Privacy policy
This draft describes data processing by [legal entity name]. Each section must match the data, services and providers actually used.
- Responsible entity
- [Legal entity name and registration details]
- Contact
- [Approved support channel and contact details]
- Last updated
- [Approval date for this version]
Responsible entity and contact
Data controller: [official name, address and registration details]. Activities and services: [short description]. Privacy contact and data protection officer, where applicable: [name or role and contact details].
Data categories and sources
List actual categories, whether required or optional, and their sources. Do not include data that is not collected:
- [Account, contact and profile data]
- [Survey answers, content and attachments]
- [Payment references, points and rewards; distinguish platform data from data held by providers]
- [Actual security, device, connection and cookie data]
- [Data received from other parties and its sources, if any]
Purposes and legal grounds
For each category, specify the purpose, use, appropriate legal ground and the consequences of not providing it: [category → purpose → ground → required or optional].
Where processing relies on consent, explain how consent is obtained and withdrawn and the effect on the relevant service: [actual process]. Explain significant analytics or automated processing, where applicable: [description and controls].
Retention, security and disposal
Specify retention rules and reasons by category, disposal or anonymization methods, backups and applicable legal obligations: [approved schedule].
Technical and organizational measures actually used to protect data: [appropriate description without sensitive security details]. This draft sets no default retention periods and promises no immediate deletion.
Rights, requests and complaints
Explain applicable rights and how to exercise them, including information, access, obtaining a copy, correction, requesting erasure and withdrawing consent where applicable: [approved channels and procedures].
Explain identity verification, responses or restrictions and their reasons, internal escalation and complaints to the competent authority: [contact details, procedures and reviewed timeframes].
Policy updates
Record the version, date, material changes and notification method: [change record and process]. The displayed document must match the version referenced by consent.