Draft a privacy policy that matches what the code does

docs/privacy-policy-draft.md

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+# Privacy policy — draft
+
+> **Don't publish this.**
+>
+> It describes what the app does, which is the easy half. Whether that's
+> lawful is the half I can't answer. Edvifi takes race, religion and
+> immigration answers from teenagers, so it probably isn't simple.
+>
+> The open questions at the end matter more than the policy text. Several are
+> decisions about the product, not the wording, and they have to be settled
+> before anyone writes a final version.
+
+Drafted 2026-09-27 against `main` @ `1df1925`.
+
+---
+
+## About Edvifi
+
+Edvifi helps high-school students organise college applications: deadlines,
+college lists, essay drafts, scholarships and financial aid.
+
+This policy covers anyone with an account. Our users are high-school students.
+Most are under 18. Some may be under 13.
+
+## What we collect
+
+### Your account
+
+**Email address**, so you can sign in, reset your password, and receive
+deadline reminders if you ask for them.
+
+**Password.** Our authentication provider stores a hash of it. We never see
+the password itself.
+
+### The intro survey
+
+Four answers are required. The other ten are optional, and you can skip any of
+them or answer "Prefer not to say".
+
+| Question | Required | Why we ask |
+|---|---|---|
+| First name | Yes | To address you in the app |
+| Age | Yes | See question 1 below |
+| ZIP code | Yes | Colleges near you, and scholarships limited to your area |
+| High-school name | Yes | School-specific scholarships are among the easiest to win |
+| Gender | No | Some scholarships are open only to certain applicants |
+| Nationality † | No | Citizenship decides FAFSA eligibility and some scholarships |
+| Race † | No | Many scholarships are restricted to specific backgrounds |
+| Hispanic or Latino † | No | Federal forms treat this separately from race |
+| Native American or Alaska Native † | No | Tribal affiliation opens specific aid, including tuition waivers |
+| Religion † | No | Faith-based organisations fund many local scholarships |
+| GPA | No | Scholarship matching, and your fit for each college |
+| Household income | No | Aid estimates, fee waivers, need-based scholarships |
+| Parent's highest education | No | First-generation students qualify for a category of aid |
+| Parents are immigrants † | No | Some scholarships are for immigrant and first-generation families |
+
+† Sensitive categories under several state privacy laws. We use these answers
+to match you to scholarships and for nothing else. We never sell them and
+never share them for advertising.
+
+### What you make in the app
+
+Your college list and where each application stands. Deadlines you set and
+tasks you tick off. Essay drafts. Scholarships you're tracking. Your settings
+and progress.
+
+### What arrives on its own
+
+**Crash reports.** When the app breaks we record the error and the line of
+code it came from. These aren't tied to your account: the tool is set never to
+build a profile of you, and we don't record your screen, your clicks or the
+pages you visit.
+
+**Server logs.** Our host records IP addresses and request details, as hosts
+do.
+
+## What we do with it
+
+Run the app. Match you to scholarships and colleges, which is the only thing
+the optional answers are for. Estimate financial aid from the income and
+family questions. Email you about deadlines if you switch that on, which is
+off unless you do. Fix crashes.
+
+We don't sell your information, share it for advertising, or train machine
+learning models on it.
+
+## Who else sees it
+
+| Service | What it gets | What for |
+|---|---|---|
+| Supabase | Everything in your account | Database and sign-in |
+| Vercel | IP address, request logs | Hosting |
+| PostHog | Error messages and stack traces | Fixing crashes. Set not to profile users |
+| Cloudflare Turnstile | IP address, browser signals | The sign-up bot check |
+| Zippopotam.us | Your ZIP code, nothing else | Converting a ZIP to a map location |
+| Resend | Email address, reminder contents | Deadline reminders, if you turn them on |
+
+Beyond these, we disclose nothing unless the law requires it.
+
+## What you can do
+
+Leave any optional question blank. The app works without them; you'll see
+fewer scholarship matches.
+
+Change your answers in your profile at any time.
+
+Switch reminder emails on or off in Settings.
+
+Delete your account in Settings. That removes your profile, survey answers,
+college list, essays, tracked scholarships and progress, permanently.
+
+## Security
+
+Database rules let each account read and write only its own records. Traffic
+is encrypted in transit. Your password is hashed by our authentication
+provider and never visible to us.
+
+No system is perfectly secure and we don't claim otherwise.
+
+## Changes and contact
+
+If this policy changes we'll update the date above, and tell you in the app if
+the change is significant.
+
+**[ADDRESS NEEDED]** for privacy questions, requests about your data, or
+anything a parent or guardian wants to raise.
+
+---
+---
+
+# Open questions
+
+The policy above describes the software honestly. These are the places where
+nobody has checked the software against the law. Several need a product
+decision before the wording can be settled.
+
+## 1. Under-13 users
+
+Age is a dropdown starting at 13. Nothing stops a twelve-year-old picking it.
+There's no age gate, no parental consent, and nothing that treats a younger
+user differently.
+
+COPPA wants verifiable parental consent before collecting anything from
+children under 13. The choices are to block under-13 sign-ups and say so, to
+build a consent flow, or to carry on and absorb the risk.
+
+Separately: age is collected and then never used. Nothing reads it. That's
+hard to defend under data minimisation on its own. It should either gate
+something or come out of the survey.
+
+## 2. Nobody has agreed to anything
+
+No consent checkbox at sign-up. No terms of service. No policy link anywhere
+in the app. A student reaches the survey and answers questions about race and
+their parents' immigration status without being shown what happens to any of
+it.
+
+Whatever the final text says, it needs a place to appear and a record that
+someone saw it.
+
+## 3. Sensitive categories
+
+CPRA, the Virginia CDPA and the Colorado Privacy Act treat race, religion and
+immigration status as sensitive. Some require opt-in consent for that data
+specifically, separate from any general consent. Right now there's neither.
+
+## 4. Users aged 13 to 17
+
+Several states set separate rules for minors over 13, covering opt-in for
+sharing and limits on profiling. Which ones apply depends on where the users
+actually are, which is a question about the user base rather than the code.
+
+## 5. FERPA
+
+If a school ever adopts Edvifi for its students, rather than students finding
+it themselves, FERPA and state student-privacy laws may apply. That's a
+different regime. Ask before it happens.
+
+## 6. No export
+
+Deletion works. Export doesn't exist. Laws that require deletion usually
+require access or portability too.
+
+## 7. No retention rule
+
+Nothing expires. An abandoned account keeps its data forever. Decide a rule
+and implement it first, rather than writing one into a policy the code
+doesn't follow.
+
+## 8. Processor agreements
+
+Supabase, Vercel, PostHog, Cloudflare and Resend each need a DPA. Check which
+are signed.
+
+Zippopotam.us is the odd one. It's a free public API with no key and no
+agreement of any kind, and it receives a student's ZIP code on every profile
+load. The data is low-sensitivity, but it's an unbound third party in the
+flow. A local ZIP-to-coordinates table removes it; that's a small change
+whenever you want it.
+
+## 9. Not covered here
+
+No lawful basis, no governing law, no international transfers, no GDPR or UK
+text. This draft assumes US-only users. If that's wrong, or becomes wrong, the
+document needs a different shape.