Legal
Privacy Policy
Last updated: 2 November 2026
This policy is from LoWisa, ABN 83 225 418 294 ("LoWisa", "we", "us"). LoWisa is a desktop app and a mobile learning app, both with a built-in AI tutor. They are designed so that the most sensitive things - your code, your projects, your conversations with the tutor - stay on your device. This policy explains what small amount of data we do handle, why, and what control you have over it.
1.What we collect
We collect only what we need to run your account and improve the product:
- Account email. When you subscribe, we receive the email address you used at checkout (or, on app-store builds, the address you activate with). We use it to identify your account, to send one-time sign-in and deletion codes, and to respond to support requests.
- Device identifier (mobile app). The mobile app reads an identifier for the handset (Android's device ID, or on iPhone an identifier the app keeps on the phone) and sends it to our server, which stores only a hashed form of it, so your free trial and subscription can belong to your phone. It is not your advertising ID; the app does not read the advertising ID at all, and this identifier is never used for advertising or shared for tracking. Your sign-in record is kept on the phone in its secure storage (the Android Keystore or the iPhone Keychain).
- Learning progress (mobile app). Lesson progress, XP, streaks and achievements are backed up to your account so a new phone or the desktop app can pick up where you left off. If you register a display name, it appears with your XP on the public standings; without one you appear under an auto-generated pen name that cannot be traced back to you. Display names are letters and numbers only - symbols are removed so nothing can pass for a verification mark.
- Profile and community content (mobile app). If you use the Community, we store what you choose to publish: your profile picture and header picture, occupation, location (a short line you type yourself; the app never reads your phone's location), the lines you write about yourself, your website and links, your social handles, the cohorts you belong to, the messages you send in cohort channels and direct messages, your Clock it posts and the pictures and videos on them, your comments, reactions, reposts and saves, and who you follow. Profile details, public-cohort messages and Clock it posts are visible to other learners, and a Clock it post has a public web page; direct messages and private cohorts are visible to their participants. Whether your account holds an active subscription is shown to other learners as a blue mark beside your name. Pictures are stored on our servers and served from lowisa.dev. Unfold stories (the parts you write or speak, and your character) are visible only to your cohort. Before Clock it posts appear, an AI model reads them to keep spam and abuse out (Anthropic, with OpenAI as a fallback).
- Pictures, videos and files in chats (mobile app). A picture, video, PDF or other file you send in a cohort chat or a direct message, including a photo you take with the camera from the chat, is uploaded to our servers so the people in that chat can download it. Before a picture is shared, we remove the hidden details cameras add to it, such as where it was taken and the camera model; from a video we remove the place it was recorded. Chat files are kept on our servers for 7 days and then deleted; the phones that received them keep their own copies. When you post a link, our server fetches that page once to show a preview card, kept for 7 days. If you ask Lo about a picture in a chat, the picture is sent to OpenAI to answer, and the answer is not kept.
- Your voice (only when you choose to speak). When you speak instead of typing - for example a spoken part in Unfold, a lecture you record in the Study Kit, or talking to Lo - the recording is sent to a speech-to-text provider (OpenAI, or ElevenLabs for the desktop app's Live Guide) to be turned into text. Other recordings are not kept. A spoken Unfold part is kept on our servers for 7 days so your cohort can play it back, then deleted; the words stay with the story. Spoken answers to the tutor, in interviews and in speaking practice are turned into text by your phone's own speech service (Google on Android, Apple on iPhone), which may use its maker's servers; LoWisa receives only the text. You can always type instead.
- Voice messages (mobile app). A voice message you record in a chat is sent to the people in that chat. The recording is kept on our servers for 7 days so they can play it, then deleted. To show its words, a voice message of up to a minute is turned into text by ElevenLabs when it is sent; a longer one only when someone in the chat asks for the transcript. The transcript stays with the message, like a written message. Translating a transcript sends its text to OpenAI; the translation is not kept.
- Live rooms (mobile app). When you join a live audio room in a cohort, the audio of the people on the stage is carried live to the listeners through Amazon Interactive Video Service (IVS). Rooms are not recorded: when a room ends, its audio is gone. Amazon IVS receives your pen-name id, your display name and your role in the room. What stays is the room's card in the cohort channel (its title, how long it ran, how many joined, and the faces of some who joined). If a host turns on live captions, the host's speech is sent from the host's phone to ElevenLabs to be turned into text for the listeners; captions are not saved, except that the last minute of them is attached to a report if someone reports the room. If you ask Lo a question in a room, the question is answered by OpenAI and spoken by ElevenLabs, and that answer is not kept after the room ends.
