Privacy Policy of Sailabus

1. What data we collect

Depending on how you use Sailabus, we may collect the following categories of personal data.

Account information

This may include:

• name;
• email address;
• login credentials or authentication information;
• account identifier;
• subscription status;
• language;
• country or region;
• account preferences; and
• information you voluntarily provide through your profile.

Study and educational data

When you use Sailabus, we may process:

• uploaded syllabi;
• lecture notes;
• PowerPoint presentations;
• PDFs;
• course documents;
• Learning Objectives;
• study notes;
• flashcards;
• questions and answers;
• practice-test activity;
• mastery scores;
• learning progress;
• study history;
• course names;
• examination dates;
• examination-related information; and
• other content you submit or generate while using Sailabus.

Users should avoid uploading unnecessary sensitive personal information.

Usage and technical data

We may collect technical and usage information such as:

• IP address;
• device type;
• browser type;
• operating system;
• app version;
• timestamps;
• pages or features used;
• session information;
• diagnostic information;
• crash logs;
• performance information;
• interaction history; and
• security-related information.

Payment information

Payments may be processed by third-party payment providers.

We may receive information such as:

• payment status;
• subscription type;
• billing country;
• transaction identifier;
• amount paid;
• currency;
• payment method category;
• renewal information; and
• refund information.

Sailabus does not necessarily receive or store complete payment-card details.

Communications

If you contact us, we may process:

• emails;
• customer-support messages;
• chat conversations;
• WhatsApp communications;
• feedback;
• complaints;
• refund requests; and
• other correspondence.

2. How we collect data

We collect personal data in several ways.

Data you provide directly

This includes information you provide when you:

• create an account;
• purchase a subscription;
• upload study materials;
• enter an examination date;
• create notes or flashcards;
• contact support;
• submit feedback;
• request a refund; or
• make a Pass Guarantee claim.

Data generated through your use of Sailabus

Sailabus generates information about how you study and interact with the Service.

This may include:

• learning progress;
• mastery calculations;
• quiz performance;
• Learning Objective status;
• study frequency;
• content-generation requests; and
• other activity required to provide learning functionality.

Data from service providers

We may receive information from service providers such as:

• payment providers;
• authentication providers;
• hosting providers;
• analytics providers;
• customer-support systems; and
• security or fraud-prevention services.

3. Why we use personal data

We use personal data for the purposes described below.

Providing Sailabus

We process information to:

• create and maintain accounts;
• provide study functionality;
• process uploaded materials;
• generate Learning Objectives;
• generate summaries, flashcards, questions, notes, explanations and other Study Content;
• track learning progress;
• calculate mastery;
• provide personalised study recommendations;
• remember courses and study history;
• provide audio, podcast, video or tutoring functionality where available; and
• otherwise provide functionality requested by the User.

Operating subscriptions and payments

We process information to:

• manage subscriptions;
• confirm payments;
• manage renewals;
• provide invoices or payment records;
• process refunds;
• detect failed payments; and
• respond to billing questions.

Pass Guarantee

Where a User participates in the Sailabus Pass Guarantee, we may process information required to determine eligibility, including:

• exam dates;
• mastery records;
• Learning Objectives;
• study-material completeness;
• course information;
• official exam results;
• proof of enrolment; and
• documentation submitted with a claim.

This information is used only as reasonably necessary to administer and protect the integrity of the guarantee.

Customer support

We use data to:

• respond to questions;
• investigate technical problems;
• resolve account issues;
• assist with payments;
• process complaints; and
• improve support quality.

Security and abuse prevention

We may process information to:

• secure accounts;
• detect fraud;
• prevent account sharing;
• detect automated or abusive usage;
• enforce fair-use limits;
• investigate suspicious refund activity;
• protect the Sailabus platform; and
• comply with legal obligations.

Improving Sailabus

We may analyse how Sailabus is used to:

• improve functionality;
• understand which features are useful;
• diagnose bugs;
• improve performance;
• develop new features;
• improve learning systems; and
• evaluate product quality.

Where reasonably possible, we use aggregated, anonymised or de-identified information for such analysis.

4. Legal bases for processing

Where the GDPR or similar laws require a legal basis, Sailabus processes personal data based on one or more of the following grounds.

Performance of a contract

Much of the processing is necessary to provide Sailabus to the User.

For example:

• maintaining an account;
• analysing uploaded materials;
• providing study tools;
• calculating progress;
• managing subscriptions; and
• administering contractual guarantees.

