Privacy Policy
- We use your data to run the app: turn your notes into study packs, plan your day and show your progress.
- We never sell your data and we never show you adverts.
- We ask for your date of birth once, on your phone, to check you are 13 or over. The date itself is never sent to us.
- Your notes are sent to an AI provider to build your study pack. They are not used to train AI models.
- You can delete your account from the app at any time. Everything goes within 30 days.
1. Who we are
FacilStudy is operated by David Nunes Cuba, trading as FacilForge (“we”, “us”). FacilForge is a trading name of David Nunes Cuba, a sole trader operating in the United Kingdom. Business address: FacilForge, Suite RA01, 195-197 Wood Street, London, E17 3NU, United Kingdom. We are the data controller for the personal data described here. Questions or requests: privacy@facilstudy.com.
2. Who can use FacilStudy
FacilStudy is for students aged 13 and over. Before an account is created the app asks for your date of birth. The check happens on your device: we store only an age band (13–15, 16–17 or 18+) and the time you passed the check, never the date itself. If you are under 13 the app does not create an account and nothing is saved.
If you are under 18 we design the app to the UK Age Appropriate Design Code: no adverts, no profiling for marketing, no nudges to share more than you need to, and privacy-protective settings by default.
3. What we collect and why
| Data | Why we use it | Legal basis (UK GDPR) |
|---|---|---|
| Sign-in identity: email address, or the identifier and name Apple or Google share when you sign in with them | To create and secure your account and send sign-in codes | Contract |
| Age band and the time you passed the age check | To keep the app age-appropriate and meet our legal duties | Legal obligation |
| Profile: display name, education level, school year, subjects, daily study time, time zone | To personalise your study plan | Contract |
| Study materials you add: photos of notes, typed text, PDFs, and the study packs, flashcards and quizzes we generate from them | To provide the core service | Contract |
| Learning activity: quiz answers, flashcard ratings, sessions, streaks, mastery scores | To plan what you study next and show your progress | Contract |
| Tutor conversations (when the AI tutor is available) | To answer your study questions and keep the tutor safe | Contract; safeguarding (legitimate interests) |
| Study partner links you choose to create, and what you allow the partner to see | To share progress only with people you invite | Consent (you can revoke at any time) |
| Subscription status from Apple, Google and RevenueCat (no card details) | To unlock the plan you or your family paid for | Contract |
| Device push token, if you allow notifications | To tell you when a study pack is ready or a reminder is due | Consent (device permission) |
| Product analytics: which screens and features you use, app version, coarse device type | To fix problems and improve the app | Legitimate interests, balanced for children (see section 6) |
| Error reports: the error code and message, which screen or action failed, app version and platform. Never the content of your notes or answers | To find and fix faults in the app | Legitimate interests, balanced for children (see section 6) |
| Early-access list on the website: your email address and where you signed up | To send one email when the app launches | Consent — deleted after that email, or sooner on request |
We do not collect precise location, contacts, your camera roll beyond the photos you pick, or any advertising identifiers. This website sets no cookies and runs no analytics.
4. AI processing of your notes
When you scan or type notes, we send the image or text to an AI provider to extract the topics and build your study pack. We currently use Anthropic (Claude) and may use OpenAI as a backup. Both process the data under commercial API terms that prohibit using it to train their models. We send only what is needed for the task and never your name, email or age.
AI-generated content can contain mistakes. Always check a study pack before saving it; the app asks you to.
5. Who we share data with
We share personal data only with the service providers that run FacilStudy, under contracts that limit what they can do with it:
- Supabase — database, sign-in, file storage and server functions (hosted in the United Kingdom, London).
- Anthropic and OpenAI — AI processing of study materials and tutor messages (section 4).
- Apple and Google — sign-in (if you choose it) and subscriptions through the App Store and Google Play.
- RevenueCat — subscription status.
- Expo — push notifications.
- Vercel — hosting for this website.
We do not sell personal data, share it with advertisers or data brokers, or use it for advertising. We may disclose data if the law requires it or to protect someone's safety.
6. Analytics, designed for young people
We measure how the app is used so we can improve it. For everyone, and especially users under 18, analytics is set up so that: nothing is captured automatically (we log only named events), there is no screen recording or session replay, IP addresses are anonymised, and data is kept for 90 days. We do not build marketing profiles.
7. Study partners
You can invite a parent, carer or tutor to be your study partner. You choose exactly what they see, for example your streak, time studied and subject progress. A partner can never read your tutor conversations or the content of your notes. You can remove a partner at any time in the app.
8. How long we keep data
- Your account data is kept while your account is active.
- When you delete your account, your files are removed first and the rest of your data within 30 days. Aggregated statistics that cannot identify you may be kept.
- Photographs of notes are deleted 30 days after the study pack is built.
- Study packs you never confirmed are discarded after 7 days.
- Error reports are kept for 90 days.
- Analytics events are kept for 90 days.
- Records of AI usage (token counts and costs, with no content) are kept for accounting.
9. Your rights
Under UK GDPR you can ask us to access, correct, delete or export your data, to restrict or object to processing, and to withdraw consent. Most of this you can do yourself:
- Edit your profile and subjects in the app.
- Delete your account from Settings, or follow Delete your account.
- Turn notifications off in your device settings.
For anything else email privacy@facilstudy.com. We reply within one month. If you are unhappy with our answer you can complain to the Information Commissioner's Office at ico.org.uk.
If you are under 18 you can exercise these rights yourself. A parent or carer can also contact us on your behalf; we may ask for proof that they are responsible for you.
10. Security
Data is encrypted in transit and at rest. Access to your data in our database is restricted per account by database-level rules. AI keys and server secrets are never included in the app. We review access and keep audit logs of deletions.
11. International transfers
Our database and file storage are in the United Kingdom (London). Some providers (Anthropic, OpenAI, Apple, Google, RevenueCat, Expo, Vercel) process data in the United States under the UK International Data Transfer Agreement or the UK extension to the EU–US Data Privacy Framework.
12. Changes
If we change this policy in a way that matters, we will tell you in the app before it takes effect. The date at the top shows the current version.
13. Contact
privacy@facilstudy.com · Legal: contact@facilforge.com · David Nunes Cuba, trading as FacilForge, Suite RA01, 195-197 Wood Street, London, E17 3NU, United Kingdom.