Privacy Policy

Data controller

The Service is developed and operated by Darabos Group, a sole proprietorship (enkeltmandsvirksomhed) owned by David Pal, who is also the seller named on the App Store. Darabos Group is the data controller for the personal data described in this policy.

Postal address: Frederiksborggade 37, 1. tv, 1360 Copenhagen K, Denmark
CVR (Danish business registration number): 46690257
Email: info@rizzpond.app · Phone: +45 28 97 28 47

Within the Service, "Wink" refers to the artificial intelligence feature that reads conversations and writes suggested replies.

Your account

No registration is required. When the application first communicates with our server, an anonymous account is created automatically. That account consists of a random identifier to which no name, email address or telephone number is attached. Your daily allowance, your free scan and any subscription are associated with that identifier.

If you elect to use Sign in with Apple, Apple provides us with a stable identifier and, if you permit it, your email address or a Hide My Email relay address. We use this information solely to recognise you again, on the same device or another, so that your account, backup and subscription remain available to you. Signing in is not required in order to purchase Rizzpond+; a purchase is associated with your account identifier whether or not you are signed in. Signing in is required only to carry Rizzpond+ and your backup over to another device.

Data stored on your device

The following data is stored within the application on your device and is not transmitted elsewhere unless you create a backup (see Backups):

• Your quiz answers: the persons you usually text, your selected vibes, your spice, effort and humour settings, and the persona derived from them.
• Your texting style: what the application has learned about how you write, and any sample texts you have entered to teach it.
• The chats you have scanned, stored per contact so that Wink can take the conversation into account on a later occasion, and the replies you have saved.
• Whether you have indicated that a reply was successful, and what you have copied.

Deleting the application deletes all of this data from the device.

Consent before data leaves your device

Immediately after the welcome screen, the application displays its House rules, which you accept by selecting I agree. One of those rules reads: "Wink reads with OpenAI. Your chat goes through our server to OpenAI, only to write your replies." A separate screen then follows, titled Let Wink read your chats?, which names OpenAI and presents two buttons of equal prominence: Don't send and Send to OpenAI. No data is sent to OpenAI until you select Send to OpenAI; this applies equally within the application and through the Ask Wink shortcut. If you select Don't send, you may nevertheless complete the setup, and the question is presented again the first time you scan. You may withdraw your consent at any time under You → Account → Stop sending to OpenAI, after which no further data is sent.

Your decision is recorded on our server, and it is our server that gives effect to it: in the absence of a recorded consent, our server declines to read a screenshot or write a reply, irrespective of any instruction from the application. For each decision you make, we retain your account identifier, whether you gave or withdrew consent, the version of the wording you were shown, and the time, and no other data. A withdrawal is recorded as a separate entry rather than by erasing the earlier one, so that the record of each decision and its time remains accurate. These entries are deleted together with your account.

Smart scan: screenshot reading

When you select a screenshot, your device first recognises the text in it locally. The application then sends the screenshot itself, together with the lines recognised by your device and their position, to our server. Our server transmits them to OpenAI, whose vision model reads the conversation, identifying who wrote each message and which message awaits your reply. The result is returned to your device.

Our server retains the following data from a scan:

• A count of scans per day for your account (the limit is 40 per day on a free account and, with Rizzpond+, 500 per day and 10 per minute, as a safeguard against automated use), and whether your free scan has been used. In order to pace requests, the server also retains the time of each request until your next request made after one minute has elapsed, and all such records are deleted when you delete your account. If a read fails or cannot be used, the free scan is restored, and that fact is also recorded.
• Technical counts in our server logs: the number of text tokens used by the read, its duration and the model used. The image and the text are never logged.

Our server does not retain the screenshot, the recognised lines or the content that was read. These exist on our server only for the seconds required to respond to your request.

We do not create or store biometric identifiers or face geometry. A photograph contained in a screenshot is read as part of the image and is not retained.

If you allow the application full access to your photo library, it looks only for the most recent screenshot, and only when that screenshot was taken within the last two minutes, so that it can offer it to you on the Reply tab. That screenshot is displayed on your device and is not sent anywhere unless you tap Reply to this, after which it is handled exactly as a screenshot you selected yourself. The application does not read, upload or retain any other photograph in your library. You can withdraw this access at any time in your device's Settings.

Where the read meets a sufficient level of confidence, your device also asks our server to begin writing replies immediately, so that they are available when you tap. That request is described under Reply generation below. It is sent only when the device is ready to display those replies to you.

