Privacy Policy

Table of Contents
    1.    Definitions
    2.    Scope
    3.    Information We Collect
    4.    How We Use Information
    5.    Legal Bases for Processing (EEA/UK)
    6.    Payments, Trials, and Subscriptions
    7.    Cookies, Analytics, Error Monitoring, and Advertising
    8.    AI Features and Interactive Tools
    9.    How We Share Information
    10.    Your Rights and Choices
    11.    Data Retention
    12.    International Data Transfers
    13.    Children’s Privacy
    14.    Changes to This Privacy Policy
    15.    Contact Information

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1. Definitions

For purposes of this Privacy Policy:

“Personal Data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual or household.

“Processing” means any operation performed on Personal Data, including collection, use, storage, disclosure, analysis, transfer, or deletion.

“Controller” means the entity that determines the purposes and means of processing Personal Data.

“Processor” or “Service Provider” means a third party that processes Personal Data on our behalf.

“Cookies” means cookies and similar tracking technologies, such as pixels, SDKs, local storage, and tags.

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2. Scope

This Privacy Policy applies to Personal Data we collect when you:
    •    visit our websites;
    •    use our web or mobile applications;
    •    register for, purchase, start a trial of, or subscribe to our Services;
    •    complete assessments, quizzes, tests, surveys, or self-discovery tools;
    •    use AI-powered chat, assistants, agents, generators, or similar features;
    •    contact us for support, billing, or other inquiries; or
    •    otherwise interact with us online.

This Privacy Policy does not apply to third-party websites, applications, or services that are not operated by us, even if they are linked from our Services.

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3. Information We Collect

We may collect the following categories of information, depending on the Service you use and how it is configured.

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3.1 Information You Provide to Us

We may collect information that you provide directly, including:
    •    your name;
    •    email address;
    •    account login credentials or authentication identifiers;
    •    billing-related information;
    •    customer support messages and correspondence;
    •    survey responses, feedback, or other content you submit; and
    •    any other information you choose to provide when using the Services.

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3.2 Account and Subscription Information

If account functionality is enabled, we may collect and process:
    •    account ID or internal user identifier;
    •    subscription or purchase status;
    •    plan type;
    •    trial status;
    •    renewal and cancellation status;
    •    access permissions;
    •    saved settings and preferences; and
    •    customer support and service history.

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3.3 Product Usage and Content Data

Depending on the product, we may collect and process:
    •    responses to tests, quizzes, assessments, or questionnaires;
    •    scores, classifications, summaries, reports, and result history;
    •    progress data and completion status;
    •    user-generated content;
    •    feature interactions;
    •    saved items, favorites, or history; and
    •    content necessary to provide the product experience you request.

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3.4 AI and Interactive Feature Data

If you use AI-powered or interactive features, we may process:
    •    prompts, messages, instructions, uploads, or other inputs you submit;
    •    AI-generated outputs shown to you;
    •    conversation history, where chat history or syncing is enabled;
    •    metadata such as timestamps, selected tools or agents, usage counts, and feature events; and
    •    moderation, abuse-prevention, or safety signals.

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3.5 Payment and Transaction Data

We and our payment providers may process data relating to your transactions, including:
    •    payment status;
    •    amount and currency;
    •    transaction identifiers;
    •    tokenized customer or payment method identifiers;
    •    subscription status;
    •    billing country, state, or region; and
    •    refund, chargeback, dispute, or fraud-prevention information.

We do not store full payment card numbers or card security codes. Those are handled by our payment processors under their own security and compliance frameworks.

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3.6 Technical, Device, and Log Data

We may automatically collect:
    •    IP address;
    •    device type and identifiers;
    •    browser type;
    •    operating system;
    •    language settings;
    •    approximate location derived from IP address;
    •    time zone;
    •    referring URLs;
    •    pages viewed, clicks, and navigation paths;
    •    crash reports, performance metrics, and diagnostic information; and
    •    fraud-prevention and security logs.

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3.7 Cookies and Similar Technologies

We may use cookies and similar technologies for:
    •    essential site and app functionality;
    •    authentication and session management;
    •    payment flow support;
    •    analytics and performance measurement;
    •    personalization; and
    •    advertising, retargeting, and attribution, where permitted.

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4. How We Use Information

We may use Personal Data for the following purposes:

 

4.1 To Provide and Operate the Services

We use Personal Data to:
    •    provide access to websites, apps, and product features;
    •    process assessments, generate results, and display reports;
    •    power AI, chat, and interactive product functionality;
    •    authenticate users and maintain accounts;
    •    process purchases, trials, and subscriptions; and
    •    provide customer support.

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4.2 To Maintain, Improve, and Develop the Services

We use Personal Data to:
    •    understand how users interact with our Services;
    •    troubleshoot bugs, crashes, and performance issues;
    •    improve usability, quality, and feature design;
    •    develop new products, features, or commercial offerings; and
    •    conduct internal analytics, testing, and product research.

