Privacy Policy

Last updated: 14 September 2026

Ly Khanh Quynh, an individual doing business as "Pretty Witty" ("Pretty Witty," "we," "us," or "our") operates the Pretty Witty app for iOS (the "App"), the website www.prettywitty.ai (the "Website"), and related services (together, the "Services").

This Policy explains what we collect, how we use and share it, your choices, and your rights.

Two commitments up front:

1. We never use your in-App content — screenshots, messages, or media — for advertising or marketing, ours or anyone else's.
2. We never use your in-App content to develop or improve AI models unless you have explicitly turned that on. It is off by default.

Terms not defined here have the meaning given in our Terms of Service. Questions: privacy@prettywitty.ai.

1. Who we are and how to reach us

Controller: Ly Khanh Quynh, doing business as "Pretty Witty" Address: 8/1 Nguyen Trai, Long Xuyen, An Giang, Vietnam Privacy and data protection contact: privacy@prettywitty.ai

Ly Khanh Quynh acts as our data protection contact for the purposes of the Singapore Personal Data Protection Act, the Malaysian Personal Data Protection Act, the Indian Digital Personal Data Protection Act, the Vietnamese Personal Data Protection Law, and equivalent requirements in the other markets listed in Section 2. Privacy questions, rights requests, and complaints should all go to the email address above.

2. Who the Services are for, and where they are available

The Services are for adults aged 18 and over only.

The App is published on the Apple App Store with an 18+ age rating and is made available only in the following territories:

Australia · Hong Kong · India · Indonesia · Japan · Macau · Malaysia · New Zealand · Philippines · Singapore · South Korea · Taiwan · Thailand · United States · Vietnam

The App is not offered in the European Union, the European Economic Area, the United Kingdom, or Switzerland, and we do not market the Services there. There is no web version of the App — www.prettywitty.ai is an informational and marketing website only.

Your data is processed and stored in India, Singapore, and the United States as described in Section 9.

3. What we collect

A. Information you give us

Account information. Your email address and a password, or a Google account, or Sign in with Apple. If you use Sign in with Apple and choose Hide My Email, we receive an Apple private relay address rather than your real one, and that is all we ever hold.

Profile information. Confirmation that you are 18 or over, a preferred name, your language, and optional conversation preferences and style presets (for example "Spice/Sugar").

Uploaded content. The screenshots you choose to submit and the text you type or paste for analysis. This is the material the App exists to work with, and it is the most sensitive data we hold. See Sections 5, 6, and 7.

Support communications. Whatever you send us when you contact us.

We do not collect your phone number, your pronouns, your date of birth, your contacts, your precise location, microphone audio, camera input, health data, or facial or biometric data.

B. Information we receive or generate automatically

Device and app diagnostics. Device model, iOS version, App version, language, approximate location (country, region, and city) inferred from your IP address, in-app event logs, and crash and performance diagnostics. This is collected through Google Analytics for Firebase and Firebase Crashlytics.

Identifiers. An account identifier, a Firebase installation identifier, and the iOS Vendor Identifier (IDFV). We do not collect the Advertising Identifier (IDFA), and we do not track you across other companies' apps or websites. The App therefore does not show you an App Tracking Transparency prompt, because there is nothing to ask about.

Purchase data. Subscriptions and credit packs are sold exclusively through Apple's In-App Purchase system. We receive transaction identifiers, product identifiers, and subscription or entitlement status from Apple. We never see or store your payment card details — Apple handles payment entirely.

Age category from Apple. Where Apple makes it available, we request your age category (over 18 / 16–17 / 13–15 / under 13) through Apple's Declared Age Range API, in order to confirm eligibility and to comply with age assurance laws in Texas, Utah, Louisiana, and elsewhere. This returns a category only. We do not receive your date of birth, your Apple Account details, or any identity document.

Website data. On the Website we use cookies, local storage, and pixels for essential functions, analytics, and interest-based advertising. See our Cookie Policy and the "Your Privacy Choices" link on the Website. This applies to the Website only and never touches in-App content.

C. How screenshots reach the App, and what we do not have access to

There are exactly two ways content enters the App:

1. The system photo picker. When you add a screenshot inside Chat History, iOS presents Apple's photo picker. This runs outside our App. It hands us only the single image you select. It does not ask for a permission, because we are not requesting one — and it does not give us access to your photo library.
2. The iOS Share Sheet. You can share a screenshot to Pretty Witty from Messages, a dating app, Photos, or anywhere else. Our Share Extension receives only the item you chose to share, at the moment you share it.