Reply generation

When you tap Reply, or when replies are written in advance of your tap as described above, the application sends the following data to our server, and our server sends it to OpenAI:

• The conversation, limited to its last 40 messages, and an indication of the message to which you are replying. Where you have pasted text instead of a screenshot, that text alone.
• The first name of the other person as it appears in the chat, so that the reply may use it naturally.
• Your settings for the reply: the person you are texting, your vibes and settings, your persona and the tone you selected.
• Your texting style and up to three of your own typed texts as examples, so that the reply reflects the way you write.

Our server retains the following data from a reply request:

• The replies written by Wink, so that, if your device submits the same request again, it receives the same answer without using a second request. Replies older than two days (one day for replies written in advance of your tap) are deleted the next time your account requests replies and, in any event, no later than 30 days after they were written; all of them are deleted when you delete your account.
• Your time zone, so that your daily allowance resets at midnight in your time zone rather than ours. It remains on our server and is not sent to OpenAI. The conversation you sent is not retained with it.
• One record per set of replies, stating the model used, your persona and vibes, the number of text tokens and the cost to us. No text from the conversation or the replies is included.
• Your daily count and your time zone.

OpenAI

Reading and writing are performed by models operated by OpenAI through its API. Your screenshot, the conversation and your settings reach OpenAI only through our server and never directly from your device, and OpenAI does not receive your name, email address or account identifier. Every request is sent with the API setting that instructs OpenAI not to store the exchange for later retrieval, together with a one-way hash of your account identifier that enables OpenAI to detect abuse without identifying you.

OpenAI processes this data under its own API terms and policies, which are available at openai.com/policies. Under those terms, OpenAI may retain API data for up to 30 days in order to monitor for abuse, and does not use it to train its models. We have not concluded a zero-data-retention agreement with OpenAI and accordingly make no commitment beyond those terms. OpenAI is established in the United States.

Use of artificial intelligence

All content written by Wink is generated by a machine-learning model. No person writes replies, no library of pre-written lines is used, and no one at Darabos Group reads your conversation in order to assist. We disclose this because the EU AI Act requires any provider of an interactive AI system to make clear to the persons interacting with it that it is such a system, and because you should be aware of it before you send another person a message you did not write yourself.

The following consequences apply:

• The output may be inaccurate. A model may misread who wrote what in a screenshot, fail to recognise humour or a warning sign, or produce text that appears appropriate but is received poorly. You should review every reply before using it.
• No automated decisions are made about you. We do not score, rank or profile you, and we do not make any automated decision that produces legal or similarly significant effects concerning you. The model generates text and performs no other function.
• Your chats are not used to train a model. We do not use your personal data to train large language models, and OpenAI does not do so under its API terms. Every request to OpenAI is also sent with the API setting that instructs it not to store the exchange for later retrieval.

Ask Wink from other applications

If you configure the Ask Wink shortcut (Action button or Back Tap), activating it takes a screenshot of the conversation displayed on your screen and sends it to our server, which reads it and writes replies in a single operation through OpenAI, in the same manner as a scan and a reply request within the application. The same consent requirement, allowances and limits apply, the screenshot is not retained, and the first reply is copied so that you may paste it. Ask Wink retains only the replies written, never the conversation it read. No data is sent unless you activate the shortcut, and no data reaches OpenAI before you have selected Send to OpenAI: in the absence of that consent, our server declines the request and the application asks for your consent first.

Rizzpond+ and payments

Payment is processed entirely by Apple. We do not have access to your card details, your bank details or your Apple ID password. Signing in is not required in order to purchase: the application provides Apple with your account identifier together with the purchase, so that the purchase is associated with that account. Upon purchase, Apple provides the application with a signed receipt, which our server verifies with Apple and links to your account. We retain the transaction identifier, whether the purchase is a live or a test purchase, and your account identifier. Whenever Rizzpond+ entitlement is relevant, our server asks Apple whether the subscription remains active, so that an expired or refunded subscription no longer unlocks Rizzpond+. A small number of accounts are granted Rizzpond+ manually for testing purposes; that list is maintained by account identifier.

Restore purchases operates without signing in. It transfers a subscription paid for by your Apple ID from a deleted account, or from an anonymous account, to the account you are currently using. A subscription belonging to a signed-in account remains with that account; to use it, you must sign in to that account.

The record of each verified purchase is held on our own server (transaction identifier, live or test, plan, date and your account identifier). Subscriptions are counted solely from that record, and no third-party subscription service receives your purchase data.

Backups

Backups are made only if you sign in with Apple. In that case, the application saves a single private backup to our server when you leave the application and whenever you tap Back up now. The backup contains your persona and quiz answers, your texting-style settings and reply preferences, your saved replies and your outcome notes. The other person's messages are removed from saved replies before upload, and your scanned chats and screenshots are never included. A backup is limited to 1 MB and retains your most recent 800 outcome notes; each new backup replaces the previous one. Restore from backup restores it to a device, and Check for a newer backup retrieves a backup saved from another device. These functions may be viewed and controlled under You → Account.

