← Wispo

Privacy Policy

Last updated: 5 June 2026

1. Who we are

Wispo is developed and operated by Nuage Digital Ltd, a private limited company registered in England and Wales. For privacy questions or data requests, contact [email protected].

For the purposes of the UK GDPR and the Data Protection Act 2018, Nuage Digital Ltd is the "controller" of personal data described in this policy. References to "we", "us" and "our" in this policy mean Nuage Digital Ltd.

2. What we collect

2.1 Audio recordings

Audio you record is stored only on your device. We do not upload audio to our servers or to any third party. If you uninstall the app or delete a recording, the audio is permanently removed.

2.2 Transcripts

Transcription runs on-device using Apple's Speech framework and OpenAI's Whisper model bundled inside the app. The audio is converted to text locally — no transcription provider receives your audio.

If you sign in and enable cloud sync, your transcript text is stored in Google Firebase Firestore so it's available on your other devices. Audio remains device-local.

2.3 AI-generated notes

When you generate AI-structured notes from a recording, the transcript text is sent to one of the following providers:

• Groq (https://groq.com) — cloud LLM provider that runs Llama models. Used by default. Groq processes the transcript and returns structured notes. We route this call through our own server (a Cloudflare Worker) so Groq does not see your account identity, only a per-request token.
• Apple Intelligence — Apple's on-device large language model. If you select this provider in Settings, the transcript never leaves your device.

Generated notes are stored on your device. If you've signed in, they also sync to Firebase Firestore alongside your transcripts.

You can switch to your own Groq API key in Settings to send AI requests directly to Groq under your own account, bypassing our server entirely.

2.4 Account information

If you sign in, we receive the following from Apple or Google:

• Your name (if you chose to share it during sign-in)
• Your email address
• A unique account identifier (Firebase UID)

We use this only to identify you across devices and to associate your subscription status with your account. We do not send you marketing email.

2.5 Subscription status

Wispo Pro subscriptions are managed by Apple. We receive only:

• Whether you have an active subscription (true/false)
• Which subscription product you bought (monthly or yearly)
• The timestamp of the most recent subscription change

Payment details, card numbers, and billing addresses are handled entirely by Apple and never reach us.

2.6 Crash and error reports

If the app crashes or encounters a serious error, we receive a crash report via Google Firebase Crashlytics. These reports include:

• A stack trace of the code that crashed
• Your device model and iOS version
• The app version
• Your Firebase UID (when signed in) so we can correlate multiple reports
• Your subscription tier (free or pro) so we can prioritise issues
• "Breadcrumb" logs of what the app was doing in the seconds before the crash (these do not include your transcripts or recording content)

Crash reports help us fix bugs and ship more stable updates. They contain no audio, no transcripts, and no AI-generated content.

2.7 Product analytics events

We use Google Firebase Analytics to understand how people move through the app — for example, which step of onboarding people drop off at, whether the paywall is converting, and how often a recording ends up generating AI notes. The events we record are limited to the following set:

• Lifecycle: onboarding completed; sign-in succeeded (with provider name only — Apple or Google); signed out; account deletion initiated; account deleted.
• Subscription: paywall shown / dismissed (with the reason it opened and whether a purchase was made); trial started; subscription purchased (with the product ID).
• Recording flow: recording started; recording stopped (with duration in seconds); transcription completed (with word count and audio duration); AI summary generated or failed (with the provider name — Apple Intelligence or Groq — and a short failure reason).

Each event carries: a Firebase device identifier, your Firebase UID (only when signed in), a session timestamp, your subscription tier (free / trial / pro), the event name, and the parameters listed above. Firebase Analytics also automatically collects approximate location (derived from your IP address), device model and iOS version, and app session length.

What analytics events never include: your audio, your transcripts, your AI-generated notes, your recording titles, your folder names, anything you've typed into the app, your name, or your email address. Event content is restricted to enums, counts, and booleans.

