Privacy Policy for the Plasticity iPad App

Last updated: 14 October 2026

This Privacy Policy explains how personal data is processed when you use the Plasticity iPad application ("Plasticity", "the app").

1. Data Controller

The controller responsible for the processing of your personal data within the meaning of the GDPR is:

Viktoriia Hrodetska
Heidenheimer Strasse 24
85748 Garching bei Muenchen
Germany
Email: info.foodb@gmail.com

You can contact the controller at any time if you have questions about this Privacy Policy or wish to exercise your data protection rights.

2. Overview

Plasticity is an AI-native iPad notebook for learners aged 16 and older who get stuck in the middle of handwritten work. You import a PDF or image, write with Apple Pencil, and can choose to ask a question by voice or text. After you grant AI-processing permission and ask Clay, Plasticity sends the disclosed page and question data to OpenAI's AI models, which return a teaching explanation and structured visual annotations that Plasticity draws over your work.

AI tutoring is a paid feature unlocked through a subscription purchased via the App Store and managed by RevenueCat. Plasticity is designed to minimize personal data collection:

• Plasticity never requires a user account, even for paid features. You may optionally sign in with Apple (Section 8). If you do not, subscription status is tied only to RevenueCat's own anonymous per-install identifier.
• Plasticity only emails you about your experience if you separately opt in (Section 9). Signing in is not consent to be contacted.
• Plasticity does not use third-party advertising networks.
• Plasticity does not use general-purpose analytics or advertising-tracking SDKs.
• The OpenAI API key is never shipped inside the app. Tutor and text-to-speech requests are relayed through a Supabase Edge Function that holds the key server-side and only forwards a request after confirming an active subscription.
• Notebooks, imported pages, ink, tutor marks, and conversation history are saved locally in the app's iOS sandbox so that notebooks remain available after the app closes. Plasticity does not provide cloud sync and does not upload complete notebooks to a controller-operated document store.
• No tutor or OpenAI text-to-speech request is sent until you complete Clay's onboarding and explicitly allow the disclosed AI processing. After confirming age eligibility, you can choose Continue without AI and use local notebook features. Tapping Clay presents the permission flow again, and permission can be withdrawn in Settings.
• Plasticity requests microphone and speech-recognition permissions to support push-to-talk questions. It does not request photo library, camera, contacts, or location permissions. Documents are imported through the system file picker rather than your photo library.

AI tutoring, voice interaction, and subscription management involve the external service providers described below. Notebook search, text recognition from handwriting or images, and conversion of selected handwriting into editable text run on your iPad and do not by themselves send content to OpenAI. The optional account and in-app feedback described in Sections 8 and 10 involve additional data when you use them. Section 9 explains product-email preferences saved in earlier versions; the current app does not invite new opt-ins.

3. Data You Provide and How It Is Used

Plasticity stores the following notebook data locally on your device and sends the listed subset for AI processing only after the permission and user action described in Sections 4 and 5:

• Page content: images of the current notebook page, including any imported PDF or image content, your handwritten ink, and previous AI-drawn teaching marks.
• Viewport information: the coordinates of the page region you are viewing, so the tutor can place explanations near your attention. The main tutor request contains the current page image and may separately include a pasted image; it does not currently add a magnified viewport crop.
• Questions: text you type, or speech you dictate using push-to-talk, converted to text by Apple's speech-recognition framework (Section 11).
• Conversation history: your questions and tutor replies are saved with the notebook locally; a limited recent portion is included in a tutor request to keep the conversation coherent across turns.
• Page interpretation: recognized text and layout from the current page, selected content, and, when available, up to 1,500 characters of recognized text from the previous page. This previous-page context is text, not an upload of the whole notebook.
• Retained scene data: identifiers and positions of teaching marks and questions the tutor has previously placed on the page, so later turns can revise or remove them consistently.

Purpose: to provide the core notebook, drawing, and AI tutoring features you request.

Legal basis:

• Art. 6(1)(b) GDPR, where processing is necessary to provide the app features you request.
• Art. 6(1)(f) GDPR, where processing is necessary for app security, troubleshooting, or maintaining reliable functionality.

