Legal
Privacy policy
Effective date: TODO. set on legal review · Version 0.1-draft
Not reviewed by a lawyer yet TODO
This page is drafted from a code-derived data map (LEGAL-DISCLOSURE-MAP.md),
not from a template — but generated and drafted legal prose is fluent and can still be
wrong about what actually happens. Every section below with a TODO
marker needs a qualified lawyer's review before this page governs anything. Do not treat it
as final.
1. Who controls this data TODO
alcoia (TODO: legal entity name and form), registered address TODO, is the controller for the purposes of the GDPR and UK GDPR. Contact: privacy@alcoia.com. If alcoia is established outside the EU/UK at launch, an Art. 27 representative will be named here TODO. A Data Protection Officer will be appointed and named here only if Art. 37 requires one; that assessment is TODO.
2. What is collected
| Data | When | Sent to |
|---|---|---|
| Paragraph text (current, and sometimes the preceding one for context) | Automatically, when the reading engine decides to summarise or ask a question | Our backend → Groq (US) |
| Selected text or a word plus its sentence | When you select text or Ctrl+hover a word with those features on | Our backend → Groq (US) |
| Whole-page text | Only if you ask "What is this page about?" | Our backend → Groq (US) |
| The reading receipt | Only if you click "Sign it" | Our backend only. never Groq |
| IP address | Every request to our backend | Our backend and host, for rate limiting and security |
| A request to a Google-operated host (tfhub.dev) | Only if you turn the camera on, the first time a face-detection model is needed | Google (US), directly from your browser |
Never collected or transmitted: webcam video, images, or frames of any kind; raw gaze coordinates; the trained on-device gaze-calibration model.
Kept on your device only, never transmitted: a list of pages you've read (URL and title, so the extension can show you your own session history), saved notes and highlights, reading-rate baselines, gaze-derived calibration features, and your settings. including whether dyslexia mode or bionic reading is on, which we treat as a disability-adjacent inference and never transmit or use for segmentation of any kind.
3. Legal basis for each purpose (GDPR Art. 6) TODO
- Generating questions and explanations from passage text: performance of a contract with you.
- Camera-based presence/region detection: consent. freely given, specific, informed and withdrawable at any time, and never a condition of installing the extension.
- Rate limiting and abuse prevention using IP addresses: legitimate interest, documented in a legitimate-interest assessment TODO: attach LIA.
4. Retention TODO
Question and explanation responses are cached server-side by content hash, not by user, for 24 hours. Signed receipts are not persisted by the server. Retention periods for every other category. account data, support correspondence, locally-stored session history. are TODO: set and publish per category.
5. Sub-processors
| Sub-processor | Purpose | Location |
|---|---|---|
| Groq | LLM inference for questions and explanations | United States |
| TODO: name host | Application hosting | TODO |
| Creem | Payment processing, merchant of record | TODO |
| Google (tfhub.dev) | Face-detection model download, camera path only | United States. only while this dependency is undisclosed-and-live; see the open item below |
International transfers to the US are made under TODO: Standard Contractual Clauses, or Data Privacy Framework certification per recipient. confirm and cite for each one.
6. Your rights
Subject to your jurisdiction, you have the right to access, rectify, erase, restrict, object to, and port your personal data, and the right to complain to your supervisory authority. To exercise any of these, contact privacy@alcoia.com. We do not use automated decision-making that produces legal or similarly significant effects about you.
7. California (CCPA/CPRA)
We do not sell or share your personal information, and we honour Global Privacy Control signals as an opt-out request. Categories collected are itemised in section 2. You have the right to know, delete, correct, opt out, and limit use of sensitive personal information (which applies to gaze-derived data if the camera is used), without discrimination for exercising any of these rights.
8. Canada (PIPEDA)
Processing is based on meaningful consent appropriate to the sensitivity of the data involved. Breaches that create a real risk of significant harm are reported to the Office of the Privacy Commissioner of Canada and to affected individuals.
9. Chrome Web Store limited use
alcoia's use of data obtained through Chrome Web Store APIs adheres to the Chrome Web Store User Data Policy, including the Limited Use requirements. Data is not sold; not used for advertising or ad personalisation; not used to train AI or ML models; not transferred except to provide or improve the user-facing features of the extension, or as required by law; and accessed by humans only for security, legal compliance, or with your explicit consent.
10. Age
alcoia is intended for users aged 16 and over. It is not directed at children, and we do not knowingly collect personal data from anyone under 16. If your institution intends to deploy alcoia to users under 16, contact us before doing so. additional terms (including FERPA) apply and are not yet in place. See the open item on the tfhub.dev transfer below.
11. Changes to this policy
Material changes will be dated and noted here, with prior versions available on request. Version history: TODO: begin on first published version.
12. Open item this policy depends on TODO
Section 5 discloses a request to a Google-operated host that occurs only on the camera
path. The preferred fix is bundling the face-detection model so the request never
happens; until that ships (or the request is otherwise removed), this disclosure has to
stay accurate and visible, not softened. See LEGAL-DISCLOSURE-MAP.md Finding 1
in the repository for the full technical detail.