Privacy Policy

1. Who This Privacy Policy Applies To

This Privacy Policy applies to visitors to the Picobuddy website, adult users who create an account or purchase a subscription, people who contact Picobuddy for support, billing, legal, or other inquiries, and learner-facing use of quizzes, practice links, and similar activity links shared by an Account Holder.

Picobuddy is designed for use by adult Account Holders. Children do not create independent Picobuddy consumer accounts.

A “Learner” is a child or student who accesses a learner-facing quiz, practice link, or similar activity provided by an Account Holder. Learners do not contract directly with Picobuddy.

2. Information We Collect

We collect information in the following categories.

2.1 Information You Provide Directly

• account information such as your name and email address, where made available through your login provider;
• profile information associated with your account;
• billing information such as billing name, billing country, tax/VAT information, subscription details, and transaction-related metadata;
• prompts, topics, instructions, grade selections, preferences, and other Input you submit to generate content;
• Generated Content such as passages, questions, quizzes, collections, saved items, favorites, and related materials;
• communications you send to us, including support messages, feedback, bug reports, and legal notices; and
• any information you choose to include in forms, emails, or other communications with Picobuddy.

2.2 Learner-Related Information

Learners do not create their own Picobuddy accounts. However, when an Account Holder shares a learner-facing quiz or practice link, Picobuddy may collect learner-related information connected to that activity.

• a learner label or identifier entered by the Account Holder or user of the link, which may technically include a nickname, initials, or a real name;
• quiz responses, answer selections, scores, and completion data;
• timestamps and activity records associated with quiz or practice attempts; and
• technical data associated with access to learner-facing links, such as device/browser information, IP address, session information, and related security or analytics logs.

2.3 Information Collected Automatically

• IP address;
• browser type, device information, operating system, and language settings;
• pages viewed, links clicked, features used, and other usage events;
• referring pages, timestamps, approximate location based on IP, and session data;
• cookie and similar technology data; and
• diagnostics, crash information, and security-related logs.

2.4 Information from Third Parties

• authentication providers such as Google and Microsoft;
• payment providers such as Stripe;
• analytics providers such as Google Analytics; and
• other technical, infrastructure, communication, hosting, storage, and AI service providers we use to operate the Services.

3. How We Use Information

We may also use prompts, Input, and Generated Content to operate, improve, develop, demonstrate, moderate, and promote the Services, as described in our Terms of Service.

• to provide, operate, maintain, and improve the Services;
• to authenticate users and manage account access;
• to generate passages, quizzes, collections, and other educational materials;
• to enable public Library publication, unlisted hosting, downloads, links, and learner activities;
• to process subscriptions, payments, renewals, billing support, and related transactions;
• to communicate with you about your account, purchases, support requests, updates, and service-related notices;
• to send newsletters, product updates, and promotional emails where permitted by law and subject to opt-out options;
• to analyze usage, monitor performance, troubleshoot issues, and improve user experience;
• to detect, investigate, prevent, and address fraud, abuse, misuse, moderation issues, and security incidents;
• to enforce our Terms of Service and other policies;
• to comply with legal obligations and respond to lawful requests; and
• to protect Picobuddy, our users, Learners, service providers, and the public.

4. Legal Bases for Processing

• Contract: where processing is necessary to provide the Services you requested, including account access, subscriptions, billing, content generation, downloads, and learner-facing links;
• Legitimate Interests: where processing is necessary for service improvement, security, fraud prevention, moderation, analytics, product development, diagnostics, recordkeeping, support, and protection of our business and users;
• Consent: where required, for example for certain cookies, optional marketing communications, or other optional processing activities;
• Legal Obligation: where processing is required to comply with tax, accounting, consumer protection, law enforcement, or other legal obligations.

5. Public Library, Unlisted Content, and Visibility

If an account is deleted, canceled, or otherwise closed, public Library passages may remain available to the community, attribution to the original account may be removed or anonymized, unlisted passages may remain hosted by Picobuddy, and associated personal data will be deleted, anonymized, or de-linked as described in this Privacy Policy, except where retention is required or permitted by law.

• Unless created through Private Mode where available, passages generated through the Services are published to the Picobuddy Library by default and may be used by the community.
• Where available, users may also choose profile settings, such as Anonymous Mode, that limit whether their profile identity is displayed alongside publicly available passages.
• Where offered on a paid plan, Private Mode means a passage is unlisted, meaning it is not published to the public Library.
• Private Mode does not necessarily mean offline storage or deletion. Unlisted content may still be hosted by Picobuddy and may remain accessible through the relevant direct link or internal service functionality.