Retention on your device: notebook pages, imported content, ink, tutor marks, and conversation history remain in the app's local sandbox until you delete the notebook or uninstall the app. Plasticity does not currently provide a controller-operated cloud backup or sync service. Copies included in iOS device backups are controlled by your Apple and device backup settings. Off-device retention by service providers is described in Sections 5 to 7.

Local recognition and search. Plasticity reads text embedded in imported PDFs and uses on-device recognition for handwriting and images to support search, selection, and conversion to editable text. It may store recognized text and its position on the page with notebook data and in local caches. Search indexes can be rebuilt; the app removes a notebook's search cache when you delete that notebook. Converted text saved on a page is notebook content. These features work without AI-sharing permission. If you later ask Clay, relevant recognized text may be included in the AI request described in Section 5.

Export and sharing. PDF exports are generated locally and may include handwriting, imported or pasted content, and Clay's marks if you choose to include them. The system share sheet lets you choose where to save or send an export. The chosen app, storage service, or recipient then handles that copy under its own terms and privacy practices. Plasticity attempts to remove its temporary export when the export screen closes or another export replaces it. Copies saved or shared outside Plasticity remain until you or the recipient delete them; deleting the notebook or Plasticity account does not remove those copies.

Limited tutor memory. When “Remember my learning” is enabled, Plasticity saves study-session timestamps and question counts, and, when Clay returns a work-check result, its tentative correctness assessment, topic and note. These records and a derived progress estimate are stored on this iPad, separately from notebook pages. They are not a cloud learner profile. A summary of earlier work checks in the same notebook, capped at approximately 400 characters, may be included in later AI requests. These estimates may be wrong and are not formal grades or decisions about admission, examinations or access to education. The purpose is to provide the notebook-specific personalization you use, under Art. 6(1)(b) GDPR.

You can pause saving and using this memory in Settings > Tutor Memory. Pausing keeps existing records. Reset a notebook's memory or choose Clear All Tutor Memory to erase saved assessments and session records without deleting your writing. Deleting a notebook or an account does not currently clear this separate memory store. It remains until you clear it or remove the app, subject to your device backups. Ordinary conversation context may still be sent with a tutor request when memory is paused.

4. Content You Choose to Write, Draw, or Say

When you allow AI processing and ask Clay, Plasticity sends the current page image, not the entire notebook, and the related request data described in Section 5. Whatever appears on that page or in your question may therefore be included. This may occasionally include information that reveals special categories of personal data under Art. 9 GDPR, for example if a homework problem, question, or note happens to reference your health, religion, or another sensitive topic.

Plasticity is intended for academic material and does not offer a service for processing identifiable people's health, religion, political views, sexual life, or other special-category personal data. Do not include such personal data, names, addresses or other unnecessary identifiers in material you send to Clay. A general AI-sharing checkbox is not treated as blanket explicit consent under Art. 9 GDPR, and your permission cannot authorize processing another person's sensitive information. If sensitive personal data has been sent inadvertently, contact the controller about removal and restriction where applicable.

You may withdraw AI-processing permission at any time in Plasticity Settings. This stops future tutor and OpenAI text-to-speech requests; it does not recall requests already sent or cancel an App Store subscription. You can separately delete notebooks and clear Tutor Memory. Withdrawal of any GDPR consent does not affect the lawfulness of processing before withdrawal.

Plasticity is not a medical, therapeutic, or professional service. Tutor explanations are educational and informational only.

5. AI Tutoring and Text-to-Speech via OpenAI

Before the first tutor request, Clay's onboarding identifies OpenAI and summarizes the data sharing below, with a detailed explanation available from “What exactly?”. It links to the Terms of Use and this Privacy Policy. Supabase relays these requests as explained in Section 7. A separate AI-sharing control is off by default; you must enable it before starting with Clay. You can instead continue without AI after confirming age eligibility. Continuing either way accepts the Terms, but continuing without AI does not grant AI-sharing permission. Closing the tour before age confirmation takes you to the privacy screen; it does not bypass the age requirement. Permission can be withdrawn in Settings, and Plasticity checks it at the tutor interface and before making an OpenAI-backed network request.

