Privacy Policy
Last updated: 16 October 2026
This policy explains what personal data SPELL WORKS S.R.L. collects through its apps, including Pookie, why we collect it, and the rights you have over it.
Who we are
The data controller is SPELL WORKS S.R.L., Calea Mănăștur nr. 91, ap. 57, Cluj-Napoca, Jud. Cluj, Romania, CUI 52949220, Trade Register number J2025089645005. You can reach us at contact@spellworks.org.
What we collect
- Account data. If you sign in with Apple or Google, we receive an account identifier and, if you share it, your email address and name.
- Anonymous identifier. If you use the app without signing in, we assign a random identifier to your device.
- Conversations. The messages and images you send to characters, and the replies generated for you.
- Purchases. Which in-app purchases you have made. Payment details are handled by Apple; we never see your card.
- Usage and device data. App interactions, crash data, device model and OS version, and an advertising identifier if you allow it.
How we use it
- To provide the app: generate character replies, voice messages and reactions (performance of a contract).
- To keep your conversation history and unlocked features if you are signed in (performance of a contract).
- To prevent abuse, moderate content and keep the service secure (legitimate interest).
- To understand how the app is used and improve it (legitimate interest, or consent where required).
- To show ads in the free version (consent, where required).
How long we keep it
If you are not signed in, your conversations and the character's memory of them are deleted when you leave the chat. If you are signed in, your history is kept until you clear it in the app or ask us to delete your account. We delete account data within 30 days of a deletion request, except where the law requires us to keep it longer (for example, purchase records for accounting).
Who we share it with
We use trusted service providers who process data on our behalf, only as needed to run the app:
- Hosting and storage: Hetzner Online (EU), MongoDB Atlas, Amazon Web Services
- AI replies: xAI (Grok), which receives the text and images of your conversation
- Voice messages: ElevenLabs, which receives the text of the character's reply
- GIF reactions: Giphy
- Sign-in: Apple and Google
- Purchases: Apple and RevenueCat
- Analytics, app integrity and advertising: PostHog, Google Firebase and Google AdMob
Some of these providers are located outside the European Economic Area, mainly in the United States. Where data is transferred there, we rely on the EU–U.S. Data Privacy Framework or the European Commission's Standard Contractual Clauses. We do not sell your personal data.
Children and teenagers
In Romania, a person must be at least 16 to consent to the processing of their data for online services. If you are under 16, please use the app only with the permission of a parent or guardian. Characters are designed to avoid sexual content, and we moderate replies. If you believe a child has given us data without the required permission, contact us and we will delete it.
Your rights
Under the GDPR, you can ask to access, correct, delete or export your data, to restrict or object to its processing, and to withdraw any consent you have given. Email contact@spellworks.org and we will reply within one month. You also have the right to complain to the Romanian data protection authority, ANSPDCP (dataprotection.ro).
Security
Data is encrypted in transit, access to our servers is restricted, and we only keep what we need to run the service.
Changes
If we change this policy, we will update the date at the top and, for significant changes, let you know in the app.