Adapty privacy policy
Who is responsible: Tavana Labs B.V. (KvK 42030516), Amsterdam — info@tavanalabs.com
Adapty helps people who have moved to the Netherlands understand official letters and keep track of what to arrange. To do that it handles personal and sometimes sensitive information, so this page says plainly what we collect, why, who else processes it, how long we keep it and what you can do about it.
What we collect
- Your situation — what you tell Adapty to build your plan, such as when you arrived, your residence route, your gemeente and who moved with you.
- Letters you scan — the pictures and the text read from them. Your BSN and V-number are blacked out on your phone before anything is uploaded. This is automatic and not perfect, so a number can occasionally remain visible.
- Questions you ask and Adapty's answers. If you speak a question, the recording is turned into text and not kept. Adapty may remember facts from your questions for next time; you can see and remove them in Me → What Adapty remembers.
- Your account — if you sign in with Apple or Google, we receive an identifier and your email address from them, not your name. If you choose Apple’s “Hide My Email”, we keep no email address at all.
- Your device — a notification token, if you allow reminders.
- Usage counts — only if you switch on “Count how far I get” in Me → Privacy. It is off by default, counts steps such as “a letter was scanned”, never sends content, and is not linked to your account.
There is no advertising in Adapty, and no tracking across other apps or websites.
Our website, adapty.nl, is hosted by Vercel, which receives your IP address to serve the pages. It counts page views, clicks on its install button and uses of the Ask box with Vercel Web Analytics, without cookies and without identifying you.
The Ask box on adapty.nl. You can ask a question on our website without an account. Before your question is stored or sent anywhere, any number of nine or more digits, such as a BSN, is removed from it. The question is sent to Google Cloud in the EU to find and write an answer from official sources and our own pages.
We check each question for personal details, such as a name, a relative, an address, a date of birth, a phone number or something about your health. If we find any, the question is deleted as soon as the answer has been shown to you, or after 15 minutes if it never is.
If we find none, and the question is in English or Dutch, we keep it for up to 90 days to improve Adapty's answers. We keep it without your internet address and without the date or time you asked: only the week. Our check is automatic and can miss something, so please don't type your name or other personal details into the box. For questions about your own situation, use the app.
Beyond that we keep only counts, such as how many questions were asked each day. Questions are never in our backups. To stop one visitor using the box up, we count questions per internet address, stored only in scrambled form and for at most 14 days. Our server's log of these requests does not record your internet address.
Why we use it, and on what legal basis
To explain official letters you scan, track the deadlines in them, and answer your questions from official sources.
We use your information only to provide Adapty to you (article 6(1)(b) GDPR). Letters about your health or an asylum procedure are special categories of data: Adapty reads them only after you have given explicit consent for that kind of letter (article 9(2)(a) GDPR), and you can withdraw it at any time in Me → Privacy. Letters about criminal matters are refused and not processed. Usage counts rely on your consent and stop when you switch them off. We use your email address to write to you about your account, such as a warning before an unused account is deleted or a change to these terms (article 6(1)(b) GDPR). We send news, tips and offers only if you switched that on, and you can switch it off in Me → Privacy or with the link in any such email (article 6(1)(a) GDPR). Questions asked on our website are handled on the basis of our legitimate interest in answering them and in improving our answers (article 6(1)(f) GDPR).
Who else processes it
Only companies that process it for us, under contract: Google Cloud, for the AI that reads letters and drafts answers, in the EU; Hetzner, which hosts our servers and backups in Germany; Langfuse, in the EU, which receives technical performance data with anonymous ids and never your letters or questions; and Apple and Google to sign you in, and Apple to deliver reminders. We never sell your data, and we never send your letters to any government body — you do that yourself.
How long we keep it
- Letters: 24 months, or 12 months for letters about health or asylum.
- Your plan and your conversations: until you delete them or your account.
- An account nobody has used for 24 months is deleted, after we have warned you.
- A download of your data stays available for 48 hours.
- Backups are kept for 30 days, so something you delete is gone from them within 30 days.
- Questions asked on adapty.nl: if we find personal details, until the answer is shown and at most 15 minutes; if we find none, up to 90 days, without your internet address or the date you asked.
How we protect it
Everything travels encrypted. Letters are stored encrypted, on servers in the EU. Your data is separated per person inside the database, so one person's records cannot be read through another's account.
Your rights
You can see and download everything Adapty holds about you (Me → Download my data), correct anything that is wrong in the app, delete a letter or a conversation, withdraw a consent (Me → Privacy), pause your account (Me → Pause my account), and delete your account and everything in it (Me → Delete my account). You also have the right to object to or restrict how we use your data. For anything else, write to the contact address above; we answer within one month.
You can complain to the Autoriteit Persoonsgegevens, the Dutch data protection authority, at autoriteitpersoonsgegevens.nl.
Children
Adapty is not meant for anyone under 16.
Changes
When this policy changes, the date at the top changes with it. If a change affects what we do with data you have already given us, we will tell you before it applies.