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4.3 For Billing, Payments, and Subscription Management

We use Personal Data to:
    •    process one-time purchases and recurring subscriptions;
    •    manage trials, renewals, cancellations, and account access;
    •    provide billing communications and receipts;
    •    handle refunds, disputes, and chargebacks; and
    •    detect fraud and misuse in connection with billing.

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4.4 For Security and Abuse Prevention

We use Personal Data to:
    •    secure our Services, systems, and infrastructure;
    •    detect and prevent fraud, bots, unauthorized access, scraping, abuse, and policy violations;
    •    investigate suspicious activity; and
    •    enforce our Terms and other policies.

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4.5 For Communications

We use Personal Data to:
    •    respond to your requests, questions, and support inquiries;
    •    send transactional communications, such as receipts, access emails, service messages, and important updates;
    •    send marketing communications where permitted by applicable law or where you have consented; and
    •    manage customer relationships.

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4.6 For Legal, Compliance, and Business Purposes

We use Personal Data to:
    •    comply with legal, tax, accounting, and regulatory obligations;
    •    respond to lawful requests from courts, regulators, and law enforcement;
    •    protect our rights, property, personnel, users, and business operations; and
    •    support audits, corporate transactions, financing, and internal governance.

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5. Legal Bases for Processing (EEA/UK)

If you are located in the European Economic Area or the United Kingdom, we process your Personal Data under one or more lawful bases recognized by the GDPR and UK GDPR, including:
    •    Performance of a contract: where processing is necessary to provide the Services you requested;
    •    Legitimate interests: where processing is necessary for our legitimate interests, such as operating, securing, improving, and supporting the Services, provided those interests are not overridden by your rights and freedoms;
    •    Legal obligation: where processing is necessary to comply with legal or regulatory requirements; and
    •    Consent: where required by law, including for certain cookies, tracking technologies, or marketing activities.  

Individuals in the EEA and UK may have rights that include the right to be informed, access, rectification, erasure, and, depending on the circumstances, restriction, objection, and data portability. These rights are recognized under the GDPR and UK GDPR.  

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6. Payments, Trials, and Subscriptions

 

6.1 Payment Providers

Payments may be processed by third-party payment providers, including Stripe and other providers we may enable from time to time depending on product, geography, platform, or commercial testing.

Our payment providers process payment information in accordance with their own privacy notices, terms, and compliance requirements.

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6.2 What We Receive

We typically receive limited payment-related and subscription-related information, such as:
    •    whether a payment succeeded or failed;
    •    transaction reference information;
    •    tokenized customer identifiers;
    •    subscription start and end dates;
    •    renewal status;
    •    billing region; and
    •    refund or dispute status.

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6.3 Trials, One-Time Purchases, and Auto-Renewing Subscriptions

Depending on the product, we may offer:
    •    one-time purchases;
    •    free or discounted trials;
    •    subscription plans that renew automatically unless canceled before the applicable renewal date; and
    •    other promotional billing flows.

Commercial terms, including pricing, billing frequency, renewals, cancellations, and refund rules, are governed by the applicable Terms, checkout disclosures, or subscription terms presented to you at the time of purchase.

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7. Cookies, Analytics, Error Monitoring, and Advertising

 

7.1 Cookies and Similar Technologies

We use cookies and similar technologies to operate the Services, remember your preferences, analyze usage, improve performance, secure our systems, and support advertising or measurement activities where applicable.

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7.2 Analytics

We may use analytics services, including Google Analytics and similar tools, to understand traffic and usage patterns, measure conversions, and improve our products.

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7.3 Error Monitoring and Diagnostics

We may use tools such as Sentry and similar diagnostic services to identify errors, investigate incidents, and improve product stability and performance. We aim to limit the inclusion of sensitive information in monitoring tools and to apply masking or filtering where reasonably feasible.

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7.4 Advertising and Attribution

Where we engage in advertising, retargeting, or campaign measurement, we may use third-party advertising or attribution tools that process cookie identifiers, device identifiers, event data, and related metadata, subject to applicable law and your choices.

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7.5 Cookie Choices

You may be able to manage cookies and similar technologies through:
    •    your browser or device settings;
    •    our consent banner or privacy settings interface, where available; and
    •    platform-level privacy controls.

Please note that disabling certain technologies may affect the availability or functionality of some features.

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8. AI Features and Interactive Tools

 

8.1 How AI Features Work

Some of our Services may include AI-powered functionality, such as chat, assistants, generators, agents, recommendations, or automated outputs. To provide these features, we may send prompts, messages, or other inputs to third-party AI providers or supporting infrastructure providers.

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8.2 Storage of AI Interactions

Where the relevant Service includes history, account sync, saved conversations, or continuity features, we may store copies of:
    •    messages or prompts you submit;
    •    outputs generated for you;
    •    related metadata; and
    •    associated account and usage information.

We do this to provide the requested functionality, such as restoring conversations, displaying history, enabling saved items, or improving service operations.

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8.3 Use Restrictions

AI features are not intended for emergency use, medical diagnosis, legal advice, financial decision-making, or other high-risk purposes unless explicitly stated otherwise.

