⚠️ DRAFT — NOT YET LEGAL ADVICE. This draft is written to match the personal data BodhiTree OS actually collects today, and to meet UK GDPR / EU GDPR structure. It still needs review by a qualified solicitor or data-protection adviser before you publish it. Fill in every
[BRACKETED]placeholder, and keep the sub-processor list (section 6) accurate as your stack changes.
Fill these in before publishing:
- [COMPANY LEGAL NAME], [COMPANY NUMBER], [REGISTERED ADDRESS]
- [PRIVACY EMAIL] — e.g. privacy@bodhitreeos.com
- [EFFECTIVE DATE]
- Confirm your ICO registration (most UK companies processing personal data must register
with the Information Commissioner's Office and pay the data-protection fee).
Effective date: [EFFECTIVE DATE]
[COMPANY LEGAL NAME] (company number [COMPANY NUMBER]), registered at [REGISTERED ADDRESS],
is the data controller for the personal data described in this policy. For any privacy
questions or to exercise your rights, contact us at [PRIVACY EMAIL].
You give us: - Account data — your email address, your name (if you provide one), and a password that we store only as a secured hash (we never see or store your actual password). - Sign-in data — if you sign in with Google or GitHub, we receive your email address and basic profile name from that provider. - Support data — anything you send us when you contact support.
We collect automatically:
- Technical and usage data — your IP address, browser/device information, and log records of
actions such as sign-in attempts, which we use to run and secure the Service (including rate
limiting to prevent abuse).
- A device identifier (for trial-abuse prevention) — when you use the app on a free trial,
it derives an identifier for your device. We store only a one-way hash of it (and a hash of
your email), never the raw value — just enough to recognise that a device has already used a
free trial, so the same machine can't take unlimited free trials. It isn't used to track you or
for advertising, and it's stored locally on your Mac (in ~/.bodhitree) as well.
We do not collect: - Your card details — payments are handled by our Merchant of Record (Lemon Squeezy); we never receive or store your full card number. - Your source code, for local and Pro use — that stays on your own machine and is not sent to us. (If you ever use a feature that processes your code on our servers, we will tell you clearly and a Data Processing Addendum will apply.)
| What we do | Why | Legal basis (UK/EU GDPR) |
|---|---|---|
| Create and run your account; provide the Service | To deliver what you signed up for | Performance of a contract |
| Process payments and manage your plan/add-ons | To bill you and give you what you bought | Performance of a contract |
| Secure the Service (rate limiting, fraud/abuse prevention, logs) | To protect you and us | Legitimate interests |
| Send service emails (verification, password reset, important notices) | To operate your account safely | Performance of a contract / legitimate interests |
| Send marketing or product-update emails (if any) | To tell you about the product | Consent (you can opt out any time) |
| Meet legal and accounting obligations | Because we have to | Legal obligation |
We use your email address to verify your account, let you reset your password, and send essential service messages. These are necessary to run your account and are not marketing. Any optional marketing emails will only be sent with your consent and will always include an unsubscribe link.
[e.g. 6 years] for
financial records), then deleted or anonymised.We do not sell your personal data. We share it only with service providers who help us run the Service, under contracts that require them to protect it:
| Provider | What they do | Data involved |
|---|---|---|
| Railway | Hosting + database | Account data, technical/log data |
| Lemon Squeezy (Merchant of Record) | Payments, tax, licensing | Email, billing data (card data held by them, not us) |
| Anthropic / OpenAI (and any AI providers) | AI model processing | Prompts/inputs you send to those features |
| Google / GitHub | Optional social sign-in | Your email + basic profile, only if you use them |
[EMAIL PROVIDER] |
Sending account emails | Your email address |
| Sentry (error monitoring, if enabled) | Diagnosing crashes/errors | Technical error and log data; configured not to send personal data (PII) |
We will keep this list current. Note: when you use your own AI provider API keys, data you send goes to that provider under your account and their terms, not through us.
Some of our providers are based outside the UK/EEA (for example in the United States). Where your data is transferred internationally, we rely on appropriate safeguards such as UK/EU adequacy decisions or Standard Contractual Clauses (and the UK International Data Transfer Addendum) to protect it.
Under UK/EU data-protection law you have the right to: - access the personal data we hold about you; - ask us to correct inaccurate data; - ask us to delete your data ("right to erasure"); - object to or ask us to restrict certain processing; - receive your data in a portable format ("data portability"); and - withdraw consent at any time where we rely on consent.
To exercise any of these, email [PRIVACY EMAIL]. We will respond within the time limits the law
requires (usually one month). You also have the right to complain to the UK Information
Commissioner's Office (ICO) at ico.org.uk, or your local supervisory authority.
We take security seriously. Measures include: storing passwords only as salted PBKDF2-HMAC-SHA256 hashes; signing session and licence tokens; encrypting data in transit (HTTPS) and at rest; keeping our database on a private network; rate limiting to prevent brute-force and abuse; and limiting who can access data. No system is perfectly secure, but we work to protect your data and will notify you and the regulator of a breach where the law requires.
We use a single essential cookie to keep you signed in (a secure, HTTP-only session cookie). It is necessary for the Service to work and is not used for advertising or cross-site tracking. If we ever add non-essential cookies (for example analytics), we will ask for your consent first.
The Service is not intended for children. You must be at least 18 (or the age of majority where
you live) to use it, and we do not knowingly collect data from children. If you believe a child
has provided us data, contact [PRIVACY EMAIL] and we will delete it.
We may update this policy from time to time. If we make material changes, we will give reasonable notice (for example by email or in the app). The "effective date" at the top shows when it was last updated.
For any privacy question, or to exercise your rights, email [PRIVACY EMAIL].