Privacy Policy

Welcome to Wissero (“we,” “us,” or “our”). Wissero GbR operates the Wissero platform (app.wissero.com) and related services. We are committed to protecting your personal information and your right to privacy in strict accordance with the General Data Protection Regulation (GDPR).

This Privacy Policy explains what data we collect, on what legal basis, how we use it, and your rights as a data subject.

The data controller responsible for your personal data is:
Wissero GbR
Mainstraße 5, 95444 Bayreuth, Germany
Email: hello@wissero.com

Wissero is not required to appoint a Data Protection Officer under Art. 37 GDPR. For all data protection enquiries, please contact us directly at the address above.

We collect information that you provide to us, information collected automatically, and information generated by your use of the platform.

A. Information You Provide
• Account Data: Name, email address, and password.
• Onboarding Data: Your learning goals, interests, and preferences collected during onboarding to personalize your experience.
• Communication: Information you provide when contacting us for support via our /contact page or email.

B. Usage and Learning Data
• Learning Metrics: Activity completion, assessment results, vocabulary and grammar mastery, and time spent learning.
• Interaction Logs: We log micro-events (such as hints used or audio replayed) to improve our pedagogy and debug technical issues.

C. User-Generated Content and StudyLab Materials
When you use StudyLab, we collect the files, documents (e.g., PDFs), and texts you upload to create Study Spaces.
• Public Study Spaces: Derivative educational metadata (such as extracted topics and vocabulary lists) will be visible to other users. Your raw uploaded materials are not accessible to others.
• Shared-Private Study Spaces: Your uploaded source materials are accessible in read-only mode to the individuals you explicitly invite.

D. Information Collected Automatically
When you visit our platform, we automatically collect certain technical information (e.g., device type, browser, anonymized IP address) for security and performance purposes. For details on cookie-based tracking, please refer to our Cookie Policy.

Voice Processing
When you use voice recording features for pronunciation exercises, your audio recordings are processed via Microsoft Azure Speech Assessment to generate immediate pronunciation feedback. Audio recordings are retained on our servers for as long as your account remains active, so that your assigned teachers and course instructors can review and assess your pronunciation progress over time. Audio recordings are not used for any purpose beyond pedagogical assessment.
Audio recordings are deleted when you delete your account or upon your explicit request. They are not deleted automatically at any earlier point.

StudyLab and AI Tutoring
When you chat with the AI Tutor or upload documents to StudyLab and trigger analysis, the relevant text is transmitted to our AI sub-processor for processing. We currently use the Google Gemini API as our primary AI sub-processor for these features. We may engage additional or alternative AI service providers in the future, in which case this policy will be updated to reflect the change before it takes effect.

Pedagogical Optimization
We use Langfuse for AI tracing to monitor, evaluate, and improve the quality and accuracy of AI-generated educational responses. Only interaction metadata (such as response quality scores) is used for this purpose, not the content of your uploaded materials.

Zero-Training Guarantee
We use paid, enterprise-tier API services for all AI features. We have Data Processing Agreements (DPAs) in place with our AI sub-processors ensuring that your personal data, chat inputs, voice recordings, and uploaded StudyLab documents are never used to train or improve their foundational AI models. Data transmitted to sub-processors is processed solely to provide the requested service.

To operate, monitor, and optimize the platform, we use the following third-party services:

• Google Analytics 4 (GA4) and Google Tag Manager (GTM): Used to understand how users interact with the platform. We have activated IP anonymization, meaning your IP address is shortened within the EEA before transmission.

• Hotjar: Used to visualize aggregate user behavior (e.g., click patterns) to identify usability issues. Hotjar processes pseudonymized data.

• DodoPayment: All payment processing is handled securely by DodoPayment. We do not store your full card details on our servers.

We do not sell your personal data. We share information with third-party service providers only to the extent necessary to operate the platform. All sub-processors are bound by Data Processing Agreements and are not permitted to use your data for their own purposes.

All core platform databases, user accounts, and uploaded StudyLab materials are hosted on servers located within the European Union (EU) / European Economic Area (EEA). Where a third-party sub-processor processes data outside the EEA, we ensure appropriate legal safeguards are in place, including EU Standard Contractual Clauses (SCCs).

If your Wissero account is provided or administered by an educational institution (“Institution”), that Institution acts as the Data Controller of your personal data, and Wissero acts as the Data Processor. In such cases:
• Your Institution may have administrative access to your learning metrics, progress reports, and account information.
• The data retention and deletion policies determined by your Institution’s Data Processing Agreement (DPA) with us will supersede the standard retention policies outlined in this document.
• Requests to exercise your GDPR rights may need to be directed to your Institution’s administrative contact.

We retain your account data, learning data, voice recordings, and Study Spaces for as long as your account is active. No personal data is deleted automatically while your account remains open.

If you delete your account or submit an explicit deletion request, your personal data and uploaded materials will be permanently erased from our active systems. Data previously transmitted to third-party AI sub-processors is subject to those providers’ own deletion timelines as governed by our Data Processing Agreements with them; these are typically 30 days or less from the date of transmission.

Exception: Payment records are retained for up to 10 years following the transaction in accordance with German commercial and tax law (§257 HGB, §147 AO), regardless of account deletion.

In accordance with the GDPR, you have the following rights regarding your personal data:
• Right of Access (Art. 15): You may request a copy of the personal data we hold about you.
• Right to Rectification (Art. 16): You may request correction of inaccurate or incomplete data.
• Right to Erasure (Art. 17): You may request deletion of your personal data under certain conditions.
• Right to Restrict Processing (Art. 18): You may request that we limit how we use your data.
• Right to Object (Art. 21): You may object to processing based on legitimate interests.
• Right to Data Portability (Art. 20): You may request that we transfer your data to another organization or directly to you.
• Right to Withdraw Consent (Art. 7(3)): Where processing is based on your consent (e.g., analytics cookies), you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, use the tools in your account dashboard or contact us at hello@wissero.com.

You also have the right to lodge a complaint with the competent data protection supervisory authority. The authority responsible for Wissero is:

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
Promenade 18, 91522 Ansbach, Germany
www.lda.bayern.de

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify registered users of material changes via email or a prominent in-platform notice at least 14 days before the changes take effect. The revised policy will always be available at wissero.com/privacy.

For questions, comments, or to exercise your data protection rights, please contact us:

Wissero GbR
Mainstraße 5, 95444 Bayreuth, Germany
Email: hello@wissero.com
Contact form: wissero.com/contact