Legitimate interests

We may rely on legitimate interests where appropriate, including:

• securing the Service;
• preventing fraud;
• improving product functionality;
• understanding Service usage;
• protecting Sailabus and its Users; and
• operating an efficient online service.

Where we rely on legitimate interests, we consider the interests and rights of Users.

Legal obligations

We may process information where necessary to comply with legal obligations, including:

• accounting;
• tax;
• legal requests;
• regulatory requirements; and
• fraud-prevention obligations.

Consent

Where required, we may rely on consent, for example for:

• certain cookies;
• certain analytics technologies;
• direct marketing; or
• other optional processing.

Where processing is based on consent, Users may withdraw that consent subject to applicable law. The GDPR requires consent to be specific, informed and freely given. (European Commission)

5. Artificial intelligence

Sailabus uses artificial intelligence and automated systems as part of the Service.

AI may be used to:

• analyse study materials;
• identify Learning Objectives;
• generate summaries;
• generate flashcards;
• create practice questions;
• provide explanations;
• create study recommendations;
• evaluate responses;
• assist tutoring;
• generate audio or video content; and
• provide other learning functionality.

Information sent to AI systems is limited to what is reasonably necessary to provide the requested functionality.

Depending on the Sailabus functionality being used, information may be processed by external technology providers acting on behalf of Sailabus.

These providers include OpenAI for study-content generation, tutoring, document analysis and speech features, and Google Gemini for generating podcast audio. Depending on the feature, data sent to these providers may include uploaded documents or extracted text and page images, questions, answers, conversation context, voice recordings or podcast scripts derived from study materials.

Such providers are required to process data in accordance with contractual and data-protection requirements applicable to their role.

Sailabus does not permit service providers to use personal data for unrelated advertising purposes.

6. Study content and uploaded documents

Users may upload educational content to Sailabus.

Such materials may contain personal data or information belonging to third parties.

Users should only upload material they are entitled to use.

Uploaded documents may be processed to:

• identify relevant academic content;
• extract Learning Objectives;
• generate Study Content;
• organise a course;
• answer questions;
• assess learning progress; and
• provide other requested functionality.

Uploading a document does not transfer ownership of the original document to Sailabus.

For information about intellectual property and Study Content, see the Sailabus Terms and Conditions.

7. Sharing flashcards and study content

Certain Study Content created within Sailabus may be reused or made available to other Sailabus Users in accordance with the Terms and Conditions.

This may include:

• flashcards;
• study questions;
• Learning Objectives;
• generic study notes;
• explanations; and
• other educational Study Content.

We do not intend to make a User's original private source document publicly available merely because Study Content has been derived from it.

Where appropriate, we seek to remove or avoid including information that directly identifies the original User when Study Content is reused.

Users should not include personal, confidential or sensitive information in Study Content that they do not wish to be reused.

8. Service providers and data recipients

Sailabus uses third-party service providers to operate the Service.

These may include providers of:

• cloud hosting;
• data storage;
• artificial intelligence;
• payment processing;
• analytics;
• customer support;
• authentication;
• email delivery;
• monitoring;
• security;
• audio processing;
• video generation; and
• other infrastructure.

These organisations may process personal data where necessary to perform services for Sailabus.

Where required by law, Sailabus enters into appropriate contractual arrangements with processors.

The GDPR expressly allows processors, provided appropriate contracts and safeguards are in place. (European Commission)

We do not sell personal data to data brokers or advertisers.

9. Advertising

Sailabus does not sell student personal data to advertisers.

We do not provide uploaded study materials, private study history or personal learning progress to advertisers for the purpose of allowing them to independently advertise to Users.

Sailabus may conduct marketing for its own products and services, subject to applicable law and User communication preferences.

If Sailabus introduces third-party advertising or materially changes how personal data is used for advertising, this Privacy Policy will be updated accordingly and any consent required by law will be obtained.

10. International data transfers

Sailabus is operated from Switzerland and may use service providers located in other countries.

As a result, personal data may be processed outside the User's country of residence.

Where required, Sailabus uses appropriate safeguards for international transfers, such as:

• adequacy decisions;
• contractual data-protection provisions;
• Standard Contractual Clauses; or
• other legally recognised safeguards.

EU data-protection law requires specific safeguards for transfers outside the EEA where no adequacy mechanism applies. (European Commission)

11. Data retention

Sailabus retains personal data only for as long as reasonably necessary for the purposes for which it was collected and for applicable legal, accounting, security and operational requirements.

