. 5(2)(c) — contract |
| Prevent fraud and abuse, secure the service | Art. 6(1)(f) — legitimate interest in protecting the service | Art. 5(2)(f) — legitimate interest |
| Revenue reporting, accounting and tax | Art. 6(1)(c) — legal obligation; Art. 6(1)(f) for aggregated business reporting | Art. 5(2)(ç) — legal obligation; 5(2)(f) |
5. Data processed when you contact us
If you email us, we process your email address, the content of your message and any information you choose to include, to answer you (GDPR Art. 6(1)(b) or 6(1)(f); KVKK Art. 5(2)(c) or 5(2)(f)). Please do not send us bet content unless you need to.
6. Data Apple shares with developers if you opt in
If you have opted in on your device to share analytics or crash data with app developers, Apple may provide us with aggregated usage statistics and crash reports. These are controlled by your iOS settings (Settings → Privacy & Security → Analytics & Improvements). The App is designed so that crash reports do not contain the text of your bets.
7. What we do not do
- No advertising, and no advertising SDKs.
- No selling or renting of personal data, and no "sharing" for cross-context behavioral advertising.
- No tracking as defined by Apple's App Tracking Transparency.
- No profiling or automated decision-making that produces legal or similarly significant effects (GDPR Art. 22). Statistics such as your score are calculated on your device, for you only.
- No collection of device advertising identifiers.
8. Recipients and international transfers
- RevenueCat, Inc. (United States) — processor under a data processing agreement.
- Apple — independent controller for App Store purchases.
- Authorities, courts or advisers where required by law.
RevenueCat is located in the United States. Transfers of personal data from the EU/EEA and UK are protected by the European Commission's Standard Contractual Clauses (with the UK International Data Transfer Addendum for UK transfers), incorporated in RevenueCat's Data Processing Addendum. For users in Türkiye: there is no adequacy decision for the United States under Article 9 of KVKK (as amended by Law No. 7499), and RevenueCat does not currently offer the standard contract published by the Personal Data Protection Authority. The data sent is limited to what §4.2 lists, is needed to deliver the subscription you buy, and never includes your name, email or the content of your bets. We keep this under review and will put an appropriate safeguard in place, or stop the transfer, when that becomes possible. You can ask us about it by email.
9. How long we keep data
- On-device data: until you delete it or the App.
- RevenueCat subscription records: while you have a subscription, then up to 3 years after it ends (to handle refunds, disputes and support requests), then deleted. You can ask us to delete them sooner.
- Apple's financial reports: Apple's aggregated sales and payment reports are kept for 10 years as required by the Turkish Commercial Code (Art. 82). They don't identify you.
- Support emails: up to 24 months after your request is resolved, unless a longer period is required by law.
10. Your rights
Depending on where you live, you have the right to:
- access your personal data and get a copy (GDPR Art. 15; KVKK Art. 11);
- correct inaccurate data (Art. 16);
- delete your data (Art. 17);
- restrict processing (Art. 18);
- data portability (Art. 20);
- object to processing based on legitimate interests (Art. 21);
- withdraw consent where processing is based on consent, without affecting past processing;
- under KVKK Art. 11: learn whether your data is processed, its purpose, the third parties it's transferred to at home or abroad, request correction or deletion and notification of third parties, object to results arising exclusively from automated analysis, and claim compensation for unlawful processing.
How to exercise them. Email email us. Because we don't know who you are, include the Subscription ID shown in the App under You → Settings → Privacy so we can find your subscription records. We may ask for information to confirm the request comes from you. We answer within one month (GDPR) or 30 days (KVKK), extendable where the law allows.
Data on your device is under your control: you can view, export (where available) or delete it in the App at any time.
Complaints. You can complain to your local data protection authority (in the EU, the authority in your country of residence, work or the alleged infringement; in the UK, the ICO; in Türkiye, the Personal Data Protection Authority — Kişisel Verileri Koruma Kurumu). We'd appreciate the chance to fix things first.
11. Children
The App is not intended for anyone under 16. We do not knowingly process personal data of children under 16. If you believe a child has used the App to make a purchase, contact us and we will delete the related records we hold.
12. Security
On-device data is stored in the App's sandbox and protected by iOS data protection when your device is locked. Communication with RevenueCat uses encrypted connections (TLS). No method of storage or transmission is 100% secure, but we limit risk mainly by not collecting your content at all.
13. U.S. state privacy rights
We do not sell or share personal information as defined by the California Consumer Privacy Act and similar laws, and we do not use sensitive personal information to infer characteristics about you. Residents of those states may make the requests described in §10 using the same contact.
14. Changes
If we change what data leaves your device, we will update this policy before the change takes effect and tell you in the App. The "Last updated" date shows the latest version.
15. Contact
Dilara Karabey — email us — Segmenler Mah. 932 Sokak 4/5, 06830 Gölbaşı, Ankara, Türkiye