When an authorized subscriber asks a question, Plasticity sends the following to its Supabase Edge Function:

• The current page image, including visible handwriting, imported page content, pasted images, and existing tutor marks.
• An optional separately included pasted image and viewport coordinates.
• Recognized page text and layout, selected content, and available recognized text from the previous page.
• A short summary of earlier work-check results in the same notebook when tutor memory is enabled and assessments exist.
• The typed question or the transcript produced through Apple's speech-recognition service.
• Up to six recent conversation messages from the current page.
• Retained tutor-scene identifiers, positions, status, and other context needed to update teaching marks consistently.
• The RevenueCat subscriber identifier, which the proxy uses to verify access. The proxy supplies OpenAI with a derived one-way hashed safety identifier rather than forwarding the raw RevenueCat appUserID.

The Edge Function forwards the AI request to OpenAI's Responses API. If you enable spoken answers, the generated reply text is separately sent through the same proxy to OpenAI's text-to-speech API, which returns synthesized audio. If permission is not active, no OpenAI-backed request is made. If the subscription is not active, the tutor request is not forwarded and the app presents subscription options; local Apple speech synthesis remains available as a fallback where applicable.

Provider: OpenAI, together with its Ireland and U.S. group entities.

Purpose:

• Generating the tutor's explanation and structured visual annotations.
• Generating spoken narration of the tutor's reply.
• Troubleshooting failed or incomplete requests.

Legal basis:

• Art. 6(1)(b) GDPR, because AI tutoring and narration are the core functionality you request and pay for.
• Art. 6(1)(f) GDPR for troubleshooting, fraud prevention, and maintaining reliable operation.

The explicit in-app AI permission is an additional user control over third-party sharing. Accepting the Terms or having a subscription does not activate it automatically. The app is not designed to process special-category personal data, as explained in Section 4.

OpenAI's output is used to generate teaching explanations, visual annotations, narration, and tentative work-check assessments for the local memory described in Section 3. Plasticity does not use AI to make legally binding decisions about you and does not carry out automated decision-making within the meaning of Art. 22 GDPR that produces legal or similarly significant effects.

Data handling and retention: Plasticity's proxy forces `store: false` for Responses API requests. OpenAI states that API inputs and outputs are not used to train its models unless the API customer explicitly opts in. Under OpenAI's default API controls, abuse-monitoring logs may contain prompts, responses, and related metadata and may be retained for up to 30 days, unless longer retention is required by law or is reasonably necessary to protect the service or third parties from harm, or different retention controls apply. OpenAI's published controls and any account-level retention configuration may change; current details are available in OpenAI's API data-control documentation.

6. Subscriptions, Payments, and RevenueCat

AI tutoring and OpenAI-powered narration are unlocked through a Plasticity subscription purchased through the App Store and managed using RevenueCat. If you do not sign in, the only identity involved is RevenueCat's own anonymous, per-install appUserID, generated on-device and used to check entitlement status both in the app and by the Supabase proxy in Section 7. If you sign in with Apple (Section 8), your Plasticity account identifier is used as the RevenueCat appUserID instead, so your subscription is linked to your account.

Apple App Store. Payments are handled by Apple through your Apple ID. Plasticity does not receive or store your full payment card details. Apple may process Apple account data, purchase history, device information, payment information, and fraud-prevention information under Apple's own privacy terms.

Provider: Apple Distribution International Ltd., Ireland, and Apple group companies.

Purpose: app distribution, in-app purchases, subscriptions, refunds, and fraud prevention.

Legal basis: Art. 6(1)(b) GDPR for subscription access and Art. 6(1)(c) GDPR where legal retention obligations apply.

RevenueCat. Plasticity uses RevenueCat to manage the subscription, validate App Store receipts, restore purchases, display the paywall, and determine whether your install has an active "premium" entitlement.

Provider: RevenueCat, Inc., USA.

Data processed may include:

• The anonymous per-install appUserID, or your Plasticity account identifier if you sign in.
• If you sign in: the email address and, on first sign-in, the name provided by Sign in with Apple, stored as customer attributes so that the controller can recognize who a subscriber is.
• App Store receipt and transaction information.
• Product identifiers and subscription/entitlement status.
• Restore-purchase events.
• Technical device and app information needed for subscription management.

Purpose: subscription management, purchase validation, entitlement verification, restore purchases, and paywall display.

