Privacy Policy

Last updated: May 17, 2026

Coursly ("we", "our", "the app") is a student productivity app that connects to your university's Moodle™ learning management system. This policy explains what data we collect, why, and how we protect it.

1. Data Controller

The data controller responsible for your personal data is Andres Goncalves, Luxembourg. Contact: adonapp@proton.me. We are not required to appoint a Data Protection Officer under GDPR Article 37. For all data protection inquiries, contact us at the email above.

2. Data We Collect

Account data. When you sign in via your university Moodle™, we create a Supabase account using your Moodle email address. We store your email and a hashed authentication token. We never store your Moodle password.

Moodle course data. With your permission, we sync your course list, assignments, deadlines, grades, and uploaded course documents from your Moodle account. This data is stored locally on your device and in our Supabase database.

AI-processed data. Course documents and syllabi are sent to our AI service (via our Supabase edge functions) to extract deadlines, generate study plans, create revision quizzes, and process voice tasks. We use the Groq API with the openai/gpt-oss-20b model. Document content is sent for processing only and is not stored by our AI provider beyond the duration of the request.

Usage data. We track AI feature usage counts (course analyses, study plans, quizzes, voice tasks) to enforce free-tier quotas. Premium subscription status is tracked via Apple StoreKit.

Calendar data. If you grant calendar access, we read your calendar events to avoid scheduling conflicts and to provide smarter study suggestions around your real schedule.

Device motion data. We access device motion sensors solely for a decorative parallax effect during onboarding. This data is not stored or transmitted.

Voice data. If you use the voice task feature, you will be prompted to grant microphone and speech recognition permission before any recording begins. Audio is processed entirely on-device using Apple's Speech framework for transcription. Only the resulting text transcript is sent to our server for task extraction. Raw audio is never transmitted to or stored on our servers. No voiceprints, biometric identifiers, or audio recordings are created, stored, or shared. You may revoke microphone permission at any time through your device Settings.

Referral data. If you participate in our referral program, we store your referral code, the number of successful referrals, and the duration of any referral reward (free Premium access).

Notifications. With your permission, Coursly sends local notifications to remind you of upcoming deadlines and revision quizzes. No notification content is transmitted to our servers.

3. How We Use Your Data

4. Legal Basis for Processing (GDPR Article 6)

We process your personal data on the following legal bases:

5. Data Sharing

We do not sell, rent, or share your personal data with advertisers or data brokers.

We share data with these service providers solely to operate the app:

We have entered into data processing agreements with our service providers in accordance with GDPR Article 28.

Your Moodle credentials are authenticated directly with your university's Moodle server. They are never transmitted to or stored on our servers.

International transfers. When your course data is processed by Groq, it is transferred to the United States. This transfer is protected by the EU-US Data Privacy Framework and/or Standard Contractual Clauses, as applicable. You can request a copy of the applicable safeguards by contacting us.

Legal obligations. We may disclose your personal information if required to do so by law, regulation, legal process (such as a court order or subpoena), or governmental request. We will attempt to notify you before disclosing your information unless prohibited by law or court order. We may also disclose information if we believe in good faith that disclosure is necessary to protect our rights, investigate fraud, or respond to a government request.

6. Data Storage and Security

Server-side data is stored in Supabase (hosted in AWS EU-West / Ireland). Data is encrypted in transit (TLS) and at rest. Row-level security policies restrict each user to their own data. Edge functions use verified JWT authentication.

Local data is stored on your device using a SQLite database (GRDB) within the app's iOS sandbox. iOS Data Protection encrypts all app data at rest when your device is locked.

On-device storage. Coursly stores data locally on your device to provide its core features:

Data breach notification. In the event of a data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and inform affected users without undue delay, in accordance with GDPR Articles 33-34 and applicable US state breach notification laws.

7. Data Retention and Deletion

You can delete your account at any time from Settings. Account deletion:

Retention periods:

8. Your Rights (GDPR / EU)

If you are in the European Union, you have the right to:

AI-generated content is supplementary and does not produce legal effects or similarly significant effects on you. No automated decisions are made regarding your academic standing, grades, or access to educational services.

To exercise these rights, contact us at adonapp@proton.me. We will respond within 30 days.

9. Your Rights (US State Privacy Laws)

California (CCPA/CPRA). If you are a California resident, you have the right to:

Categories of personal information we collect (per Cal. Civ. Code § 1798.140):

We do not sell or share your personal information as those terms are defined under the CCPA/CPRA. We do not use your data for cross-context behavioral advertising.

We do not collect sensitive personal information as defined by the CPRA (Social Security numbers, precise geolocation, racial/ethnic origin, etc.).

Virginia (VCDPA), Colorado (CPA), Connecticut (CDPA), and other US states. If you reside in a US state with a comprehensive privacy law, you may have similar rights to access, delete, correct, and opt out of targeted advertising, profiling, and sale of personal data. We do not engage in targeted advertising, profiling for decisions that produce legal effects, or sale of personal data. To exercise any rights, contact us at adonapp@proton.me. We will respond within 45 days. If we deny your request, you may appeal by emailing us with the subject line "Privacy Rights Appeal."

Do Not Track / Global Privacy Control. Coursly does not track users across third-party websites or services and does not serve targeted advertising. We honor the Global Privacy Control (GPC) signal as a valid opt-out request.

10. Children's Privacy

Coursly is designed for university students aged 16 and older. We do not knowingly collect personal information from children under 13 as defined by the U.S. Children's Online Privacy Protection Act (COPPA), or from anyone under 16. If you believe a child under 16 has provided us data, contact us at adonapp@proton.me and we will promptly delete it.

11. Third-Party AI Disclosure

AI-generated content. Coursly uses artificial intelligence to analyze course materials and generate study plans, revision quizzes, deadline detection, and voice task extraction. You should be aware that:

We may change AI service providers in the future. The same data protection commitments described in this policy will apply to any new provider.

12. Changes to This Policy

We may update this policy from time to time. Material changes will be communicated via an in-app notice. The "last updated" date at the top reflects the most recent revision.

13. Contact

For questions or concerns about this privacy policy:

Email: adonapp@proton.me