Consequently:

• We do not request photo library access, Limited Photos Access, or any storage permission.
• We do not request camera access. There is no in-App camera.
• We do not read your clipboard, and we do not support drag-and-drop into the App.
• We have no on-screen awareness, assistant, or keyboard extension of any kind. The App does not integrate with Siri, App Intents, Shortcuts, Apple Intelligence, or Visual Intelligence, and we ship no custom keyboard.
• We do not collect facial mapping, TrueDepth, or head-movement data, and we do not use Face ID or any biometric authentication.

Outside the two moments described above, we have no visibility into your photos, files, screen, or device.

4. How we use your information

We rely on consent rather than legitimate interests wherever local law requires it, including in India, Vietnam, South Korea, Thailand, and Indonesia. Where we rely on consent, you can withdraw it at any time, and withdrawing it does not affect processing that already happened.

5. AI processing of your content

What happens when you submit a screenshot

Before your first upload, the App asks for your explicit permission to send content to our AI provider, and tells you exactly what is sent and to whom. You can decline, and you can withdraw permission later in Settings → Privacy, in which case the analysis feature stops working but the rest of the App continues to function.

When you do submit a screenshot or text:

1. It is transmitted over an encrypted connection to our backend, hosted on Render in Singapore, where it is held only for the duration of processing.
2. It is sent to Google's Gemini models, accessed through OpenRouter as a routing service. Our routing is pinned to Google — no other AI provider receives your content.
3. The suggestions come back to your device, and the screenshot and transcript are stored encrypted in our infrastructure in India.

What our AI providers do with it

OpenRouter operates a zero-data-retention configuration for our account. It routes the request and does not retain your prompts.

Google processes our requests on the paid Gemini API tier. On this tier, Google does not use prompts or responses to train its models. Google does log prompts and responses for up to 55 days solely to detect violations of its Prohibited Use Policy, after which they are deleted. Processing takes place on Google's infrastructure and the exact location varies.

This means that if you delete something in the App, a copy may still exist in Google's abuse-monitoring logs for the remainder of that 55-day window. We cannot shorten or delete those logs.

Please do not upload

Our security is good, but no system is perfect, and the moment content leaves our systems for an AI provider we no longer control it. Do not upload:

• Government-issued identification (passports, driver's licences, national ID cards)
• Financial information (card numbers, bank statements, account details)
• Medical or health records you want kept confidential
• Intimate images or sexually explicit visual content
• Personal data of other people that you have no right to share
• Anything you could not afford to have exposed in a security incident

6. AI model development — opt-in only

We do not use your content to develop AI models unless you switch it on. The setting is in Settings → Privacy and is off by default. As of the date of this Policy, we have not trained or fine-tuned any model on user content.

If you leave it off (the default): your screenshots and their transcripts are permanently deleted 90 days after upload, or sooner if you delete them yourself.

If you turn it on: after the 90-day period, instead of being deleted, your screenshots and transcripts are de-identified and retained so that we can develop and improve the conversation-coaching features. De-identification involves removing names, faces, and other direct identifiers; stripping metadata such as timestamps, device identifiers, and location; and aggregating content so that individual records cannot readily be traced back to a person.

An honest limitation. De-identifying free-text conversations is difficult and we will not claim it is perfect. We therefore do not treat de-identified content as though it were outside privacy law and beyond all protection. We continue to store it encrypted, under the same access controls, and we never publish it, sell it, or share it with third parties. We do not attempt to re-identify it, and we conduct re-identification risk assessments before it is used.

You can change your mind. Turning the setting off stops any further content being retained for this purpose. Content that has already been de-identified and merged into training datasets cannot be pulled back out, because there is no longer a reliable link between it and you. If this concerns you, leave the setting off.

7. Sensitive content, and other people in your screenshots

Sensitive categories

Screenshots of dating conversations frequently contain information that counts as sensitive or special-category data under the laws of the markets we operate in — for example information about sexual orientation or sexual life, health, religious belief, or ethnicity. Where local law requires separate, explicit consent for processing such data, we ask for it before you upload, and you can withdraw it at any time.

We process this material only to deliver the feature you asked for, and — if and only if you have opted in — for the de-identified model development described in Section 6. We never use it for advertising, and we never disclose it to advertisers or marketing vendors.

Other people

Your screenshots will usually contain messages, profiles, or photographs of other people who are not our users and have not agreed to anything. We take this seriously and so should you. By uploading, you confirm that you have the right to share what you are sharing, and you agree not to upload content that violates another person's privacy or another platform's terms.

What we ask of you:

• Upload only conversations you are personally part of
• Crop or remove full names and other strongly identifying details where you can
• Never upload intimate or sexually explicit images of another person
• Remove anything sensitive that the App does not need in order to help you

If you are not a Pretty Witty user and believe your information appears in someone else's upload, email privacy@prettywitty.ai and we will locate and remove it. You do not need an account to make this request.

