Draft — not yet reviewed or approved
This page is a structural placeholder. It has not been written or reviewed by a data protection officer or legal counsel, and it does not yet describe YAIRN’s actual commitments. Do not rely on it.
Privacy Policy
Last updated: Not yet published
Who is responsible for your information
TODO — Name the data controller, the privacy contact, and the DPO. The memo flags that this may be a joint-controller arrangement between the project and each participating school — that has to be settled before this section can be written.
What we collect
TODO — Describe each category in plain language and say why we need it.
Drafting note (from engineering)
What the platform actually stores today: your email address, an optional real name, a generated nickname, your school, your role, the interests you pick, and your consent choices. Then whatever you create — projects, artefacts (including any image, video or audio you upload), comments, forum posts, and private reflections (which can carry an image or voice memo). Plus activity records: when you last signed in, which projects you have viewed, and notifications sent to you.
No date of birth or age is collected. No analytics or tracking scripts of any kind are used. No location beyond your school’s city and country.
What other people can see
TODO — Explain the sandbox/community split and what the nickname does, at a reading level that works for a 16-year-old.
Drafting note (from engineering)
Other members see your nickname, never your real name. Draft work stays inside your school until a teacher publishes it. Private reflections are visible only to you and the project team — not to your teacher.
Our legal basis for using it
TODO — State the basis for each purpose. The memo warns that consent is often weak in a school-mediated setting because participation may not feel optional — so the essential processing likely rests on something other than consent, with consent reserved for the genuinely optional choices.
Where your information is stored and processed
TODO — List every country involved and the safeguards for each transfer. This is the section the memo treats as most important, and the one most likely to be got wrong.
Drafting note (from engineering)
The services that process data for YAIRN, and where:
- Supabase — database, sign-in, file storage — Canada (ca-central-1)
- Vercel — runs the website — region not pinned
- Cloudflare — DNS and traffic routing for yairn.ca — global
- Postmark — sends email — United States
- Google — optional sign-in — United States
- Anthropic — AI safety checks and summaries — United States
- OpenAI — search indexing — United States
Note for the drafter: text people write — including private reflections — is sent to Anthropic for an automated safety check on submission, and project text is sent to OpenAI for search. The EU–Canada adequacy decision does not cover either, because both are transfers to the United States rather than to Canada. See §4 of the review doc.
How long we keep it
TODO — Set a retention period per data category, plus what happens at the end of the project and how long backups persist. No retention schedule exists yet — this needs a client decision before it can be written or built.
Your rights
TODO — Cover access, correction, deletion, objection, withdrawing consent, and how to complain to a supervisory authority. Give a real contact address.
Drafting note (from engineering)
Not yet built: there is currently no self-service way to download your data, correct it, or delete your account. Until those exist this section must describe a manual process with a named human and a response time, not a button that does not exist.
Automated processing
TODO — Describe the automated safety check on posted content, that flagged content is hidden pending human review, and that no decision about a person is made by automation alone.
Keeping it secure
TODO — Summarise the safeguards without overstating them.
If something goes wrong
TODO — Set out the breach process, including reporting obligations and who tells participating schools. No incident runbook exists yet.
Changes to this policy
TODO — Explain that material changes mean asking people to review their choices again. The platform already ties every consent record to a policy version to support this.
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