- Notifications (mobile app). To send notifications to your phone (a reply, a direct message, a mention, activity on your Clock it posts), the app registers a push token with Google Firebase Cloud Messaging and sends it to us with your phone's time zone and language. Notifications go from our server through Google Firebase and, on iPhone, Apple's push service. A notification carries the sender's display name and picture and the first 140 characters of the message, so the text passes through those services to reach your phone. You can turn notifications off in your phone's settings at any time. We remove a push token when you sign out, when Google says it is no longer valid, or after 270 days unless the app renews it.
- Sharing into LoWisa (mobile app). When you share a link, text, pictures, videos or PDFs from another app to LoWisa, the app reads only what you shared and keeps a copy on the phone for at most a day. Nothing is uploaded until you pick a chat and tap Send; it is then sent like any other chat message.
- Camera (mobile app). A photo of a page or a problem for a lesson, the Study Kit or Fix it is read on your phone and only the words are sent. A photo you send in a chat, or one you convert to a PDF or Word file in the Career tools, is uploaded for that purpose. The QR code scanner reads only the code.
- Credit and usage records. For managed subscriptions, our backend keeps a ledger of credit grants, deductions, and balances so we can meter AI usage fairly and resolve billing questions. The mobile app also sends one anonymous count a day of which parts of the app were opened, with no account or device identifier.
- Store purchases (mobile app). When you buy a plan or credits in the app, Google Play or the App Store handles the payment. We check the purchase with the store and keep the product, the order or transaction number and the purchase status with your account.
- Feedback submissions. If you choose to send feedback from inside the app or by email, we keep what you send us.
- Website analytics (only if you allow them). If you choose Allow analytics in the cookie settings on the lowisa.dev home page, PostHog records which pages you view and what you click (for example, which download buttons), a replay of how the page was used with anything you type hidden, and your browser, device and approximate location, under a random visitor ID. Until you allow it, nothing is collected or stored. You can change your choice at any time (section 6).
- Error reports. If the desktop app crashes, it sends the error message, the technical stack trace, the app version and the platform to us so we can fix the bug. No account, email, code or project content is included, and the reports are deleted after 60 days. The mobile app does not send crash reports.
2.What stays local on your machine
The following never leaves your computer as far as LoWisa's own services are concerned:
- Your code and projects. LoWisa opens folders on your disk. We do not upload, index, or store your repositories on our servers.
- Your chat history with the tutor. Conversations are stored locally on your machine.
- Your API keys. If you use BYOK (bring your own key), your provider keys are stored locally and sent only to the AI provider you configured - never to LoWisa's servers.
- Your photos and files on the phone. The mobile app sees only the pictures, videos and files you pick or share to it. It never reads your photo library, contacts, calendar or location, and it saves to your photos only when you tap Save.
One important nuance: when you ask the tutor a question, the relevant context (for example, the code you are asking about) is sent to the AI model provider that answers the request - see the subprocessor table below. That is how any AI assistant works. We do not retain that content on LoWisa's servers.
3.Why we use your data (legal basis)
Where the EU or UK General Data Protection Regulation (GDPR) applies, these are the legal bases we rely on:
| Purpose | Data | Legal basis |
|---|---|---|
| Running your account and the app | Account email, device identifier, learning progress, what you ask the tutor, your voice when you choose to speak, profile and community content, chats, live rooms | Contract: we need it to provide the service you asked for |
| Payments, plans and credits | Purchase records, subscription status, credit ledger | Contract, and legal obligation for accounting and tax records |
| Notifications on your phone | Push token, notification content | Consent: your phone's notification permission, which you can turn off at any time |
| Keeping LoWisa safe and fair | Checks of Clock it posts, reports, the free-trial marker, server logs | Legitimate interests: preventing spam, abuse and misuse of free credits |
| Fixing and improving LoWisa | Desktop error reports, the app's anonymous daily usage count, feedback | Legitimate interests: finding bugs and learning which parts are used |
| Answering support and privacy requests | Your messages and the details needed to answer them | Legitimate interests, or legal obligation when you exercise a privacy right |
| Website analytics | As described in section 1, only if you allow them | Consent, which you can withdraw at any time in Cookie settings |
Where we rely on legitimate interests, you can object (section 9). Withdrawing consent does not affect what was done before you withdrew it.
