Last updated: March 26, 2026


1. Controller

The controller responsible for data processing is:

Stefan Johann Sinnegger

Kirschentalgasse 16E

6020 Innsbruck, Austria

Email: [email protected]

This privacy policy explains how Wholy ("the App") collects, uses, and protects your personal data in compliance with the General Data Protection Regulation (GDPR).

2. Data We Collect

Account Data: When you create an account, we collect your email address and an encrypted password. Authentication is handled by Supabase (hosted in the EU).

Audio Data: When you upload an audio file or record within the App, the audio is temporarily uploaded to Cloudinary (USA) for processing. Audio files are used solely for transcription and are not stored permanently on our servers.

YouTube Data: When you paste a YouTube URL, we retrieve the transcript via the Supadata API (USA). We do not access your YouTube account or any data beyond the public transcript of the video you provide.

AI-Processed Content: Transcripts are processed by AI services (Anthropic Claude and OpenAI GPT) via Supabase Edge Functions to generate summaries, flashcards, and quizzes. Your content is sent to these services solely for processing and is not used to train AI models.

Bible Texts: When you view Bible verses, we retrieve them from the API.Bible service. No personal data is sent to this service.

Local Data: Your summaries, flashcards, quiz results, and app preferences are stored locally on your device using AsyncStorage. This data does not leave your device unless you explicitly share it.

3. Legal Basis for Processing (Art. 6 GDPR)

We process your data based on the following legal grounds: