Privacy policy

Version 1.3 · 24 October 2026

1. Who and what

NitroStudy · Kemax12 (vof) · Falckstraat 21, 2515 KM Den Haag · KvK 93024290 · btw NL866251777B01. Contact info@nitrostudy.com. We decide why and how personal data is used for NitroStudy. We receive details from you, a learner entering a guardian address, linked accounts and necessary payment/security events.

This includes your name or nickname, email, account ID, age group, role, preferences, guardian address and linking status, uploads and generated study material, study activity and practice feedback, billing status, purchase evidence and the billing address supplied to Stripe for tax calculation, correspondence and security data such as IP address, timestamps and browser details. The authentication service processes your password; the payment provider processes full card details. You do not need to include sensitive private information in study material or conversations.

2. Purposes and legal bases

Account identity, login and requested storage support the service agreement. Personalised study processing uses uploaded content, questions, answers, activity and derived practice feedback; under 16 we require active guardian consent, and otherwise use the service agreement where necessary. Optional parent oversight is a separate choice that can be withdrawn. Payment administration uses the agreement and legal accounting obligations. Security and handling correspondence rely on legitimate interests in preventing abuse, protecting systems and answering requests with proportionate safeguards. Optional analytics is disabled. We do not sell your information or use it for advertising profiles.

3. AI and audio

After registration, you choose your own nickname. We check it using local rules and OpenAI's free moderation endpoint to reject discriminatory, hateful or abusive names. Only the chosen nickname is sent for this check; name checks do not consume your personal learning budget.

New registrations are temporarily available only from age 18. Direct text AI remains blocked for younger accounts until the required privacy setup is confirmed. Paid subscriptions are available to authorised adult purchasers. Plus, Ultra and Ultimate have internal cost budgets for new AI tasks of at most €10, €12 and €25 respectively per monthly subscription period. The daily allowance equals the corresponding monthly budget divided by 30, per 24-hour period. Unused daily allowance does not accumulate. Text and personal podcast audio share this budget; costs are conservatively reserved in advance. Annual subscriptions have separate monthly budgets. Saved lessons remain accessible. Each free account has a conservatively reserved AI budget of at most €0.01 per 24-hour period. A separate safety limit of €1 per UTC day applies across all free accounts. Once reached, new free AI tasks are temporarily unavailable; saved work remains accessible. A task exceeding the remaining budget is not started. Failed or uncertain provider attempts can still consume the budget.

Necessary text, study context and, where needed, images or PDF content are sent directly to the OpenAI API. Text uses GPT-6 Luna. We disable response storage for these requests (store: false); this does not by itself confirm ZDR approval. Podcast speech uses OpenAI gpt-4o-mini-tts directly. Live conversations are currently disabled. ZDR for this direct route has been requested but not confirmed; we do not describe it as an approved ZDR route. For users aged 12–15 and accounts without a recorded age group, personal audio through the direct OpenAI route is blocked until the required ZDR setup is confirmed. Parental approval alone does not remove this block. There is no silent fallback to another service. Provider billing and operational metadata may still exist: ZDR does not mean no records of any kind. NitroStudy does not itself train models on your material. The owner has enabled input/output sharing for complimentary daily tokens on the OpenAI project in use. OpenAI may therefore use shared inputs and outputs for model improvement and training. This is not a ZDR route. Do not share confidential, sensitive or unauthorized content; complimentary tokens do not change this processing. We use study feedback to tailor practice, not to decide school admission or official grades. We do not make solely automated decisions with legal or similarly significant effects. Without necessary account details we cannot provide an account; optional oversight can be stopped without deleting the learning account. Withdrawal does not make earlier lawful processing unlawful. From age 16, you can explicitly restart through the privacy controls after your own withdrawal. We check your recorded age group and identity; this does not override a parent pause or deletion. Existing valid parent links may show limited progress again; you can stop that oversight separately. Subscription renewal is not restarted automatically. Under 16, fresh parental approval is required; contact us to arrange this.