Legal basis: Art. 6(1)(b) GDPR for subscription functionality and Art. 6(1)(f) GDPR for fraud prevention and reliable operation of subscription features.

The in-app paywall's Terms of Service and Privacy Policy links open in an in-app browser and point to whatever URLs are configured for the offering in the RevenueCat dashboard.

Retention: Apple and RevenueCat may retain purchase, receipt, entitlement, device, and fraud-prevention records for the periods needed to provide subscriptions, maintain transaction history, meet accounting or legal obligations, resolve disputes, and prevent fraud under their respective policies. Deleting Plasticity does not by itself cancel an App Store subscription or erase records Apple or RevenueCat must retain. You can manage or cancel the subscription through Apple and may contact the controller regarding rights requests associated with the RevenueCat appUserID.

7. Server-Side Proxy: Supabase

Plasticity uses a Supabase Edge Function (openai-proxy) as a tightly limited relay between the app and OpenAI, so the OpenAI API key never ships inside the app binary. A second Edge Function (plasticity-account) and Supabase Auth support the optional features in Sections 8 to 10; that processing is described there.

Provider: Supabase, Inc., USA.

After the app's AI-permission checks allow a tutor or text-to-speech request, the Edge Function receives your RevenueCat appUserID and the applicable request payload. It calls RevenueCat's API to confirm an active subscription, records quota usage under a one-way hash of the installation identifier, and sends the validated AI payload to OpenAI using a server-side key only if the entitlement and quota checks succeed. The raw RevenueCat appUserID is used for the RevenueCat entitlement check and is not forwarded to OpenAI.

Data processed may include:

• The anonymous per-install appUserID, used to check entitlement with RevenueCat and transformed into one-way hashes for quota and safety controls.
• The request payload described in Sections 3–5, passed through to OpenAI.
• One-way hashed per-install request counters organized into burst, daily, and monthly usage windows.
• The request IP address, processed in memory for short-term rate limiting and potentially present in infrastructure security logs.
• Technical logs needed to operate, secure, and troubleshoot the function.

Purpose: keeping the OpenAI API key server-side, checking subscription entitlement before allowing a request, enforcing request and abuse limits, and routing AI/TTS requests.

Legal basis: Art. 6(1)(b) GDPR for providing the requested AI functionality and Art. 6(1)(f) GDPR for security and reliable operation.

Retention: for the tutor proxy, Plasticity's application database does not persist page images, questions, prompts, answers, narration text, raw RevenueCat appUserIDs, or IP addresses. IP-based burst-limit entries exist only in the active Edge Function instance and expire after a short rolling window. The database stores one-way hashed request counters needed for abuse prevention and cost limits. Old quota windows are periodically deleted after the current and recent monthly windows. Supabase may also process and retain operational or security logs according to its service configuration and published terms. You may contact the controller to request deletion of server-side data associated with your pseudonymous identifier where applicable.

8. Optional Account: Sign in with Apple

You can use every Plasticity feature without an account. In Settings you may choose to sign in with Apple so that the controller can recognize you as a customer and link your subscription to you.

When you sign in, Apple provides Plasticity with a stable user identifier and an email address. You may choose Apple's "Hide My Email" option, in which case Plasticity receives a private relay address that forwards to your real address. On the first sign-in Apple may also provide the name you choose to share.

Data processed:

• Supabase Auth stores your account: a Plasticity account identifier, the Apple user identifier, the email address provided by Apple, and sign-in timestamps.
• On your iPad, the app stores your session (account identifier, Apple user identifier, email address, and sign-in tokens) in the iOS Keychain on that device only.
• RevenueCat uses your account identifier as the subscriber identifier and stores the email address and name provided by Apple as customer attributes (Section 6).

Notebooks are not uploaded to your account. They remain on your iPad as described in Section 3.

Purpose: providing the account you request, linking your subscription to you, recognizing subscribers, and answering support requests.

Legal basis: Art. 6(1)(b) GDPR, because the account is a feature you request.

Signing out removes the Plasticity session from your iPad. Your server account and RevenueCat profile remain. The app returns to an anonymous subscriber identifier and attempts to synchronize the App Store purchase. If access does not appear, use Restore Purchases with the Apple Account that bought the subscription. Linking and restoration depend on Apple, RevenueCat and network availability; signing in does not create a second purchase.

