Privacy Policy

1. Controller (Verantwortlicher)

The Controller within the meaning of the GDPR (DSGVO) is:

2. Types of Data Processed

Inventory Data: Names, email addresses (for parent account creation and waitlist signups), and optional child age and country provided by the parent.

Content Data: Student answers, page completions, and voice or text inputs entered during a tutoring session (processed for the tutoring interaction and the weekly parent summary).

Usage Data: Access times, device information, IP addresses.

3. Purpose and Legal Basis (Art. 6 GDPR)

We process your data for the following purposes and based on the following legal bases:

• Providing the Service: To run the tutoring service and produce the weekly parent summary. Legal Basis: Art. 6(1)(b) GDPR (Performance of Contract).
• Security & Improvement: To ensure server stability and improve the quality of the AI tutoring. Legal Basis: Art. 6(1)(f) GDPR (Legitimate Interest).
• Payment Processing: If you subscribe to a paid plan. Legal Basis: Art. 6(1)(b) GDPR.

4. Children and Parental Consent

5. Data Transfer to Third Parties & Third Countries (Crucial for AI)

5.1. AI Providers: We use external AI models (e.g., OpenAI, Anthropic) to generate tutoring hints and explanations. These providers serve as Processors (Auftragsverarbeiter) under a Data Processing Agreement.

5.2. Transfers to the USA: Some service providers are located in the USA. Data transfer to the USA is based on:

• The EU-US Data Privacy Framework (if the provider is certified), OR
• Standard Contractual Clauses (SCCs) approved by the EU Commission, ensuring an adequate level of data protection.

5.3. By using the service, the parent or legal guardian acknowledges that the child’s input data (answers, voice or text entered during a tutoring session) will be sent to these third-party AI providers for processing.

6. Storage Duration

We store personal data only as long as necessary for the provision of the service or as legally required (e.g., tax retention periods). You may delete your account and associated data at any time via the user settings or by writing to [email protected].

7. Your Rights as a Data Subject

Under the GDPR, you have the following rights:

• Right of Access (Art. 15 GDPR): You can request information about your stored data.
• Right to Rectification (Art. 16 GDPR): You can correct wrong data.
• Right to Erasure (Art. 17 GDPR): “Right to be forgotten.”
• Right to Restriction of Processing (Art. 18 GDPR).
• Right to Data Portability (Art. 20 GDPR).
• Right to Object (Art. 21 GDPR): You can object to processing based on legitimate interest.

8. Hosting

This service is hosted on third-party cloud infrastructure within the EU and/or the USA. A Data Processing Agreement (AV-Vertrag) has been concluded with the hosting provider.

9. Product Analytics

We use PostHog (operated by PostHog Inc.) to understand how visitors use this website — for example, which pages they land on, whether they complete the waitlist form, and where they leave. This helps us improve the product before launch. We use the European Union instance of PostHog, so analytics data is hosted in the EU.

• We use anonymous tracking by default. A person profile is only created when you actively submit the waitlist form.
• We do not record session videos.
• We respect the “Do Not Track” browser signal — if your browser sends it, we do not capture analytics for your visit.

Legal Basis: Art. 6(1)(f) GDPR (Legitimate Interest in product analytics, balanced against your privacy through the measures above). For the waitlist signup specifically, Art. 6(1)(a) GDPR (Consent).

10. Cookies and Tracking

We use strictly necessary cookies for session management. For the product analytics described in Section 9, we use first-party analytics cookies (set by us, not by an advertising network). We do not use advertising cookies or third-party advertising pixels. Legal Basis: Art. 6(1)(f) GDPR.