Anonymous usage events

For every account, the application sends our server short usage events recording: that the application was opened or closed and for how long; which screen was displayed and for how long; which quiz step was answered; that a scan was read or a reply was copied; and that the subscription screen was opened or closed and whether a purchase was made. An event consists of a fixed name and a small number of numerical values or fixed labels (for example, a screen name or a count). It never contains a message, a name, a screenshot or any text you wrote or received. Each event is linked to your account identifier, which enables us to count persons rather than taps and ensures that events are deleted when you delete your account. We use these events to identify where the application is unclear or slow and what requires correction. We do not use them to track you across other applications or websites or to build advertising profiles, and we do not sell them or share them with anyone. They are retained for 30 days (180 days for the named test accounts described in Test accounts).

The Service displays no advertising, contains no third-party trackers or analytics software, and does not use an advertising identifier. No personal data is sold or shared for marketing purposes.

Test accounts

This policy states that we retain no screenshots and no conversations. That statement applies to all users except a limited list of named test accounts, which at present comprises only the account of David Pal, the proprietor of Darabos Group. For those accounts, and only those accounts, additional data is recorded: their reads and replies are retained with names, telephone numbers, email addresses, links and addresses removed, together with timings and a record of what their application displayed and did (numerical values and fixed labels, never text). Their screenshots and raw reads are held in private storage only until they are transferred to the proprietor's computer, after which they are deleted from the server. No person is a test account unless named on that list, and the database itself refuses to store such reads, replies or files for any other account. Any person other than the proprietor will be asked for their agreement before being added. A test account is deleted in the same manner as any other account, together with its files and its log.

Usage limits and security measures

In order to keep the Service affordable and to prevent abuse, our server limits the size of every request and every screenshot, counts requests per account per minute and per day, and totals the daily cost of all requests combined. Free accounts share a daily total; once it is reached, free use is suspended until the following day. Rizzpond+ is not subject to that total, but only to a considerably higher safety total for the Service as a whole. In either case, the application informs you accordingly. The daily totals record an amount and a number of calls and are not linked to any account.

To prevent the automated creation of accounts in large numbers, the application also verifies once to our server, using Apple's App Attest, that it is the genuine Rizzpond application running on a genuine iPhone. Your iPhone generates a key that never leaves the device; Apple certifies it, and we retain the public part of that key and Apple's certificate for it with your account. This contains no information about you or your chats, cannot be used to follow you into other applications, and is deleted with your account.

Other participants in a conversation

A screenshot contains messages written to you by another person. In order to write your reply, that person's messages and the first name displayed for them in the chat are transmitted through our server to OpenAI, which processes them under its API terms as described above. Their messages are read solely to write your reply and are not retained by us. The only data concerning them that the application retains is held on your device: the conversation itself, stored under their first name, so that Wink can resume the conversation on a later occasion.

The legal basis for this processing is the legitimate interest of the user of the Service in obtaining assistance in responding to a conversation to which that user is a party (GDPR Art. 6(1)(f)). We have balanced that interest against the interests of the other person and have limited the processing accordingly: only a first name is used, none of their data is stored by us, and it is used for no purpose other than that single reply. If you are such a person and wish to object, please write to info@rizzpond.app. We are unable to inform each such person individually, because we do not know who they are and hold no means of contacting them, such that doing so would prove impossible (GDPR Art. 14(5)(b)); this policy is published in place of individual notice. Users are required to scan only conversations to which they are a party. See the terms.

Place of processing and international transfers

• Our server and database are operated on Supabase in Frankfurt, Germany (EU).
• OpenAI processes reads and replies in the United States.
• Apple processes payment and Sign in with Apple under its own terms.
• This website and our email are hosted by Simply.com in the EU, which maintains its own technical logs.

Our own database remains in the EU. A transfer of personal data from the EU to the United States requires an appropriate safeguard under Chapter V of the GDPR. Transfers to OpenAI in the United States rely on the European Commission's Standard Contractual Clauses (Decision (EU) 2021/914), which form part of its data processing terms.

Retention periods

Every record in our database is linked to your account and is deleted with it.

Legal basis for processing

We process your personal data where necessary to provide the Service you have requested (reading the conversation, writing the reply, administering your allowance, your subscription and your backup) and, as regards the transmission of a conversation to OpenAI, on the basis of the consent you gave in the application before the first transmission, which you may withdraw at any time. Because a conversation may reveal data concerning your sex life or sexual orientation, we transmit it to OpenAI only with your explicit consent (GDPR Art. 9(2)(a)), given on a separate screen in the application. We retain counts and limits on the basis of our legitimate interest in keeping the Service affordable and free from abuse, and we retain anonymous usage events on the basis of our legitimate interest in understanding how the application is used and where it fails. The legal basis concerning other participants in a conversation is set out in Other participants in a conversation.

