Ink Nuvo
Draft for counsel to review. Every [bracketed] part is for the owner to fill in before launch.
Privacy notice
Version 1, [date]. This is the full notice. A short version is in the app, under Settings → Privacy & AI.
1. Who is responsible
[company name exactly as registered], [registered address]. Privacy contact: [privacy contact email]. [Data protection officer, if you have one.]
2. What we process and why
| Data | Why | Basis (GDPR) |
|---|---|---|
| Account: the sign-in id from Apple or Google, and your email | To sign you in, to tell you about a data breach and to give support | Contract (Art. 6(1)(b)); legal duty (Art. 6(1)(c)) |
| Your writing: projects, chapters, sections and the originals you typed | To provide the service | Contract (Art. 6(1)(b)) |
| Style guides and the titles of the books they came from | To provide the service | Contract (Art. 6(1)(b)) |
| Settings and word balance | To provide the service | Contract (Art. 6(1)(b)) |
| Purchases and refunds (amount, date, pack) | Accounting, refunds, preventing fraud | Legal duty (Art. 6(1)(c)); legitimate interest (Art. 6(1)(f)) |
| Logs: technical details of requests, and IP addresses, never your text | Security and keeping the service working | Legitimate interest (Art. 6(1)(f)) |
We use no ads, analytics or tracking. The only cookie keeps you signed in. It is strictly necessary, so no consent banner is needed.
3. AI processing
- To rewrite a section, suggest ideas or analyse a style, we send the text involved to Anthropic, the maker of Claude. Anthropic acts for us as a processor.
- Anthropic may process it in the US or other countries. The transfer is covered by [the EU-US Data Privacy Framework / standard contractual clauses].
- Anthropic doesn't keep this text by default and doesn't use it for training without permission. Text that its safety systems flag may be kept for up to 2 years.
- No decision with legal or similarly significant effect on you is made by the AI.
- Rewritten text is AI-generated. Your original is kept with each section, and exports mark the rewritten text.
4. Uploaded books
Books you upload to build a style are read in memory for the few minutes the analysis takes. They are never written to disk or to backups. We keep only the style guide and the titles of the books. A guide never contains real quotes from them.
5. Who receives data
- [hosting provider, EU country]: runs our server.
- [backup storage provider, EU]: stores encrypted backups.
- Anthropic: the AI processing above.
- Apple and Google: sign-in. They act for themselves.
- Paddle: sells the word packs on the web, as merchant of record, and handles payment, tax and invoices. It acts for itself under its own privacy notice. We receive the payment record, never your card details.
- Apple: sells the word packs in the iPhone app, for itself.
We don't sell data.
6. Where it is stored
Our server is in [EU country]. The disk is encrypted. The operator can technically read stored text, because the AI needs plain text to work, so end-to-end encryption isn't possible. We look only when you ask us to, and we record it.
7. How long we keep it
| Data | Kept |
|---|---|
| Account, projects and styles | Until you delete them or your account |
| Sign-in sessions | 30 days (web) or 90 days (iPhone) after last use |
| Logs and IP addresses | 14 days |
| Backups | 30 days, so deleted data leaves them within 30 days |
| Payment and word records | [N] years (accounting duty), without your name or email after you delete your account |
| One-way hash of your Apple or Google sign-in id | After you delete your account, so the free words are granted only once per person (legitimate interest, Art. 6(1)(f)) |
| Uploaded books | Never stored |
8. Your rights
You can ask to see your data, correct it, delete it, restrict or object to its use, and receive it in a portable form. Delete your account in Settings → Account. Export a project in Settings → Export. For a full export of your account, or any other request, email [privacy contact email]. We answer within one month.
You can complain to the data protection authority: [supervisory authority, with address and website].
9. Children
Ink Nuvo is for people aged 16 or older, or the age of digital consent in their country.
10. Security
Encrypted connections and disks, sessions that can be ended at once, strict separation between accounts, secrets kept out of the database, and monitoring that never records your text. If a breach puts you at risk, we tell the authority within 72 hours and tell you.
11. Changes
We publish changes here and update the version above. For a change that matters, we tell you in the app.
See also the terms and contact and reports.