A live conversation uses your microphone after you start it. Audio is sent to OpenAI during the conversation. Each session lasts at most ten minutes; you can stop earlier. NitroStudy does not save the raw question recording as a study file; the transcript and answer may be saved with your activity. Generated lesson audio is saved for playback. Browser speech recognition and online browser voices are not used in this route; an available local device voice may read text without sending it to a browser provider.

4. Children and parents

We keep an age group, based on your declaration. Under 16 the workspace stays blocked until an email recipient actively declares parental responsibility and consents. We confirm email access, not identity or legal parenthood; additional checks are used when doubt or risk requires them. Privacy consent does not purchase anything. Learners aged 12 and over can exercise their own applicable privacy rights.

A parent sees how much and when you learn, never your subjects, files, answers or tutor conversations. A parent may use the ordinary unlink action. The learner may stop oversight through the privacy action or withdraw study-processing consent online. Limiting the ordinary unlink button does not remove a right to withdraw consent. Full withdrawal blocks learning and oversight and stops subscription renewal; necessary legal records are retained. An old parent link cannot unilaterally reactivate learner-withdrawn consent. Contact us if you later want to restart.

A study link is not payment authority. The recorded buyer can separately authorise linked parents to manage billing. A plan-request link expires after seven days; opening it buys nothing.

5. Recipients and locations

Firebase/Google Cloud provide login, private storage and databases. OpenAI directly processes text, necessary document content, podcast speech and live audio. Resend delivers transactional email; Google reCAPTCHA protects forms; Cloudflare provides website protection where configured; Stripe processes payments and billing. We arrange processor agreements where providers act as processors. Stripe and other providers may also act as independent controllers for their own legal accounting, fraud prevention or security purposes. Device-local speech stays on the device.

For processing outside the EEA we use the applicable adequacy decision, including eligible Data Privacy Framework participation, or standard contractual clauses with supplementary safeguards where required. The processing may take place in the United States or other countries outside the EEA. Service regions do not by themselves prove that all support access remains in the EEA. Ask us for details of relevant safeguards.

6. Retention

Account material and progress remain while needed for your active account; you can request deletion. Pending consent never grants access. For unfinished registration we keep only data needed to complete registration, secure the service and preserve necessary evidence. Request earlier deletion if you will not continue; waiting for consent does not justify indefinite retention. Codes expire after 10 minutes and verification grants after five minutes. Expired temporary records are no longer usable; the operational cleanup procedure removes unnecessary metadata. Parent control links last 90 days; expired links do not reopen access.

Our retention policy provides for: routine correspondence normally up to two years after resolution, security/application logs normally 30 days, accounting records normally seven years and OSS evidence ten years where applicable. Requests, disputes or legal duties may justify limited longer retention. Provider security logs and backups may follow separate deletion cycles; deletion does not imply instant erasure from every backup. Account deletion removes active study data while legally necessary payment and rights-handling evidence is retained with limited access.

7. Public sharing

Accounts are private. Publishing a course or share link makes a snapshot of its summaries and titles accessible to other users, without original files. Do not include personal data in content you publish. Unpublishing prevents new access but does not remove copies already imported by others. A public ranking may display your chosen name. Avoid full names and other private details and contact us if you want visibility stopped.

8. Your rights and safety

You can request access, correction, erasure, restriction, applicable portability, objection and withdrawal of consent. Use Settings → Parents / Privacy, account deletion under Security, or info@nitrostudy.com. We normally respond within one month; a permitted extension is explained within that month. Verification is proportionate, not an automatic request for an identity-document copy. Parents can represent children where legally authorised; statutory privacy rights remain with the learner as applicable.

We restrict access, use encrypted connections and protect against abuse. We assess incidents and notify authorities and affected people where legally required. Complain to the Dutch Autoriteit Persoonsgegevens if needed. Material privacy changes are explained before they apply.