Your choices and your rights

• Deleting your account. You may delete your account in the application under You → Account, by selecting Delete account if you signed in with Apple or Delete my data if you did not. Deletion takes place on the server first; only once the server has confirmed that no data remains does the application erase the data on your device and return to the Welcome screen. All data associated with the account on our server is deleted with it: your account, every count, your subscription link and purchase record, your OpenAI consent record, your usage events, your backup and, in the case of a test account, its files and log. If you signed in with Apple, the application also asks Apple to disconnect Rizzpond from your Apple ID. If you hold a subscription, you must also cancel it with Apple: deleting the account does not cancel the subscription, and if you delete the account without cancelling, Apple will continue to charge you. The confirmation screen links to Apple's page for that purpose. If you reinstall Rizzpond, Restore purchases can transfer the subscription to your new account.
• Signing out. You may Sign out at any time; the data on your device remains on the device. Delete local data on the You tab erases the data on that device only, and the application states this.
• Not signing in. If you do not use Sign in with Apple, no profile data is backed up.
• Requests to us. Under EU data protection law, you have the right to request a copy of the personal data we hold about you, to have it rectified or erased, to restrict or object to its processing, and to data portability. Requests may be made through the contact form by selecting Privacy and data, or by email to info@rizzpond.app. You are not required to cite any law or right; it is sufficient to state what you are requesting. We respond within one month and will inform you if we require the further two months permitted by the GDPR for a complex request. The procedure by which we verify that a request originates from you where your account is anonymous is described in the US privacy notice, and applies to all users.
• Complaints. You also have the right to lodge a complaint with a data protection authority. In Denmark, this is Datatilsynet; elsewhere in the EU, the competent authority may be found on the European Data Protection Board's list.

Residents of the United States

US state privacy laws require the same information to be stated in different terms, together with certain additional information: the statutory categories of personal information we collect, whether we sell or share personal information, which information is treated as sensitive, and how to appeal if we decline a request. That information is set out in the US state privacy notice. In particular, we do not sell your personal information, we do not share it for advertising purposes, and the contents of your chats are treated as sensitive and used solely to write your reply.

Do Not Track. We do not track you across the applications or websites of other companies, and accordingly a Do Not Track signal has no effect on our processing. We treat Global Privacy Control signals as described in the US privacy notice.

Consumer health data (Washington and Nevada)

We do not request health information. A chat you scan may nevertheless contain such information, for example a reference to an illness. Where it does, that information is used solely to write the relevant reply, is sent to OpenAI only after you have given your consent to that transmission, and is not retained by us. The rights and deletion procedures described in this policy apply to it in the same manner as to all other data, and we never sell it.

This website

This website sets no cookies, whether first-party or third-party, stores no data in your browser by means of local storage or any similar technology, and uses no analytics service, advertising pixel, fingerprinting technique or A/B testing tool. As no information is stored on or accessed from your device, no consent is required under the EU ePrivacy rules, and the website accordingly displays no cookie banner. Fonts are the system fonts of your device and are not requested from a third party. Simply.com, which hosts the website within the European Union, receives your IP address, the page requested and your browser's user-agent string, and maintains its own technical and security logs. We do not receive those logs or maintain any analytics in respect of the website. The application does not set any cookies; the data it stores on your device and the usage events it sends are described elsewhere in this policy.

The contact, feedback and work-with-us forms

When you use the form on Support, the feedback form on What's new or the form on Work with us, the information you enter (your name, email address, topic, message and any links or company name you add) is sent by email to our inbox at Simply.com (info@rizzpond.app for Support and feedback, partners@rizzpond.app for Work with us). The feedback form does not request your name, and the provision of an email address on that form is optional. The website itself stores none of it. To prevent the forms from being flooded, the server counts messages per IP address for the current hour. It stores only a keyed one-way hash of the address, never the address itself, and a count from an earlier hour is deleted the next time any person sends a message. We use your message solely to respond to you and never for marketing, and we delete it once the correspondence has concluded, and in any event no later than 12 months after your last message. A job application is deleted 6 months after we respond to it, unless you agree to our retaining it for longer. The legal basis for this processing is our legitimate interest in responding to your enquiry or, in the case of an application, your request to be considered for a position.

Changes to this policy

Before the application begins to process your data in a new way, this policy will be updated and the date at the top of this page amended. In the case of a material change, the application will notify you before the change applies to you.

Contact

Darabos Group (David Pal)
Frederiksborggade 37, 1. tv
1360 Copenhagen K, Denmark
CVR 46690257
info@rizzpond.app