We use this only for product analytics — understanding usage and improving the app. We do not share it with advertisers, use it for ad targeting, or sell it. You can request that we exclude your account from analytics by emailing [email protected].

2.8 What we don't collect

• We do not use any analytics SDK other than Firebase Analytics (no Mixpanel, no Amplitude, no Segment, no Facebook SDK).
• We do not track you across other apps or websites.
• We do not show advertising and do not share data with advertisers.
• We do not sell your personal data, to anyone, ever.

3. Why we collect it

• To make the app work — record audio, transcribe it, generate notes.
• To sync across your devices — so your notes are available on every device where you sign in.
• To process subscriptions — so we can grant you Pro features after Apple confirms a purchase.
• To fix bugs — so we know when the app crashes or errors out, and can ship updates that fix the problem.

Under UK GDPR, the lawful bases for our processing are:

• Performance of a contract (Article 6(1)(b)) — for the core service of recording, transcribing, syncing.
• Legitimate interests (Article 6(1)(f)) — for crash reporting, which is necessary to deliver a working product.
• Consent (Article 6(1)(a)) — when you sign in or explicitly enable cloud sync.

4. Who we share your data with

We do not sell your personal data and we do not share it with advertisers, data brokers, or analytics companies. We share limited data only with the sub-processors that make the app work:

• Google Firebase (Firestore, Authentication, Crashlytics, Analytics) — cloud sync, sign-in, crash reporting, and product analytics events as described in §2.7. Operated by Google LLC and its affiliates.
• Cloudflare, Inc. (Workers, Pages, Email Routing) — proxies AI requests to Groq, hosts this website, and routes support email.
• Groq, Inc. — generates AI-structured notes from transcript text. Based in the United States.
• Apple Inc. — processes App Store subscriptions and provides Sign in with Apple. We receive subscription status and (if you choose to share it) your name and email.

Each sub-processor handles only the data needed to perform its function and is bound by its own privacy and security commitments.

We may also disclose your personal data:

• Where required by law — to comply with a court order, subpoena, or other lawful request from a public authority, regulator, or law-enforcement agency.
• To enforce our terms or protect rights — where we have a good-faith belief that disclosure is necessary to investigate suspected fraud, abuse, or violations of our Terms of Use, or to protect the rights, property, or safety of Wispo, our users, or the public.
• In a corporate transaction — if Nuage Digital Ltd is involved in a merger, acquisition, restructuring, or sale of assets, your data may be transferred to the successor entity. We will notify you in advance of any such transfer and your rights under this policy will continue to apply.

5. Where your data lives and international transfers

Firebase data is stored in Google's data-centre regions; by default our Firestore database is hosted in europe-west2 (London) so UK and EU user data stays in the UK or EEA at rest. Crashlytics and Authentication operate globally and may store data in the United States.

Cloudflare's network is global; the closest edge node handles each request. Groq processes AI requests in the United States.

Where data is transferred outside the UK or EEA — for example to Groq, or to Google or Cloudflare's US infrastructure — we rely on one or more of the following transfer mechanisms approved under UK GDPR:

• The UK International Data Transfer Agreement (IDTA), or the UK Addendum to the EU Standard Contractual Clauses.
• The European Commission's Standard Contractual Clauses (SCCs).
• The UK Extension to the EU–US Data Privacy Framework, where the receiving organisation is certified.

Copies of the relevant transfer safeguards are available on request by emailing [email protected].

6. How long we keep it

• Audio: kept on your device until you delete the recording or the app. Never stored elsewhere.
• Transcripts and AI notes: kept in your Firebase Firestore document until you delete the recording, delete your account, or sign out and explicitly clear local data.
• Account information: kept until you delete your account.
• Crash reports: kept by Firebase Crashlytics for 90 days by default, then deleted.
• Analytics events: kept by Firebase Analytics for 2 months by default, then aggregated and the raw user-level data deleted. User-property data (subscription tier, etc.) may persist for as long as your account is active.
• Subscription receipts: kept as long as required by Apple's StoreKit and applicable tax law (typically up to 7 years for VAT records).

