Draft for review by a licensed attorney before publication.
Names Trainer Privacy Policy
Effective: [EFFECTIVE DATE] Operator: [COMPANY/OPERATOR NAME], [POSTAL ADDRESS], [CONTACT EMAIL]
Names Trainer is a flashcard app for learning people's names from their photos. This policy explains what data the app handles and what you can do about it. The short version: everything stays on your device unless you sign in, and we do not track you.
1. The app works without an account
By default, everything you add (photos, names, notes, study progress, settings) is stored only in your browser's or device's local storage (IndexedDB) and is not sent to us. If you never sign in, we receive no personal data from you beyond the ordinary server logs described in section 4. Settings lets you export a full backup or erase everything on the device.
2. What we collect if you sign in
Signing in is optional; you need it only to back up or share a deck.
| Data | Why |
|---|---|
| Your email address | Your sign-in link (we use no passwords) and account messages |
| An optional profile name or handle | Shown to people you share with and to owners of decks you join |
| Decks you upload: titles, descriptions, names, notes, memory hooks, photos | Storing them and showing them to the people you share with |
| Study progress for synced decks | So progress follows you between devices |
| Which shared decks you have joined or installed | Your deck list; owners see who joined |
| Reports you submit about a deck | Reviewing the deck and responding |
Photos are resized to 640 pixels and camera metadata (EXIF, including any location) is removed on your device before upload.
We do not collect: location, contacts, device identifiers, advertising identifiers, usage analytics, crash reports, or anything from other apps.
3. No facial recognition, no biometrics
We do not use facial recognition, and we do not create, store, match, or share biometric identifiers or templates. When you import photos, the app may use your device's built-in face detection solely to choose where to crop the picture. That runs entirely on your device, and nothing from it is stored or sent anywhere.
4. Where data is stored and who processes it
- Cloud storage and sign-in: Supabase. Account data, decks, photos, progress, and reports live in a Supabase project (Postgres database and file storage) hosted in [REGION]. Supabase also sends the sign-in email. If you are in the EU, UK, or Switzerland, your data is transferred to [REGION] under our processors' standard contractual clauses or equivalent safeguards.
- Hosting: Cloudflare. The app is served by Cloudflare Pages. Like any host, Cloudflare and Supabase keep short-lived server logs (IP address, request details) for security and reliability, typically under 30 days. The app also fetches a small version file from our server to offer updates; no identifier is sent.
That is the full list. The app loads no third-party scripts, fonts, SDKs, analytics, or advertising, and makes no other network requests.
5. Legal bases (GDPR and UK GDPR)
- Performing our contract with you: your email, profile, decks, photos, progress, and memberships, which we need to provide the account, sync, and sharing you asked for.
- Legitimate interests: server logs, abuse prevention, and handling reports, so the service stays secure and lawful. You can object at any time.
- Consent: where you choose to publish a deck. You can withdraw it by making the deck private again.
Uploading other people's photos and names for your own personal use is generally a household activity. If you do it for a school, employer, club, or other organisation, that organisation is responsible for having a lawful basis, and we process the content on its behalf. See section 8.
6. Sharing
We do not sell, rent, or trade personal data, and we do not share it for advertising (no "sale" or "sharing" under the CCPA/CPRA).
Your decks are private by default. They are visible to others only if you:
- Share by link. Anyone with the link can sign in and study the deck. You can see who has joined, remove people, and stop the link.
- Publish. A published deck is public and can be found and studied by anyone. Only publish decks of public figures, or where everyone pictured has agreed.
Beyond our processors, we disclose data only where the law requires it.
7. Retention
- Local data stays on your device until you delete it or clear the app's storage.
- Cloud data is kept while your account is active. Deleting a deck deletes its cards and photos. Leaving a shared deck deletes your progress for it.
- Deleting your account deletes your account, decks, photos, progress, and memberships. Backups held by our processors expire within [30] days.
- Reports are kept for [12 months] so we can handle repeat problems.
8. Photos of other people
You may upload photos and names of other people only if you have the right to, for example colleagues' directory photos for your own use, or with their permission. Keep such decks private, or share by link only with the people who need them. Never publish a deck of private individuals, and never include children in a published deck. Teachers and youth leaders: see minors-and-consent.md.
If your photo is in someone's deck and you want it removed, email [CONTACT EMAIL] with the deck link (if you have it) and enough detail to identify the photo. We will remove it from any published or link-shared deck and contact the owner about private decks. We aim to respond within [5] business days.
9. Your rights
You can:
- Access and export everything: Settings exports a complete backup, including photos and progress, in open formats (JSON, JPEG, CSV).
- Correct anything by editing it.
- Delete decks, photos, or people in the app, or your whole account (below).
- Object to or restrict processing based on legitimate interests.
- Complain to your data protection authority (EU/UK) or state attorney general (US). We never discriminate against you for exercising a right.
Account deletion: use "Delete account" in Settings, or email [CONTACT EMAIL] from your sign-in address. We complete deletion within [30] days and confirm by email.
10. Children
Names Trainer is not directed at children under 13, and we do not knowingly collect their personal data. If you believe a child under 13 has created an account, email [CONTACT EMAIL] and we will delete it.
11. Security
All traffic uses HTTPS. Per-row access rules in the database mean each person can read only their own data and the decks shared with them, and photos in private and link-shared decks are served only to signed-in people with access. No system is perfectly secure, so keep a local backup of anything you cannot afford to lose.
12. Changes
We post changes here with a new effective date, and for material changes we notify signed-in users by email or in the app before they take effect.
13. Contact
[COMPANY/OPERATOR NAME] [POSTAL ADDRESS] [CONTACT EMAIL]