4.Subprocessors
We use a small number of service providers to operate LoWisa:
| Provider | Purpose | Data involved |
|---|---|---|
| OpenAI | AI model inference and speech-to-text | Prompts and code context you send to the tutor; your voice when you choose to speak, to turn it into text; a chat picture you ask Lo about; a voice-message transcript you ask to translate; questions to Lo in a live room; reported content, to help review it; Clock it posts when the first check is unavailable |
| Anthropic | AI model inference | Prompts and code context you send to the tutor; Clock it posts, checked before they appear |
| AI model inference | Prompts and code context you send to the tutor | |
| Google Firebase Cloud Messaging | Notifications to your phone | Push token; the notification's sender name, picture and the first 140 characters of the message |
| Apple Push Notification service | Notifications to iPhone (through Firebase) | The same notification content, on iPhone only |
| xAI | AI model inference | Prompts and code context you send to the tutor |
| ElevenLabs | Tutor voice narration and speech-to-text | The tutor sentences to be spoken aloud; in the desktop app's Live Guide, your voice when you talk to Lo, to turn it into text; voice messages and video sound in chats, to show their words; a live room host's speech when captions are on |
| Amazon Polly (Amazon Web Services) | Tutor voice narration | The tutor sentences to be spoken aloud (only the sentences, never your account details) |
| Meta (Muse Spark models) | Exam marking, mastery lessons and a safety check of the tutor's words in exam review | The exam pages and answers you hand in for marking; the tutor's draft lines, checked before you see them |
| Polar.sh | Payments and subscriptions (web and desktop) | Checkout email, billing details, subscription status |
| Google Play / Apple App Store | Purchases made inside the store apps | Payment handled entirely by the store; we receive a purchase receipt, never your card details |
| Amazon Web Services | Backend hosting, email delivery, downloads and website delivery; live audio rooms (Amazon IVS) | Account email, credit ledger, usage records, learning-progress backup, profile and community content (including pictures, videos, files and voice messages), spoken Unfold parts (kept 7 days), sign-in code emails, standard server logs (IP address, request metadata); in live rooms, the live audio of the speakers and each person's pen-name id, display name and role (nothing recorded) |
| ipapi.co | Approximate city and country for sign-ins to demonstration accounts we operate | Only the IP addresses that sign in to those accounts, never ordinary accounts |
| PostHog | Website analytics, only if you allow them | Page views, clicks and page replays on lowisa.dev (typed text hidden), browser, device and approximate location |
Each provider processes data under its own terms and only for the purpose listed. We do not sell your data to anyone.
5.Where your data is processed
LoWisa is an Australian business, and most of our providers are overseas, so your data is processed outside your country:
- United States. Our servers and stored data are with Amazon Web Services in its US East (Virginia) region. The AI and voice providers (OpenAI, Anthropic, Google, xAI, Meta, ElevenLabs and Amazon Polly) process requests mainly in the United States, and PostHog processes website analytics there.
- Worldwide networks. The website and downloads are delivered through Amazon's servers around the world, notifications through Google Firebase and Apple's push service, and payments by Polar, Google Play and the App Store in the countries where they operate.
To protect your data when it leaves your country, we use providers whose data processing terms commit them to protect it, including the European Commission's Standard Contractual Clauses (with the UK addendum) for data from the EU and the UK. For Australians, we take reasonable steps to make sure overseas providers handle personal information in line with the Australian Privacy Principles. Email us for more detail about these safeguards.
6.Cookies and storage on the website
The lowisa.dev home page asks before it uses analytics. This is what the website stores on your device:
| Name | Purpose | How long |
|---|---|---|
| lowisa-cookie-choice | Local storage. Remembers your choice in cookie settings. Strictly necessary, so it is stored without asking. | Until you change your choice or clear the site's data |
| ph_… and __ph_… | PostHog cookie and local storage, only if you allow analytics: a random visitor ID, session details and your choice, so visits and clicks can be counted. | The cookie lasts up to 1 year; everything is removed as soon as you choose No thanks |
| ph_… (session storage) | PostHog, only if you allow analytics: tells one browser tab from another. | Until you close the tab |
| lwct, lwrt | Local storage on shared game and riddle pages (lowisa.dev/s/…): a random code so each browser counts once. | Until you clear the site's data |
Changing your choice. Select Cookie settings at the bottom of the lowisa.dev home page at any time. No thanks stops analytics straight away and removes what PostHog stored. You can also clear the site's data in your browser's settings.
The guide, help and support pages store nothing. The privacy, terms and account deletion pages load their typeface from Google Fonts, which receives your IP address but sets no cookies. The videos under "Watch LoWisa at work" on the home page come from YouTube in its privacy-enhanced mode, which sets no cookies until you play a video; when you play one, YouTube may store its own data under Google's privacy policy.
7.Data retention
- Account and billing records are kept while your subscription is active, and afterwards only as long as needed for accounting and legal obligations.
- Credit and usage ledger entries are kept to support billing accuracy and dispute resolution.
