Small Wins

1. Introduction

Small Wins ("we," "our," or "us") is committed to protecting your privacy and being transparent about how we collect, use, and share your information. This Data Policy explains our practices regarding the collection and use of information through our mobile application.

By using the Small Wins app, you agree to the collection and use of information in accordance with this policy. If you have any questions about this policy, please contact us.

2. Information We Collect

2.1 Information You Provide

We collect information you directly provide when using the app:

• Profile Information: Your name, preferred categories (Health, Finance, Productivity, Learning, Relationships, Mental/Self), preferred time of day, and win style preferences
• Content: Photos and images you upload as evidence of your achievements, journal entries, and progress notes
• Preferences: Your coaching preferences, notification settings, and app customization choices
• Feedback: Any feedback, comments, or support requests you send us

2.2 Information Collected Automatically

We automatically collect certain information when you use the app:

• Usage Data: How you interact with the app, features you use, and your progress tracking patterns
• Device Information: Device type, operating system, app version, and unique device identifiers
• Performance Data: App performance, crash reports, and error logs
• Location Data: General location information (city/country level) for content personalization

2.3 Information from Third Parties

We may receive information from third-party services:

• App Stores: Basic account information and purchase history from Apple App Store or Google Play
• RevenueCat: Subscription status and payment information for premium features
• OpenAI: Aggregated usage statistics for AI content generation

3. How We Use Your Information

We use the collected information for the following purposes:

Purpose	Information Used	Legal Basis
Provide AI Coaching Services	Profile data, preferences, progress history	Contract performance, legitimate interest
Personalize Content	Categories, preferences, usage patterns	Legitimate interest, consent
Track Progress	Evidence photos, journal entries, achievements	Contract performance
Send Notifications	Preferences, device tokens	Consent, legitimate interest
Improve Services	Usage data, feedback, performance metrics	Legitimate interest
Process Payments	Subscription data, payment information	Contract performance

4. AI Content Generation and Data Processing

Small Wins uses OpenAI's artificial intelligence technology to provide personalized coaching. Here's how your data is processed:

Important: By using our AI features, you acknowledge that your information will be processed by OpenAI in accordance with their privacy policy. We recommend reviewing OpenAI's privacy practices at openai.com/privacy.

5. Information Sharing and Disclosure

We do not sell, rent, or trade your personal information. We may share your information in the following circumstances:

5.1 Service Providers

• OpenAI: For AI content generation (as described above)
• RevenueCat: For subscription management and payment processing
• Cloud Services: For data storage and app hosting
• Analytics Services: For app performance monitoring and improvement

5.2 Legal Requirements

We may disclose your information if required by law or in response to valid legal requests, such as subpoenas or court orders.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the business transaction.

5.4 Aggregated Data

We may share aggregated, anonymized data that does not identify individual users for research, analytics, or business purposes.

6. Data Storage and Security

6.1 Storage Locations

• Local Storage: Your data is primarily stored locally on your device using secure storage methods
• Cloud Storage: Some data may be backed up to secure cloud servers for app functionality
• Third-Party Services: Limited data is processed by OpenAI and RevenueCat as described above

6.2 Data Security

We implement appropriate security measures to protect your information:

• Encryption of data in transit and at rest
• Secure authentication and access controls
• Regular security assessments and updates
• Limited access to personal data by authorized personnel only

6.3 Data Retention

We retain your information for as long as necessary to provide our services:

• Active Use: Data is retained while you actively use the app
• Account Deletion: You may request deletion of your account and associated data
• Legal Requirements: Some data may be retained longer if required by law

7. Your Rights and Choices

You have certain rights regarding your personal information:

7.1 Access and Control

• View Data: Access your profile information and preferences within the app
• Update Information: Modify your profile, preferences, and settings
• Delete Content: Remove photos, journal entries, and other content you've created
• Export Data: Request a copy of your data in a portable format

7.2 Communication Preferences

• Notifications: Control push notifications and reminder settings
• Marketing: Opt out of promotional communications (if any)
• Data Processing: Request limitations on how your data is processed

7.3 Account Deletion

You may request deletion of your account and associated data by contacting us. Note that some information may be retained for legal or business purposes.

8. Third-Party Services and Integrations

Our app integrates with several third-party services. Each has their own privacy policies:

9. Children's Privacy

Small Wins is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place to protect your information in accordance with applicable data protection laws.

11. Changes to This Policy

We may update this Data Policy from time to time. We will notify you of any material changes by:

• Posting the updated policy in the app
• Sending you a notification
• Updating the "Last updated" date at the top of this policy

Your continued use of the app after changes become effective constitutes acceptance of the updated policy.

13. Data Protection Rights (GDPR)

If you are located in the European Economic Area (EEA), you have additional rights under the General Data Protection Regulation (GDPR):

• Right to Rectification: Correct inaccurate or incomplete personal data
• Right to Erasure: Request deletion of your personal data ("right to be forgotten")
• Right to Restrict Processing: Limit how we process your data
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing of your personal data
• Right to Withdraw Consent: Withdraw consent for data processing where applicable

To exercise these rights, please contact us using the information provided above.