Last updated: 28 July 2026 · Version 1.0
Template. The processing described below — vendors, data categories, payment flow, AI provider — is what this boilerplate actually ships, so most of this document is already true of your deployment. What remains: replace every
{{PLACEHOLDER}}(company identity, regions, retention windows), delete subprocessor rows you do not deploy, and note that analytics currently runs WITHOUT the consent this policy promises — see the warning in the Cookie Policy. Then have a qualified lawyer review the result. This is not legal advice.
{{COMPANY_LEGAL_NAME}} ("we", "us") operates {{PRODUCT_NAME}} at {{PRODUCT_URL}}. This policy explains what personal data we process, on what legal basis, who we share it with, and how you exercise your rights.
1. Who is responsible for your data
The data controller is:
{{COMPANY_LEGAL_NAME}} {{REGISTERED_ADDRESS}} Company registration: {{COMPANY_REGISTRATION_NUMBER}} VAT: {{VAT_NUMBER}}
Privacy contact: {{PRIVACY_CONTACT_EMAIL}}
{{IF_APPLICABLE: We have appointed a Data Protection Officer, reachable at {{DPO_EMAIL}}.}}
{{IF_APPLICABLE: Our EU representative under GDPR Article 27 is {{EU_REPRESENTATIVE}}.}}
2. What we collect, why, and on what basis
| Data | Purpose | Legal basis (GDPR Art. 6) |
|---|---|---|
| Name, email, password hash | Create and secure your account | Performance of a contract |
| Workspace name and members | Provide shared workspaces | Performance of a contract |
| Billing address, VAT ID, payment method token | Take payment, issue invoices, meet tax obligations | Contract; legal obligation |
| Content you create in the product | Provide the service to you | Performance of a contract |
| Product usage and device analytics | Understand and improve the product | Consent |
| Support conversations | Answer your questions | Legitimate interest |
| Server and security logs | Keep the service available and secure | Legitimate interest |
| Marketing emails | Tell you about the product | Consent |
We do not collect special-category data, and the service is not directed at children under {{MINIMUM_AGE: 16}}.
3. Payment data
Payments are processed by Stripe on its hosted checkout pages. Your card number reaches Stripe directly and is never stored on our servers — we retain only a token, the last four digits, and the transaction record needed for invoicing and tax.
4. Who we share data with
We do not sell your personal data. We share it with the processors below, each under a data processing agreement:
| Subprocessor | Purpose | Location |
|---|---|---|
| Vercel Inc. | Application hosting and compute | {{REGION: e.g. EU (Frankfurt) — set by your Vercel project}} |
| Neon Inc. | Primary database (Postgres) | {{REGION: e.g. AWS eu-central-1 — set by your Neon project}} |
| PostHog Inc. (EU Cloud) | Product analytics, error tracking, logs | EU (Frankfurt) |
| Stripe Payments Europe, Ltd. | Payments, invoicing, fraud prevention | EU / US (global infrastructure) |
| Resend (Plus Five Five, Inc.) | Transactional email | US |
| Anthropic, PBC | AI-assisted features | US |
{{IF_APPLICABLE: | Cloudflare, Inc. | Bot protection on sign-in and sign-up (Turnstile) | Global | — delete this row if Turnstile is not enabled.}}
{{IF_APPLICABLE: | Crisp IM SARL | Support chat | EU (France) | — delete this row if Crisp is not enabled.}}
We will also disclose data where legally compelled, and to an acquirer in the event of a merger or sale — in which case we will notify you first.
5. AI-assisted features
{{PRODUCT_NAME}} uses Anthropic's Claude models to power {{AI_FEATURE_LIST: as shipped in the template: note summaries}}. Content you submit to those features is sent to Anthropic to generate a response.
Anthropic does not use content sent through its API to train its models. {{CONFIRM: true under Anthropic's commercial terms as of mid-2026 unless you opt in to data sharing — re-verify when you launch.}} Outputs are generated automatically and may be inaccurate — review anything you rely on.
6. International transfers
Analytics data stays in the EU (PostHog EU Cloud). Where data does leave the European Economic Area — hosting, email, payments and AI run partly on US infrastructure — we rely on the European Commission's Standard Contractual Clauses and, where the provider is certified, the EU–US Data Privacy Framework, together with the safeguards each processor maintains. A copy of the relevant safeguards is available from {{PRIVACY_CONTACT_EMAIL}}.
7. How long we keep it
| Data | Retention |
|---|---|
| Account and content | For the life of the account, then deleted {{ACCOUNT_DELETION_WINDOW: within 30 days}} of account deletion |
| Invoices and tax records | {{TAX_RETENTION_PERIOD: e.g. 6 years}}, as tax law requires |
| Server and security logs | {{LOG_RETENTION_PERIOD: e.g. 90 days}} |
| Analytics events | {{ANALYTICS_RETENTION_PERIOD: e.g. 12 months — check your PostHog project settings}} |
| Support conversations | {{SUPPORT_RETENTION_PERIOD: e.g. 24 months}} |
Deleting your account removes your content on the schedule above. Invoices are the deliberate exception: tax law requires us to keep them, and that obligation overrides an erasure request.
8. Your rights
You may request access to your data, correction, erasure, a portable copy, restriction of processing, or object to processing based on legitimate interest. Where we rely on consent, you can withdraw it at any time without affecting prior processing.
Exercise any of these by emailing {{PRIVACY_CONTACT_EMAIL}}. We respond within one month.
If you are in the EEA or UK and believe we have mishandled your data, you may complain to your national supervisory authority — ours is {{LEAD_SUPERVISORY_AUTHORITY: e.g. the AEPD (www.aepd.es) for a Spanish controller}}.
California residents additionally have the right to know what we collect, to delete it, to correct it, and to opt out of sale or sharing. We do not sell or share personal information as the CPRA defines those terms, so there is no sale or sharing to opt out of. We will not discriminate against you for exercising these rights.
9. Security
Data is encrypted in transit (TLS) and at rest by our hosting and database providers. Passwords are stored only as scrypt hashes. Access to production systems follows least privilege, and payment card data never touches our servers (see section 3). No system is perfectly secure; if a breach affects your personal data, we will notify you and the relevant authority as the law requires.
10. Changes
We will post any revision here with a new version number and effective date. For material changes we will notify you by email or in the product before the change takes effect.
Questions: {{PRIVACY_CONTACT_EMAIL}}.