8. How we share information

We do not sell your personal information, and we do not share it for cross-context behavioural advertising. We disclose it only as follows:

• Service providers, listed individually in Section 9, who process data on our instructions in order to run the Services
• Apple, which processes all payments through In-App Purchase and provides subscription status and age category signals
• Professional advisers — lawyers, accountants, auditors — where genuinely necessary
• Advertising and analytics partners on the Website only, using Website visit data. Never in-App content.
• Authorities, where we are legally required to disclose, or where disclosure is necessary to protect rights, safety, or property
• A successor, in the event of a merger, acquisition, financing, or sale of the business. We would notify you before your data became subject to a different privacy policy.

In-App content is walled off. No advertising product, ad network, or marketing vendor has access to your screenshots, messages, or media. This is not a preference we might revise quietly; it is a commitment.

9. Service providers and where your data lives

Note on the Firebase Realtime Database. The Firebase Realtime Database is not offered in the asia-south1 region. Our Realtime Database instance is hosted in the nearest available region; contact privacy@prettywitty.ai if you would like us to confirm the current region for your data. Firebase Cloud Messaging is operated by Google on globally distributed infrastructure.

Data processing agreements. We rely on Google's and Apple's standard data processing terms, and maintain processing agreements with our other providers, requiring them to implement appropriate security measures, process data only on our instructions, assist with your rights requests, and notify us of breaches. You may request further detail at privacy@prettywitty.ai.

10. Security

We protect your data with:

• Encryption in transit (TLS) and encryption at rest for stored content
• Role-based, least-privilege access controls — access to uploaded content is restricted to the minimum number of people
• Access logging and monitoring for all access to uploaded content
• Network security controls and managed key handling
• Periodic security review and vulnerability testing

No system is completely secure. If a breach affects your personal data, we will notify you and the relevant regulators as described in Section 12.

11. How long we keep things, and how to delete them

Deleting your data

Individual screenshots: delete them at any time in the App.

Your whole account: Settings → Delete Account. This is irreversible and removes your account, profile, conversation history, and all uploaded content.

Without using the App: email privacy@prettywitty.ai and we will handle it. You do not need to have the App installed.

What "deleted" means in practice

• Content becomes inaccessible to you immediately
• It is purged from our active systems within 30 days
• It is purged from encrypted backups within a further 90 days, as those backups roll over
• Copies in Google's AI abuse-monitoring logs persist for the remainder of their 55-day window from the date you submitted the content, and we cannot delete these
• We may retain a minimal record where law requires it — for example transaction records for tax purposes, or records needed to resolve a payment dispute or prevent fraud

12. If something goes wrong

If we become aware of a personal data breach affecting you, we will notify you and the competent regulator without undue delay, and within the timeframes set by your local law — generally within 72 hours of becoming aware, and within 3 calendar days for notifications to Singapore's Personal Data Protection Commission. We will tell you what happened, what data was involved, and what you should do.

13. Your choices

AI analysis. Consent is requested before your first upload and can be withdrawn at any time in Settings → Privacy.

AI model development. Off by default. Settings → Privacy. See Section 6.

Push notifications. Optional, and controlled both in the App and in iOS Settings.

Marketing email. Unsubscribe from the footer of any marketing email, or write to privacy@prettywitty.ai. You will still receive essential service messages about your account and purchases.

Website cookies and advertising. Manage these through the cookie banner, our Cookie Policy, or the "Your Privacy Choices" link on the Website. Where applicable we honour the Global Privacy Control signal for Website processing.

What you upload. The most effective privacy control is the one you hold. Do not submit content you need to keep strictly private.

14. Your rights

Whatever market you are in, we extend the following rights to you:

• Access the personal data we hold about you
• Correct data that is wrong or incomplete
• Delete your data (Section 11)
• Export a copy in a machine-readable format
• Object to or restrict processing based on our legitimate interests
• Withdraw consent at any time where we rely on it
• Nominate another person to exercise your rights on your behalf, where your local law provides for this
• Complain to your national data protection authority

To make a request, email privacy@prettywitty.ai. We may ask for information to verify your identity — we will not hand your data to someone claiming to be you. We respond within 30 days, and faster where your local law requires it. We do not charge for this and we will never treat you differently for exercising a right.

United States. We are a small business and do not currently meet the applicability thresholds of the California Consumer Privacy Act or the other US state comprehensive privacy laws. We nonetheless extend the rights above to US residents as a matter of policy. We do not sell personal information, we do not share it for cross-context behavioural advertising, and we do not process consumer health data as that term is defined under Washington, Nevada, or Connecticut law — please do not upload medical or health information to the App.

15. International data transfers

Your data is processed in India, Singapore, and the United States, and on Google's and Apple's infrastructure, which may be located elsewhere. If you are outside those countries, using the Services means your data is transferred internationally.

We protect those transfers through contractual commitments with each provider, Standard Contractual Clauses or equivalent approved mechanisms where local law requires them, provider selection based on demonstrated security and privacy practice, and periodic reassessment.

South Korea. Under PIPA we obtain your separate consent to transfer your personal data abroad. The recipients, destinations, purposes, categories of data, and retention periods are those set out in Sections 9 and 11. You may refuse this transfer, though doing so means we cannot provide the analysis feature.

Japan. Under the APPI we make information available about the data protection regimes of India, Singapore, and the United States on request at privacy@prettywitty.ai.

Vietnam and India. Where cross-border transfer assessments or filings are required of us, we complete them within the statutory deadlines.

If your jurisdiction requires data to remain local, our infrastructure cannot currently support that. Contact us if this affects you.

16. Age requirement

The Services are for adults aged 18 and over. The App carries an 18+ rating on the App Store.

We confirm your eligibility in two ways: you confirm you are 18 or over when you create an account, and, where Apple provides it, we check the age category returned by Apple's Declared Age Range API. Where your Apple Account is subject to an age assurance law — including Texas SB2420, Utah's App Store Accountability Act, and Louisiana's equivalent — we act on the age signal and the parental consent status Apple provides, and we will restrict or end access where consent is refused or withdrawn.

If we learn that someone under 18 is using the Services, we block access and delete the account. If you believe a minor has given us personal data, contact privacy@prettywitty.ai and we will act promptly.

17. Advertising and analytics

In-App: no advertising, no advertising SDKs, no attribution or measurement SDKs, no cross-app or cross-site tracking, and no access by any third party to your in-App content. We do not collect the IDFA.

Website: we use analytics and advertising cookies. Manage them through the cookie banner, the Cookie Policy, or "Your Privacy Choices". We honour Global Privacy Control for Website processing where required.

18. App permissions and device features

19. Regional information

India — Digital Personal Data Protection Act 2023 and DPDP Rules 2025. We process your data on the basis of your consent, or for a permitted legitimate use. You have rights of access, correction, completion, erasure, grievance redressal, and nomination. Our data protection contact is in Section 1. Substantive obligations under the DPDP framework phase in through May 2027, and we are aligning ahead of those dates.

Vietnam — Personal Data Protection Law 91/2025/QH15 and Decree 356/2025/ND-CP. We obtain your consent before processing, complete personal data processing impact assessments and cross-border transfer impact assessments where required, and file them within the statutory deadlines.

Singapore — PDPA. Our data protection contact is in Section 1. We notify the PDPC of notifiable breaches within 3 calendar days and affected individuals as soon as practicable.

South Korea — PIPA. We obtain separate, itemised consent for the processing of sensitive information and for cross-border transfers, and you may refuse either.

Thailand — PDPA and Indonesia — Law 27/2022. We obtain explicit consent for sensitive personal data, including data revealing sexual behaviour or orientation.

Malaysia — PDPA (as amended). We have a designated data protection contact and notify breaches as required.

Japan — APPI. We use your data only for the purposes stated in Section 4, and provide information about destination countries on request.

Hong Kong — PDPO, Macau, Taiwan — PDPA, Philippines — Data Privacy Act. We handle your data in line with local requirements and you may exercise the rights in Section 14.

Australia — Privacy Act 1988 and New Zealand — Privacy Act 2020. You may access and correct your data and complain to the OAIC or the New Zealand Privacy Commissioner respectively. Cross-border disclosures are made subject to the contractual protections in Section 15.

United States. See Section 14.

20. Changes to this Policy

We may update this Policy. When we do, we will change the date at the top and, where the change is significant or required by law, notify you in the App or by email. Where a change requires your consent, we will ask for it rather than assume it.

21. Contact

Email: privacy@prettywitty.ai Post: Ly Khanh Quynh (d/b/a Pretty Witty), 8/1 Nguyen Trai, Long Xuyen, An Giang, Vietnam

Summary (not binding — the sections above govern)

• Screenshots come in only through Apple's photo picker or the Share Sheet. We have no camera, photo library, clipboard, screen, or keyboard access.
• Your content is analysed by Google Gemini via OpenRouter, with your explicit permission, on a paid tier where Google does not train on it. Google keeps abuse-monitoring logs for up to 55 days.
• Screenshots are deleted after 90 days. Model development is opt-in and off by default.
• We never use in-App content for advertising, and we never sell your data.
• You can delete individual screenshots or your whole account in the App, or by email.
• Payments go through Apple. We never see your card details.
• Data lives in India, Singapore, and the United States.