Privacy Policy

Who we are

Adaptaly ("we", "us") is a personal project and educational platform created and managed by an individual developer based in the Netherlands. Adaptaly helps students study more effectively using AI-powered tools.

Contact: adaptaly@gmail.com

What we collect and why

• Email address - used to manage the waitlist and send early access or product updates.
  Legal basis: Consent (GDPR Art. 6 (1)(a)). You can withdraw your consent at any time using the unsubscribe option.
• Age confirmation - used to determine if parental consent is required for users under 16.
  Legal basis: Legal obligation (GDPR Art. 6 (1)(c) and Art. 8).
• Parent or guardian email - for minors, used only to obtain verifiable consent.
  Legal basis: Legal obligation (GDPR Art. 8).

We do not collect passwords, payment information, or any data that is not necessary for the waitlist and consent process.

Processors and service providers

Adaptaly uses trusted third-party services to host and process limited data securely:

• Hosting and CDN: Vercel (US/EU) for application hosting and content delivery.
• Database: Supabase (EU) for secure data storage.
• Email delivery: Brevo (EU) for sending parental consent and waitlist emails.

These processors follow strict security and privacy practices and are bound by data processing agreements.

International transfers

Some service providers may process data outside the EEA. When this happens, we ensure adequate protections are in place such as Standard Contractual Clauses approved by the European Commission.

Data retention

Waitlist data is stored until Adaptaly launches or until you unsubscribe, whichever comes first. Data may be retained longer only if required by law.

Pending parental consent records are deleted after consent is granted or automatically after 30 days if no response is received.

Your rights

Under the GDPR, you have the right to:

• Access your personal data
• Rectify inaccurate or incomplete data
• Request erasure (right to be forgotten)
• Restrict or object to processing
• Request data portability
• Withdraw consent at any time

To exercise your rights, contact adaptaly@gmail.com.

You may also contact the Dutch Data Protection Authority at autoriteitpersoonsgegevens.nl.

Children and parental consent

In accordance with GDPR Article 8, children under 16 require parental consent before their data can be processed. The waitlist includes an age confirmation step:

• 16 or older: You can join directly.
• Under 16: A parent or guardian email is required to obtain consent.

Parents receive an email containing a consent link. The child's data is only added to the waitlist after approval.

Cookies and analytics

We currently use only essential cookies required for the website to function correctly. We do not use analytics, advertising, or tracking cookies at this time.

If we add analytics or non-essential cookies later, we will update this policy and ask for consent.

Security

We take reasonable technical and organizational measures to protect your data:

• Encryption in transit (HTTPS and TLS)
• Encryption at rest in the database
• Access control and authentication
• Regular reviews of dependencies and configurations

While we strive to protect your information, no system is completely secure. Please contact us immediately if you suspect unauthorized access to your data.

Changes to this policy

This policy may be updated from time to time. Updates will be posted on this page with a new Last updated date. Significant changes will be announced by email to waitlist subscribers.

Contact

For any questions about this Privacy Policy or your personal data, contact:

Email: adaptaly@gmail.com
Controller: Individual developer based in the Netherlands