Your App Store purchase belongs to the Apple Account used for Media & Purchases. That account can differ from the Apple Account used for Sign in with Apple. Switching either account does not automatically transfer ownership of a purchase. Restoring with another Apple Account may not restore the subscription. Signing in does not synchronize notebooks or tutor memory.

Deleting your account. In Settings > Account > Delete Account, Plasticity asks for confirmation with Apple. It first attempts to withdraw the email preference saved on this iPad, then requests deletion of the account's RevenueCat customer record, account-linked contact preferences and feedback, and Supabase account. If a required deletion step fails, the app reports failure so you can retry. A completed withdrawal stays effective even if a later deletion step fails. If ownership of an older email preference cannot be verified, account deletion can still proceed; the app keeps that preference visible and explains how to request withdrawal through support.

Plasticity also attempts to revoke its Sign in with Apple connection. If Apple does not confirm revocation, the app explains how to remove Plasticity in your Apple Account's Sign in with Apple settings. Deletion does not erase local notebooks or tutor memory and does not cancel the App Store subscription. You can manage or cancel the subscription with Apple. Apple and RevenueCat may retain purchase records needed for their legal and operational purposes described in Section 6.

Feedback submitted while signed out is not automatically attached to a later account and is not necessarily removed by account deletion. Contact the controller to identify and request removal of earlier anonymous records, including preferences from older installations. We may request proportionate proof of ownership; knowing a subscriber identifier alone is not proof. Removing the Apple sign-in connection outside Plasticity signs you out but does not itself delete the Plasticity account.

Retention: account data is kept until you delete your account.

9. Product-Email Preferences from Earlier Versions

The current app no longer invites you to enter an email address for product emails, either in the library or in Settings. If you opted in using an earlier version, your saved preference may remain active until you withdraw it. That earlier invitation asked for an email address and agreement to occasional emails about your experience and how Plasticity could work better. Signing in or supplying a reply address for feedback does not create a product-email subscription.

Data processed: the email address you enter, the exact wording you agreed to and its version, the date and time of your agreement, and the RevenueCat appUserID (or your account identifier if you are signed in) that the record is stored under. The record is stored in Supabase. The current app does not copy this research-email address or consent timestamp into RevenueCat; an email shared by Apple for an optional account remains separate. A random management secret is stored with the preference in this iPad's app storage; the server stores only its hash. This lets the device change or withdraw that preference after signing out without treating a public subscriber identifier as a password. When a preference is successfully linked during sign-in, the existing server record is associated with the account rather than copied to a new record.

Purpose: contacting you to ask about your experience and how Plasticity could work better.

Legal basis: your consent under Art. 6(1)(a) GDPR.

If this device has a saved preference, open Settings > Help & Feedback > Product Emails and confirm that you want to stop them. You can also email info.foodb@gmail.com, including by replying to a product email. These emails must include an easy way to stop further messages. Withdrawal deletes the active preference when the server confirms success and does not affect the lawfulness of emails sent earlier. Signing in or out is not a new email opt-in. If you have removed the app, lost the device-held secret, used other addresses or installations, or have a preference from an older build, contact the controller to stop those emails. The app does not synchronize email-preference settings across devices.

Retention: the active preference is kept until withdrawal or deletion of the account it is linked to. A preference that could not be linked remains separately withdrawable as described above. Uninstalling the app alone does not withdraw a server-side email preference.

10. In-App Feedback

In Settings > Help & Feedback > Send Feedback you can send a message to the controller. The message is stored together with an optional reply email address you may enter, the app version and build, the iPadOS version, the iPad model identifier, and the RevenueCat appUserID (or your account identifier if you are signed in). The form states that this technical information is included.

Purpose: understanding problems and suggestions, improving Plasticity, and replying when you provide an email address. A reply email address is used only to answer that message.

Legal basis: Art. 6(1)(f) GDPR, the controller's legitimate interest in maintaining and improving the app, and Art. 6(1)(b) GDPR where you ask for a reply about your use of the app.

Retention: feedback is kept for as long as needed to evaluate and act on it. Feedback linked to your account is deleted through account deletion. Earlier anonymous feedback needs a separate deletion request. You may request deletion at any time by contacting the controller.