- Profile and community content is kept while your account exists, and removed when you delete the account (section 8). A cohort you created is handed to its next member when you leave or delete, so the group keeps its history. Chat messages are kept with their chat.
- Pictures, videos, files and voice messages sent in chats are deleted from our servers after 7 days. Clock it pictures and videos and your profile and header pictures are kept until you remove them or delete your account.
- Voice recordings are not kept, except a spoken Unfold part and a voice message, each kept for 7 days and then deleted; what was said stays as text with the story or the message.
- Live rooms are never recorded. A room's details are deleted within 3 days of it ending, apart from its card in the cohort channel.
- Reports. The fact that a post was reported, and why, stays with that post. What is sent for review (the reported content, and for a live room the last minute of captions, if captions were on) is kept for 120 days after it is reviewed.
- Push tokens are removed when you sign out, when the token stops working, or after 270 days unless the app renews it. The list of notifications in the app keeps each one for 60 days.
- Feedback and error reports are kept as long as they are useful for improving the product, then deleted; desktop error reports are deleted after 60 days.
- Everything local (code, projects, chat history, keys) is yours - deleting it is entirely under your control, and uninstalling LoWisa removes the app's local data directories.
8.Deleting your account
You can delete your LoWisa account and its data yourself, without asking us:
- In the mobile app: Profile → This phone → Delete my account. If your plan is billed by Google Play or the App Store, the app deletes the account only once that subscription has ended: cancel it in the store, and you can delete the account when the period you paid for is over.
- On the web, at any time (even with the app uninstalled): lowisa.dev/delete-account.html. We email a one-time code to the address on the account, and the code confirms the deletion. This page deletes the account whether or not a subscription is still running.
Deletion removes your email address, your device activations and sign-in sessions, your push tokens, your cloud learning-progress backup, your entry on the public standings, your profile (picture, header picture, occupation, location, about, links, handles), your Clock it posts with their words, pictures and videos, what you learned, saved and followed, and your cohort memberships (a cohort you created passes to its next member, or closes if you were alone in it). Comments you left on other people's posts and messages you sent in cohorts and direct messages, including the words of your voice messages, stay in their threads under an auto-generated pen name, with no picture, mark or link back to you; the recordings themselves are deleted within 7 days of being sent in any case. It is immediate and cannot be undone. Two things are retained: an anonymous marker that a free trial was used on the device (so deletion cannot be used to farm unlimited trials), and the pseudonymous financial ledger of past credit grants and deductions, kept for accounting - after deletion those records no longer connect to any email address or person. Any credits left on the account, including top-ups, are lost. Deleting your account does not cancel a subscription; cancel it with your payment provider (Polar's customer portal, Google Play, or the App Store) so it does not renew.
9.Your rights
Depending on where you live, you have the right to:
- access the personal data we hold about you and get a copy;
- correct data that is wrong or incomplete;
- erase your data (deletion is self-service, see section 8);
- restrict how we use your data while a question about it is being settled;
- port your data: receive it in a common machine-readable format, or have it sent to another service;
- object to uses based on our legitimate interests;
- withdraw consent at any time, for example through Cookie settings on the website or your phone's notification settings;
- complain to a data protection authority (section 10).
To use any of these rights, email support@lowisa.dev from the address on your account. We may ask you to confirm it is you, and we answer within one month. Cancelling your subscription is always available through the app or your payment provider's portal.
10.Complaints
If you are unhappy with how we have handled your personal information, email support@lowisa.dev with "Privacy complaint" in the subject and tell us what happened. We will confirm we received it within 7 days, look into it, and send you our answer and what we will do about it within 30 days.
If you are not satisfied with our answer, you can complain to a regulator:
- Australia: the Office of the Australian Information Commissioner (OAIC), at oaic.gov.au.
- European Union: the data protection authority in the country where you live or work, or where you think the problem happened.
- United Kingdom: the Information Commissioner's Office (ICO), at ico.org.uk.
- Elsewhere: your local data protection authority.
You can also go to a regulator first; we would still like to hear from you so we can put it right.
11.Children
LoWisa is for people aged 13 and over. If you are under 13, do not use LoWisa. Where the law in your country requires a parent's or guardian's consent for someone older than 13 to use an online service (for example, under 16 in some EU countries), a parent or guardian must agree before you use LoWisa. We do not knowingly collect personal information from children under 13; if you believe a child under 13 has given us personal information, contact us and we will delete it.
12.Changes to this policy
If our practices change, we will update this page and the "Last updated" date above. Meaningful changes will be called out rather than buried.
13.Contact
LoWisa, ABN 83 225 418 294. Questions about privacy at LoWisa: support@lowisa.dev.