Privacy Policy

1. Who the operator is

The operator of personal data (data controller) is WITU Corp, principal address 8 The Green STE A, Dover, DE 19901 (hereinafter the “Operator”), operator of the witu.health website.

The Operator develops the WitU mobile app and the WITU Band PRO and WITU Ring wearables, sells them through the witu.life and witu.health websites, and answers customer enquiries.

The witu.life website is hosted on a server in the Russian Federation. The witu.health website is hosted by Vercel Inc. (USA).

2. What the website collects

The website requires no registration and creates no accounts. We receive data only when you send it to us yourself.

• Contact forms (“Contact”, “Support”, “For business”, “Collaboration”): your name, email address and message, plus that form's own fields — subject, order number, organization, job title.
• Newsletter sign-up in the footer: your email address.
• Buying the video lessons: your name and email address.
• Placing an order: name, phone number, email address and delivery address — we need these to ship the device to you.
• Engraving: the text you chose, if you order an engraved bracelet.
• Technical data: IP address and browser details in the web-server logs — written on every request to the site, as on any website.

3. What the website stores in your browser

The website sets no cookies of its own. It uses your browser's local storage instead, and everything held there stays on your device:

• witu-consent — your answer in the consent banner, so that we do not ask again.
• witu-theme — light or dark theme.
• witu-utm — the campaign tags you arrived with. Written on your first visit and kept until you close the tab.
• Your ring-size calibration, if you used the on-screen ruler.
• The analytics trackers set cookies of their own — but only once you have accepted in the banner.

4. Who we share data with

We do not sell your data and we do not pass it to data brokers. Below is the complete list of who receives it, and what for.

• Telegram — form submissions and newsletter sign-ups. A message containing the contents of the form reaches a WITU staff member in the messenger. Telegram's servers are located outside the Russian Federation.
• The payment gateway — when you pay. It receives the amount, the order number and the payment description so that it can issue a Faster Payments System QR code.
• Your bank and NSPK (the Faster Payments System) — on a QR-code transfer they see the payee, the amount and the payment reference.
• Yandex Metrica (Yandex LLC, Russia) — on witu.life only and only with your consent: page views, referral source, click maps and goal completions.
• Google Analytics and the Meta Pixel (USA) — on witu.health only and only with your consent.
• The hosting provider — web-server logs. For witu.life this is a provider in Russia; for witu.health it is Vercel Inc. (USA).

5. Analytics and consent

The trackers load only once you choose “Accept” in the banner. If you choose “Essential only”, no tracker is loaded at all.

We do not build advertising profiles from this data and we do not pass it to ad networks to serve third-party advertising. witu.health uses the Meta Pixel — under the laws of some U.S. states, loading an advertising pixel may count as a “sale” or “sharing” of personal information; you can opt out in the same banner.

Campaign tags (utm_source and the like) are saved in your browser tab for the session, on your first visit and, before you answer the banner — they do not leave your browser unless you submit a form or accept analytics.

6. How long we keep it

• Messages from the forms — in the messenger conversation, until you ask us to delete them.
• Payment data — with the payment gateway and the bank, for the periods the law sets for payment records.
• Analytics data — with the service concerned: Yandex Metrica keeps it for up to 25 months.
• Web-server logs containing IP addresses — 30 days.

7. How to exercise your rights

You have the right to obtain a copy of your data, to have it corrected, to ask for its deletion and to withdraw your consent. Email support@witu.health, quoting the email address or phone number you used to contact us — that is enough for us to find you. We will reply within the period set by applicable law.

You can withdraw your consent to analytics yourself: the “Do Not Sell or Share My Personal Information” link in the footer of any page reopens the banner.

8. Security

• All traffic to the site runs over HTTPS.
• The payment-gateway keys and the token used to deliver form submissions are held on the server only and never reach the browser.
• Pages and requests that contain personal data are not cached.
• The website stores no payment details: you enter your card number in your own bank's app, and it never reaches us.

9. Children

The website is not intended for anyone under [AGE]. We do not knowingly collect data from minors. If you believe a child has sent us their data, email support@witu.health and we will delete it.

10. For users in Russia

Personal data is processed with your consent, in accordance with Federal Law No. 152-FZ “On Personal Data”.

The witu.life website is hosted on a server located in the territory of the Russian Federation.

Please note: messages sent through the website's forms are delivered to us through the Telegram messenger, whose servers are located outside the Russian Federation. If you would rather your enquiry did not pass through a messenger, write to us directly at support@witu.health.

11. For users in the European Union

We act as a data controller within the meaning of the GDPR. The legal basis for processing the data you send through the forms is your consent and steps taken at your request before entering into a contract; the legal basis for processing order data is performance of a contract.

You have the rights of access, rectification, erasure, restriction of processing, portability and objection to processing, as well as the right to lodge a complaint with the supervisory authority in your country.

Processing involves cross-border transfers of data to the Russian Federation and the United States of America — see the list of recipients in section 4.

12. For users in the United States

We do not sell personal information for money. Using an advertising pixel on witu.health may be treated as a “sale” or “sharing” of personal information for cross-context behavioral advertising under the laws of several states; you can opt out in the consent banner at any time.

You have the right to request details of the data collected about you and to have it deleted — support@witu.health. We do not deny service to anyone for exercising these rights.

13. Changes

We may update this Policy. We announce material changes on the website at least 30 days before they take effect. The date of the last update is shown at the top of this document.

14. Contact

This document is a template prepared for WITU Corp and should be reviewed by an attorney and adapted to applicable law before publication. It is provided for information only and is not legal advice.

• Support: support@witu.health
• Privacy questions and data requests: support@witu.health