Privacy Policy
This privacy policy applies to the Wrist AI app (hereby referred to as "Application") for mobile devices that was created by Wrist AI (hereby referred to as "Service Provider") as a Freemium service. This service is intended for use "AS IS".
Data Controller Information
The data controller responsible for your personal information is:
- Name: Boris Bugor (trading as Wrist AI)
- Address: 29A Falcon Road, SW11 2PH, London, UK
- ICO Registration Number: ZC081819
- Email: support@onwrist.ai
AI Processing and Audio Data Collection
Important: The Application uses artificial intelligence to provide AI-powered voice chat functionality. When you use the Application:
- Audio Recordings: The Application collects audio recordings from your device's microphone when you speak to the AI assistant.
- Conversation History: Your conversations with the AI assistant are stored locally on your device to provide context for your interactions.
- Processing by OpenAI: Your audio recordings and conversation history are sent to OpenAI (a US-based company) for processing through their AI models (specifically, GPT-4 audio models) to generate responses. OpenAI processes this data in accordance with their Data Processing Agreement and privacy policy.
- Real-time Processing: Audio data is processed in real-time and is not permanently stored on OpenAI's servers. Conversation history is stored locally on your device.
- OpenAI Privacy Policy: You can review OpenAI's privacy practices at https://openai.com/privacy
By using the AI voice chat features, you consent to the processing of your audio data and conversation history as described above.
Information Collection and Use
The Application collects information when you download and use it. This information may include information such as:
- Your device's Internet Protocol address (e.g. IP address)
- The pages of the Application that you visit, the time and date of your visit, the time spent on those pages
- The time spent on the Application
- The operating system you use on your mobile device
The Application does not gather precise information about the location of your mobile device.
The Service Provider may use the information you provided to contact you from time to time to provide you with important information, required notices and marketing promotions.
For a better experience, while using the Application, the Service Provider may require you to provide us with certain personally identifiable information, including but not limited to device identifier. The information that the Service Provider request will be retained by them and used as described in this privacy policy.
Third Party Access
Only aggregated, anonymized data is periodically transmitted to external services to aid the Service Provider in improving the Application and their service. The Service Provider may share your information with third parties in the ways that are described in this privacy statement.
Please note that the Application utilizes third-party services that have their own Privacy Policy about handling data. Below are the links to the Privacy Policy of the third-party service providers used by the Application:
- OpenAI - AI processing for voice chat
- Amplitude
- RevenueCat
- Flagsmith
The Service Provider may disclose User Provided and Automatically Collected Information:
- as required by law, such as to comply with a subpoena, or similar legal process;
- when they believe in good faith that disclosure is necessary to protect their rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
- with their trusted services providers who work on their behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.
Opt-Out Rights
You can stop all collection of information by the Application easily by uninstalling it. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.
Data Retention Policy
The Application does not operate its own servers or backend storage. Data is handled as follows:
- Local Device Storage: Conversation history is stored locally on your device. You can delete this data at any time by deleting conversations within the app or uninstalling the Application.
- Third-Party Service Providers: Data processed by third-party services (OpenAI, Amplitude, RevenueCat, Flagsmith) is retained according to their respective privacy policies and data retention periods. We do not control the retention periods of these third-party services.
- Data Deletion: All your data is stored locally on your device and can be deleted at any time by deleting conversations within the app or uninstalling the Application. Data held by third-party service providers is subject to their respective deletion policies.
Children
The Service Provider does not use the Application to knowingly solicit data from or market to children under the age of 13.
The Application does not address anyone under the age of 13. The Service Provider does not knowingly collect personally identifiable information from children under 13 years of age. In the case the Service Provider discover that a child under 13 has provided personal information, the Service Provider will immediately delete this from their servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact the Service Provider at support@onwrist.ai so that they will be able to take the necessary actions.
Security
The Service Provider is concerned about safeguarding the confidentiality of your information. The Service Provider provides physical, electronic, and procedural safeguards to protect information the Service Provider processes and maintains.
Changes
This Privacy Policy may be updated from time to time for any reason. The Service Provider will notify you of any changes to the Privacy Policy by updating this page with the new Privacy Policy. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.
This privacy policy is effective as of 2026-02-25
Legal Basis for Processing (UK GDPR)
We process your personal data based on the following legal grounds:
| Data Type | Purpose | Legal Basis |
|---|---|---|
| Audio recordings & conversation history | AI voice chat functionality | Contract - necessary to provide the service you requested |
| Device ID & analytics | App improvement & performance monitoring | Legitimate interest - improving our service |
| Coarse location | Analytics | Legitimate interest - improving our service |
| Purchase history | Subscription management | Contract - necessary to process payments |
| Diagnostic data | Feature flags & app configuration | Legitimate interest - maintaining service quality |
International Data Transfers
Your personal data may be transferred to and processed in countries outside the United Kingdom and European Economic Area (EEA), including the United States. These transfers are made to the following third-party service providers:
- OpenAI (United States): Processes audio recordings and conversation data for AI functionality
- Amplitude (United States): Provides analytics services
- RevenueCat (United States): Manages subscriptions and payments
- Flagsmith (United Kingdom): Provides feature flags and app configuration
We ensure that these transfers are protected by appropriate safeguards, including Standard Contractual Clauses approved by the UK Information Commissioner's Office (ICO) and European Commission. Each provider has committed to GDPR-compliant data processing through their Data Processing Agreements.
Your Rights Under UK GDPR
You have the following rights regarding your personal data:
- Right to Access: Request a copy of the personal data we hold about you
- Right to Rectification: Request correction of inaccurate personal data
- Right to Erasure: Request deletion of your personal data (also known as the "right to be forgotten")
- Right to Restrict Processing: Request that we limit how we use your data
- Right to Data Portability: Request a copy of your data in a machine-readable format to transfer to another service
- Right to Object: Object to processing based on legitimate interests
- Right to Withdraw Consent: Where processing is based on consent, you can withdraw it at any time
To exercise any of these rights, please contact us at support@onwrist.ai with proof of your identity. We will respond within 30 days.
Right to Lodge a Complaint: If you believe we have not handled your data properly, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk or call 0303 123 1113.
Your Consent
By using the Application, you are consenting to the processing of your information as set forth in this Privacy Policy now and as amended by us.
Contact Us
If you have any questions regarding privacy while using the Application, or have questions about the practices, please contact the Service Provider via email at support@onwrist.ai.