7. Your rights

Under the UK GDPR you have the right to:

• Access the personal data we hold about you
• Correct inaccurate data
• Delete your data ("right to be forgotten")
• Restrict how we process your data
• Object to processing based on legitimate interests
• Port your data — request a copy in a machine-readable format
• Withdraw consent at any time where processing is based on consent
• Complain to the UK Information Commissioner's Office (ico.org.uk) if you believe we have mishandled your data

To exercise any of these rights, email [email protected]. We aim to respond within 30 days.

8. Deleting your account and data

You can delete individual recordings and notes within the app at any time. To delete your entire account, including all transcripts and notes in our cloud:

1. Email [email protected] from the email address associated with your account, or
2. Open Settings inside the app and tap Sign Out, then delete the app from your device.

Account deletion via email is irreversible. Cloud data is permanently removed within 30 days of the request.

Note that crash reports already received by Firebase Crashlytics may persist for up to 90 days as part of normal Firebase retention.

9. Children

Wispo is not intended for children under 13 (or the equivalent minimum age in your jurisdiction — 16 in much of the EU, 13 in the UK). We do not knowingly collect data from children. If you believe a child has used the app, contact [email protected] and we will remove their data.

10. Security and data breaches

We use HTTPS for all network connections, Apple's standard secure storage for on-device data, and Firebase's authentication and security rules to ensure your cloud data is only accessible to you (and to us when you contact support). Crash reports and AI requests are transmitted over TLS.

No system is completely secure. If, despite our safeguards, a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the UK Information Commissioner's Office within 72 hours of becoming aware of it, as required by Article 33 of the UK GDPR. Where the breach is likely to result in a high risk to you, we will also notify you directly without undue delay, in line with Article 34.

If you believe your account has been compromised, contact [email protected].

11. Cookies, analytics, and tracking

The Wispo iOS app does not use cookies. It contains the following third-party SDKs:

• Google Firebase (Auth, Firestore, Crashlytics, Analytics) — described in §2.4, §2.5, §2.6 and §2.7 above.
• WhisperKit — bundled OpenAI Whisper inference engine for on-device transcription. Runs entirely locally and makes no network calls of its own.
• Google Sign-In — only loaded when you choose Sign in with Google.

Firebase Analytics is used for product-improvement analytics in the limited form described in §2.7 — recording the lifecycle, subscription, and recording-flow events listed there. The app does not contain any other analytics SDK (no Mixpanel, no Amplitude, no Segment, no Facebook SDK), no advertising identifier collection, no cross-app tracking, and no IDFA prompting.

The Wispo marketing website (wispo.co.uk) is a static site hosted on Cloudflare Pages. It does not set tracking or advertising cookies and is not instrumented with website analytics. Cloudflare may set strictly-necessary cookies for security and bot-protection purposes; these are required to deliver the site and are not used for tracking or profiling.

12. Automated decision-making

We do not make decisions about you that produce legal or similarly significant effects using purely automated means. AI-generated notes are a productivity feature; they do not determine your access to services, eligibility for any product, or any other outcome with legal effect. You remain in control of how you use them.

13. Changes to this policy

We may update this policy as the app evolves. Material changes will be announced inside the app on next launch. Continued use after a material change means you accept the updated policy. The "Last updated" date at the top of this page reflects the most recent change.

14. Contact and complaints

For any privacy question, data request, or complaint, email [email protected]. We aim to respond within 30 days.

If you are not satisfied with our response, you have the right to lodge a complaint with a data protection supervisory authority. In the United Kingdom this is the Information Commissioner's Office (ico.org.uk, +44 303 123 1113). If you are based in the European Economic Area, you may lodge a complaint with the supervisory authority in your country of residence — a directory is available at edpb.europa.eu.