Template · v0.1-draft
Privacy Policy
What personal information is collected, why, and who ever sees it.
This is a working template. It is not legal advice and has not been reviewed or approved by a lawyer. Plain-language draft prepared in-house. Not enforceable, not advice.
Who this applies to
Everyone, at account creation and on every material change.
- Creating an account
- Private progress tracking
What the final text must cover
- 01
What we collect
Account data, challenge data, notes, images, device data.
Operative wording to be supplied by counsel
- 02
Why
A lawful basis for each purpose, separated from consent-based uses.
Operative wording to be supplied by counsel
- 03
Private by default
That nothing publishes without a separate recorded permission.
Operative wording to be supplied by counsel
- 04
Storage and retention
Where data lives, how long, and what deletion means.
Operative wording to be supplied by counsel
- 05
Sharing
Processors, hosting, analytics; that participant data is never sold.
Operative wording to be supplied by counsel
- 06
Your rights
Access, correction, deletion, portability, objection, complaint route.
Operative wording to be supplied by counsel
- 07
Children
Whether under-18 participation is permitted at all.
Operative wording to be supplied by counsel
Open questions for counsel
- Do we need a GDPR representative and a lawful-basis mapping for an international cohort?
- Retention period for withdrawn material versus the audit record of the withdrawal itself.