Please do not submit passwords, full payment card data, government-issued identification numbers, highly sensitive health data, or other information that you do not want processed through AI-enabled systems.

 

8.4 Abuse Prevention and Safety

We may review, monitor, or analyze usage of AI features, including by automated means, to maintain safety, prevent abuse, detect fraud, and enforce our Terms and policies.

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9. How We Share Information

We may share Personal Data as follows:

 

9.1 Service Providers and Vendors

We may share information with vendors and service providers that help us operate the Services, including providers of:
    •    cloud hosting and infrastructure;
    •    authentication;
    •    analytics;
    •    error monitoring;
    •    customer support;
    •    billing and payment processing;
    •    subscription management;
    •    email delivery;
    •    security and fraud prevention;
    •    advertising and attribution; and
    •    AI and content processing tools.

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9.2 Corporate Affiliates and Related Companies

We may share information with our affiliates, subsidiaries, parent entities, and other companies under common control where reasonably necessary for internal administration, product operations, support, analytics, security, billing, legal compliance, or business development.

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9.3 Legal and Compliance Disclosures

We may disclose Personal Data where we believe in good faith that doing so is necessary to:
    •    comply with applicable law, regulation, legal process, or governmental request;
    •    enforce our contracts and policies;
    •    detect, prevent, or address fraud, security, or technical issues; or
    •    protect the rights, property, safety, and security of the Company, our users, or others.

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9.4 Business Transfers

We may share or transfer Personal Data in connection with an actual or proposed merger, acquisition, financing, asset sale, reorganization, bankruptcy, or similar corporate transaction.

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9.5 With Your Direction or Consent

We may share your information where you request, direct, or consent to the disclosure.

We do not sell Personal Data for money. If any activity we conduct constitutes “sharing” or targeted advertising under applicable privacy laws, we will honor legally required opt-out rights.

California privacy law recognizes consumer rights including the right to know, delete, correct, and opt out of certain “sale” or “sharing” practices as defined by law. The CPRA amended the CCPA and is enforced by the California Privacy Protection Agency.  

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10. Your Rights and Choices

Depending on your location and applicable law, you may have the right to:
    •    request access to Personal Data we hold about you;
    •    request correction of inaccurate Personal Data;
    •    request deletion of Personal Data;
    •    object to or request restriction of certain processing;
    •    withdraw consent where processing is based on consent;
    •    request data portability, where applicable; and
    •    opt out of certain advertising, profiling, or sharing practices, where applicable.  

 

To exercise any applicable privacy rights, please contact us at:

Email: info@insightway.org
Subject Line: Privacy Request

We may need to verify your identity before fulfilling your request. We may also deny or limit a request where permitted by law.

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If you are located in the EEA or UK, you may also have the right to lodge a complaint with your local supervisory authority.  

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11. Data Retention

We retain Personal Data for as long as reasonably necessary for the purposes described in this Privacy

 

Policy, including to:
    •    provide the Services;
    •    maintain accounts and subscription records;
    •    comply with legal, tax, accounting, and regulatory obligations;
    •    resolve disputes;
    •    enforce our agreements; and
    •    detect and prevent fraud and abuse.

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Retention periods vary depending on the nature of the data, the product involved, legal obligations, and operational needs.

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For example:
    •    billing and transaction records may be retained as required by law;
    •    diagnostic, log, and security data may be retained for a limited period as needed for operations, debugging, and security;
    •    account, usage, test, results, and chat history data may be retained while your account remains active or as needed to provide related features; and
    •    backup copies may persist for a limited time after deletion before being overwritten in the normal course of operations.

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12. International Data Transfers

We may process and store Personal Data in the United States and in other countries where we or our service providers operate.

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If you are located in the EEA, UK, or another jurisdiction with transfer restrictions, and your Personal Data is transferred to a country that does not provide the same level of legal protection, we will use appropriate safeguards where required by law, such as Standard Contractual Clauses or other recognized transfer mechanisms. The European Commission recognizes safeguards such as adequacy decisions and Standard Contractual Clauses for international transfers.  

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13. Children’s Privacy

Our Services are not intended for children, and we do not knowingly collect Personal Data from children in violation of applicable law.

If a Service is directed to a general audience, it is not intended for use by children under the age required by applicable law to provide valid consent on their own behalf. In the United States, the Children’s Online Privacy Protection Act (COPPA) imposes specific requirements when online services are directed to children under 13 or when an operator has actual knowledge it is collecting personal information from a child under 13.  

If you believe that a child has provided us with Personal Data in violation of applicable law, please contact us and we will take appropriate steps to investigate and, where required, delete the information.

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14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

When we do, we will post the updated version on the relevant Service and revise the “Last Updated” date above. If changes are materially significant, we may also provide additional notice where required by law, such as via email, in-product notice, or a website banner.

Your continued use of the Services after an updated Privacy Policy becomes effective means that the updated Privacy Policy will apply to your future use of the Services, to the extent permitted by law.

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15. Contact Information

Insightway Apps Inc.
16192 Coastal Highway
Lewes, DE 19958
United States

Email: info@insightway.org