Privacy Policy

<p><em>This is a working draft. Replace every [BRACKETED] item with your real details and have a qualified lawyer review it before you publish. It is not legal advice.</em></p><h2>1. Who is responsible for your data</h2><p>StudyBro is operated by [LEGAL ENTITY NAME], [LEGAL FORM], registered at [FULL ADDRESS, SWITZERLAND] ([COMPANY REGISTRATION NUMBER]). We are the controller of the personal data described in this policy.</p><p>For any question about this policy or your data, write to <a href="mailto:privacy@studybro.app">privacy@studybro.app</a>.</p><h2>2. What we collect</h2><p><strong>Account data.</strong> [Describe exactly what is required to create an account: email address, display name, and anything else. If StudyBro can be used without an account, say so.]</p><p><strong>Study content.</strong> The notes, study sets, flashcards, subjects and exam dates you add to the app. This is content you create, and it may contain whatever you choose to put in it.</p><p><strong>Usage data.</strong> How you use the app: sessions started and completed, study streaks, progress per set, and similar activity needed to show your progress and run the study algorithm.</p><p><strong>Device and technical data.</strong> [Describe what is collected automatically: device model, operating system version, app version, crash diagnostics, IP address. Name any analytics or crash reporting tool you use.]</p><h2>3. Why we process it, and on what legal basis</h2><p>Under Article 6 of the GDPR, we rely on the following bases:</p><ul><li><strong>Performance of a contract (Art. 6(1)(b)).</strong> To give you an account, store your study content, generate your study plan and flashcards, and track your progress.</li><li><strong>Legitimate interests (Art. 6(1)(f)).</strong> To keep the service secure, prevent abuse, fix crashes and improve how the app works. We balance this against your rights and interests.</li><li><strong>Consent (Art. 6(1)(a)).</strong> For anything optional, such as [marketing emails, optional analytics, push notifications]. You can withdraw consent at any time without affecting processing already carried out.</li><li><strong>Legal obligation (Art. 6(1)(c)).</strong> Where we must keep records or respond to lawful requests.</li></ul><h2>4. AI processing</h2><p>StudyBro uses artificial intelligence to generate flashcards from your notes, answer questions in the chat, and build study plans. To do this, the relevant content is processed by [NAME THE AI PROVIDER(S), e.g. OpenAI, Anthropic, or your own hosted models].</p><p>[State clearly: whether your content is sent to a third-party provider, where that provider processes it, whether it is used to train models (it should not be), and how long the provider retains it. This is the single most important disclosure in this policy for a student-facing AI app — do not leave it vague.]</p><h2>5. Who we share data with</h2><p>We do not sell your personal data. We share it only with service providers acting on our instructions under a data processing agreement:</p><ul><li>[Hosting and database provider, and the country it operates in]</li><li>[Authentication provider]</li><li>[AI model provider]</li><li>[Analytics or crash reporting provider]</li><li>[Payment provider, if you offer paid features]</li></ul><p>We may also disclose data where legally required, or to establish or defend legal claims.</p><h2>6. International transfers</h2><p>Some providers listed above are located outside Switzerland and the European Economic Area. Where that is the case, transfers are covered by [European Commission Standard Contractual Clauses / an adequacy decision / another safeguard], together with the Swiss addendum recognised by the Federal Data Protection and Information Commissioner. You can request a copy of the relevant safeguards from us.</p><h2>7. How long we keep it</h2><p>We keep your account and study content for as long as your account is active. If you delete your account, we delete or irreversibly anonymise your personal data within [NUMBER] days, except where we must keep records for a legal reason. Backups are purged within [NUMBER] days.</p><h2>8. Your rights</h2><p>Under the GDPR and the Swiss Federal Act on Data Protection, you can ask us to:</p><ul><li>confirm whether we process your data, and give you a copy of it (access);</li><li>correct data that is wrong or incomplete (rectification);</li><li>delete your data (erasure);</li><li>restrict or object to certain processing;</li><li>receive your data in a portable, machine-readable format;</li><li>withdraw any consent you have given.</li></ul><p>Write to <a href="mailto:privacy@studybro.app">privacy@studybro.app</a> and we will respond within one month. If you think we have handled your data badly, you may complain to the Swiss Federal Data Protection and Information Commissioner (FDPIC), or to the supervisory authority in your EU country of residence.</p><h2>9. Children and young people</h2><p>StudyBro is rated 12+ and is used by school students. [State the minimum age for using StudyBro. Under the GDPR, processing based on consent for children under 16 requires parental authorisation, and some EU countries set this as low as 13 — confirm which ages you accept and how you verify or obtain parental consent. Swiss law assesses capacity individually rather than by fixed age.]</p><p>We do not knowingly collect data from children below that age. If you believe a child has given us personal data, contact us and we will delete it.</p><h2>10. Security</h2><p>We use [encryption in transit and at rest, access controls, and other measures] to protect your data. No system is perfectly secure, but we take this seriously and will notify you and the competent authority of any breach that is likely to result in a risk to your rights, within 72 hours of becoming aware of it.</p><h2>11. Changes to this policy</h2><p>If we make a material change we will tell you in the app or by email before it takes effect. The date at the top of this page always shows the current version.</p><h2>12. Contact</h2><p>[LEGAL ENTITY NAME]<br/>[FULL ADDRESS]<br/><a href="mailto:privacy@studybro.app">privacy@studybro.app</a></p>