6. Children’s Privacy and Learner Data

Picobuddy is not designed for children to create direct consumer accounts.

Children may access learner-facing quizzes or practice links only through an adult Account Holder and under that adult’s responsibility.

Picobuddy prefers that Learners be identified by nicknames or initials rather than real names. Account Holders must not intentionally submit unnecessary personal information about children in prompts, passage descriptions, learner fields, or other free-text inputs.

If Picobuddy becomes aware of prohibited, excessive, or inappropriate child personal data, or content that creates privacy, safety, legal, or moderation risk, we may review, edit, unpublish, restrict, disable, or delete the relevant content, links, or associated account access.

• how learner-facing links are shared and used;
• obtaining any authorization or consent required for their use case;
• choosing what learner information is entered into the Services; and
• complying with applicable child privacy, education, and consumer protection laws.

7. Cookies and Similar Technologies

Picobuddy uses cookies and similar technologies for core functionality, security, sign-in, analytics, and related service purposes.

Picobuddy does not currently describe advertising or retargeting pixels in this Privacy Policy as active service features. If we add advertising, retargeting, or other non-essential tracking technologies in the future, we may update this Privacy Policy and any cookie notice or consent tools as required by law.

• essential cookies or similar technologies needed for authentication, security, session management, and core site functionality;
• analytics technologies used to understand how users interact with the Services, including through Google Analytics; and
• preference technologies that help remember settings or improve the user experience.

8. When We Share Information

Picobuddy does not sell personal data in exchange for money.

• with service providers and processors that help us operate the Services, such as hosting, storage, database, analytics, authentication, billing, email delivery, infrastructure, security, and AI-related providers;
• with payment providers such as Stripe to process subscriptions and transactions;
• with authentication providers such as Google and Microsoft when you choose to sign in using those services;
• with analytics providers such as Google Analytics;
• with communication providers such as Brevo for email delivery;
• with hosting and infrastructure providers such as SiteGround and Firebase;
• where necessary to comply with law, regulation, legal process, or lawful requests;
• where necessary to investigate, prevent, or address fraud, abuse, security issues, or violations of our Terms or policies;
• in connection with a merger, acquisition, financing, reorganization, sale of assets, or similar business transaction; and
• where you direct us to share information, such as by using shareable links or publicly publishing content.

9. International Data Transfers

Picobuddy is operated from the Netherlands, but the Services may rely on providers located in other countries, including the United States and other jurisdictions.

As a result, personal data may be transferred to, stored in, or accessed from countries outside your own jurisdiction. Where required by law, we rely on appropriate safeguards for international transfers.

10. Data Retention

• account data is retained while your account is active and for a limited period afterward as needed for support, security, fraud prevention, backups, and legal compliance;
• billing, tax, and transaction records may be retained for as long as required by applicable tax, accounting, and financial reporting laws;
• public Library passages may remain available after account deletion without account attribution;
• unlisted passages may remain hosted after account deletion or cancellation;
• learner quiz and practice attempt data may remain in databases where needed to support hosted content, system integrity, analytics, recordkeeping, abuse prevention, or legal compliance; and
• where account deletion occurs, personal data associated with the deleted account will be deleted, anonymized, or de-linked so that it is no longer reasonably attributable to an identified person, except where retention is legally required or technically necessary for limited backup, security, fraud-prevention, or similar purposes.

11. Security

Picobuddy uses reasonable technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure.

However, no internet-based service or storage system can be guaranteed to be completely secure. You are responsible for maintaining the security of your devices, account access methods, and connected third-party sign-in accounts.

12. Your Rights and Choices

Depending on where you live, you may have rights regarding your personal data, subject to applicable law.

You may also update certain account information through your account or sign-in provider, unsubscribe from marketing emails using the unsubscribe link in those messages, and stop using the Services or cancel your subscription at any time, subject to the Terms of Service.

We may need to verify your identity before responding to certain requests.

• access personal data we hold about you;
• request correction of inaccurate or incomplete personal data;
• request deletion of your personal data;
• object to or restrict certain processing;
• withdraw consent where processing is based on consent;
• request portability of certain personal data; and
• lodge a complaint with a competent data protection authority.

13. Third-Party Services and External Links

Picobuddy may contain links to third-party websites, platforms, or services, or may rely on third-party functionality for sign-in, payment processing, analytics, communications, hosting, storage, or AI-related features.

This Privacy Policy does not govern the privacy practices of third parties. Your use of third-party services may also be subject to their own terms and privacy policies.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

If we make changes, we will post the updated version on the Picobuddy website and update the Last Updated date above. If we make a material change, we may provide additional notice where appropriate, such as by email or in-product notice.

15. Contact Us