Storage for Sections 8 to 10. Account data is held by Supabase Auth. Product-email consent and feedback are stored in Supabase database tables that are not reachable through Supabase's public data interface and are accessed only by the plasticity-account Edge Function. That function also processes your IP address in memory for short-term rate limiting, and Supabase may keep operational or security logs as described in Section 7. The function's own logs do not contain email addresses, feedback messages, or sign-in tokens.

11. Speech Recognition via Apple

When you use push-to-talk, your speech is processed using Apple's Speech framework (SFSpeechRecognizer), which converts your spoken question to text. Depending on your device, language, and Apple's own configuration, this processing may occur entirely on your device or may involve Apple's servers. This processing is governed by Apple's own privacy policy and iOS permission settings, not by the controller.

Purpose: converting spoken questions to text so they can be sent to the AI tutor as described in Section 5.

Legal basis: Art. 6(1)(b) GDPR, because voice input is a feature you actively choose to use, together with the microphone and speech-recognition permissions you grant on your device.

12. Email and Support Requests

If you contact the controller by email or another support channel, the contact details and message content you provide are processed to respond to your request.

Purpose: responding to your request and handling any data protection rights request.

Legal basis:

• Art. 6(1)(b) GDPR where the request relates to your use of the app.
• Art. 6(1)(f) GDPR for general support and documentation.

Retention: support communications are retained only for as long as needed to answer the request and, where necessary, for statutory limitation or documentation periods.

13. Access to and Storage on Your Device under the TDDDG

Plasticity stores and reads information on your device, including notebook pages, ink, imported documents, recognized text and search caches, conversation history, tutor marks, tutor memory, AI permission state, onboarding state, and the RevenueCat anonymous identifier. If you sign in, it stores your sign-in session in the iOS Keychain. It may also retain a product-email preference saved in an earlier version so you can withdraw it. The old question counter used to show the product-email invitation is removed by the current app. Retention and deletion for these categories are described in Sections 3 and 8 to 10. To the extent the TDDDG applies, strictly necessary local storage is based on Section 25(2) TDDDG and does not require separate consent. Plasticity does not currently use cookies, advertising identifiers, third-party tracking technologies, or analytics identifiers. If non-essential tracking or analytics technologies are added in the future, Plasticity will request any legally required consent before using them.

14. Third-Party Service Providers

Plasticity currently uses the following relevant third-party service providers:

These providers may engage subprocessors under their own data processing terms. Plasticity requires every third party that receives personal data from the app to provide the same or equivalent level of protection described in this Policy and required by applicable contractual and legal obligations.

15. International Data Transfers

OpenAI, Supabase, RevenueCat, Apple, and their subprocessors may process data outside the European Union or European Economic Area, including in the United States.

Where personal data is transferred to a country outside the EU/EEA, Plasticity relies on appropriate safeguards under Chapter V GDPR, such as:

• An adequacy decision under Art. 45 GDPR, including the EU-US Data Privacy Framework where the recipient is certified and the transfer falls within the certification.
• Standard Contractual Clauses under Art. 46 GDPR.
• Additional technical and organizational safeguards where required.

You may contact the controller to request more information about the safeguards used for international transfers.

16. Data Security

Plasticity uses technical and organizational measures designed to protect data against unauthorized access, loss, misuse, alteration, or disclosure, including:

• Local storage within the iOS app sandbox.
• TLS/HTTPS for all network communication.
• Server-side handling of the OpenAI API key via the Supabase Edge Function, so the key is not embedded in the app binary.
• Anonymous, per-install identifiers by default; accounts are optional.
• Sign-in tokens stored only in the iOS Keychain on your device.
• Private contact and feedback tables accessed through restricted server functions. Changing or withdrawing a stored contact preference requires either the owning account's verified session or the preference's device-held secret. Account deletion removes rows linked to the verified account; caller-supplied subscriber IDs do not authorize deletion of someone else's records.
• Limiting third-party services to those needed for app and subscription functionality.

No method of electronic storage or transmission is completely secure, but processing is kept proportionate and protected.

17. Your Rights

Subject to the legal requirements and limitations of the GDPR, you have the following rights:

• Right of access under Art. 15 GDPR.
• Right to rectification under Art. 16 GDPR.
• Right to erasure under Art. 17 GDPR.
• Right to restriction of processing under Art. 18 GDPR.
• Right to data portability under Art. 20 GDPR.
• Right to object under Art. 21 GDPR.
• Right to withdraw consent at any time under Art. 7(3) GDPR, without affecting processing that occurred before withdrawal.
• Right not to be subject to qualifying automated individual decision-making under Art. 22 GDPR.
• Right to lodge a complaint with a supervisory authority under Art. 77 GDPR.

To exercise your rights, contact: info.foodb@gmail.com

If you have an account, you can delete it and the related records yourself in Settings (Section 8), and withdraw product-email consent in Settings (Section 9). Because accounts are optional, for other requests the controller may need information that helps identify relevant off-device records, such as your RevenueCat anonymous appUserID, subscription transaction information, the email address you used, or other details you provide. Notebook content stored only on your iPad is controlled through the app and device rather than through a Plasticity account.

You may also contact the competent data protection supervisory authority. For a private controller established in Bavaria, this is generally:

Bayerisches Landesamt fuer Datenschutzaufsicht (BayLDA)
Promenade 18
91522 Ansbach
Germany
Website: https://www.lda.bayern.de/

You may also lodge a complaint with any other competent data protection authority in the EU member state of your habitual residence, place of work, or place of the alleged infringement.

18. Required or Optional Data

You are not legally required to provide personal data to use Plasticity. However, certain information is necessary for specific features:

• Without confirming eligibility under the 16+ policy, you cannot proceed beyond the onboarding privacy screen into the notebook library. The Terms and Privacy Policy remain accessible.
• Without a page image and question, Plasticity cannot generate a tutoring response.
• Without granting the AI-processing permission described in Section 5, you can use local notebook features but cannot use Clay's OpenAI-backed tutoring or narration.
• Without an active subscription and the RevenueCat entitlement check it relies on, AI tutoring and OpenAI-powered narration are unavailable; the app will show a paywall instead.
• Without microphone and speech-recognition permission, you can still type questions instead of using push-to-talk.
• Without network access, AI tutoring, subscription validation, and text-to-speech features are unavailable.
• Signing in and in-app feedback are optional. Not using them, or withdrawing an earlier product-email preference, does not limit any other feature.

19. Minimum Age and Age Confirmation

Plasticity is intended for people aged 16 and older. It is not offered to children under 16, including with parental permission. If you are 16 or 17, a parent or legal guardian must give you permission to use the app and read the Terms with you. Purchases also require any authorization required by applicable law.

The onboarding privacy screen requires you to enable an initially off age-confirmation control. It states that you are at least 16 and explains that, if you are under 18, a parent or guardian must have read the Terms and agreed. This confirmation is required to continue either with or without AI. Existing installations that have not confirmed eligibility must complete this step too. The app does not start account-restoration or subscription services or expose the notebook library, AI, account or feedback features before successful confirmation. The tour and legal links remain available before confirmation; the links visit our website.

Only the version of the successfully confirmed eligibility policy is saved in this iPad's app settings. The checkbox state is transient until you continue, and we do not collect or separately save your age group or parental details or send the declaration to our servers. We do not request a birth date, identity document, parent identity or parent contact information in this flow. The confirmation is a self-declaration; we do not independently verify age or parental permission through this screen.

Purpose and legal basis: applying the app's minimum-age policy and reducing access by users outside its intended audience, under Art. 6(1)(f) GDPR, our legitimate interest in providing an age-appropriate service. The local confirmation is retained until app data is removed or replaced by a new policy confirmation, subject to device backups. It does not grant AI-sharing or research-email consent. The app's separate Terms and permission flows continue to apply.

If you believe a child under 16 has used Plasticity or provided personal data, contact info.foodb@gmail.com so we can investigate and address access or deletion as appropriate. The age requirement does not delete existing notebooks, cancel a subscription or remove an existing server account. Manage subscriptions through Apple and contact the controller for help with account or data-rights requests.

20. Changes to This Privacy Policy

This Privacy Policy may be updated when Plasticity changes its features, service providers, or data processing practices, or when legal requirements change. The latest version will be identified by the "Last updated" date above.