Different categories of information may therefore have different retention periods.

For example:

• active account data may generally be retained while the account remains active;
• study materials may be retained while necessary to provide the User's courses and account;
• transaction records may be retained as required for accounting and tax purposes;
• fraud and security information may be retained where reasonably necessary to prevent abuse;
• support correspondence may be retained for an appropriate period after resolution; and
• Pass Guarantee records may be retained for the period reasonably necessary to assess claims and resolve disputes.

When personal data is no longer required, it will be deleted, anonymised or otherwise handled in accordance with applicable law.

Deleting an account therefore does not necessarily require immediate deletion of every record where Sailabus has a lawful reason or legal obligation to retain certain information.

12. Account deletion

Users may request deletion of their account.

Where permitted by law, Sailabus will delete or anonymise personal data that is no longer necessary.

Certain information may remain where required or permitted for:

• accounting;
• taxes;
• legal claims;
• fraud prevention;
• security;
• regulatory compliance; or
• enforcement of agreements.

Content that has already been legitimately anonymised or incorporated into non-personal aggregated data may not be capable of being associated with or deleted as personal data.

Study Content that Sailabus is entitled to retain or reuse under the Terms and Conditions may also remain where it no longer identifies the User or where another lawful basis applies.

13. Data security

Sailabus uses technical and organisational measures designed to protect personal data.

Depending on the type of information and system, these measures may include:

• encryption in transit;
• secure hosting infrastructure;
• access controls;
• role-based permissions;
• authentication controls;
• monitoring;
• backups;
• logging;
• security updates; and
• restrictions on employee access.

No online service can guarantee absolute security.

Users are responsible for protecting their own login credentials and should notify Sailabus if they suspect unauthorised account access.

14. Data breaches

If Sailabus becomes aware of a personal-data breach, it will investigate the incident and take appropriate measures.

Where legally required, Sailabus will notify the relevant data-protection authority within the applicable legal timeframe.

Affected Users will be informed where required by applicable law and where the breach is likely to result in a sufficiently serious risk to them.

Under the GDPR, certain breaches must be reported to the competent supervisory authority without undue delay and, where feasible, within 72 hours after becoming aware of them. (European Commission)

15. User rights

Depending on the law applicable to the User, Users may have rights concerning their personal data.

These may include the right to:

• request access to personal data;
• obtain information about how data is processed;
• correct inaccurate personal data;
• request deletion of personal data;
• restrict certain processing;
• object to certain processing;
• receive certain personal data in a portable format;
• withdraw consent where processing is based on consent; and
• lodge a complaint with a competent data-protection authority.

Not all rights apply in every circumstance.

Sailabus may need to verify the identity of the person making a request before acting on it.

The GDPR requires organisations to inform people clearly about these rights and about the right to complain to a supervisory authority. (European Commission)

16. Automated processing and personalisation

Sailabus automatically analyses study behaviour and educational performance in order to provide functionality such as:

• mastery measurements;
• Learning Objective progress;
• personalised revision;
• spaced repetition;
• recommendations;
• question difficulty;
• study prioritisation; and
• Pass Guarantee status.

These systems are intended to support learning and generally do not make legal or similarly significant decisions about Users.

Where applicable law provides additional rights relating to automated decision-making, Sailabus will respect those rights.

17. Children and younger users

Sailabus is intended for students in secondary school and further education, including college and university. It is not intended for primary-school children.

Where applicable law requires parental or guardian consent for a younger User to use particular online services or for particular personal-data processing, Sailabus may require such consent.

Users who are not legally permitted to provide the required consent themselves should use Sailabus only with the involvement of a parent or legal guardian where required.

Sailabus may introduce age-verification or parental-consent mechanisms where legally necessary.

18. Cookies and similar technologies

Sailabus may use cookies and similar technologies for purposes such as:

• authentication;
• security;
• remembering settings;
• maintaining sessions;
• measuring performance;
• analytics; and
• improving the Service.

Some cookies are necessary for Sailabus to function.

Where consent is legally required for non-essential cookies or similar technologies, Sailabus will provide appropriate consent controls.

Users may also be able to control cookies through their browser or device settings, although disabling certain cookies may affect functionality.

19. Analytics

Sailabus may use analytics tools to understand how the Service is used.

Depending on the page, configuration and applicable consent, these tools may include Google Analytics, Hotjar and, in parts of the older application, Mixpanel. Google Tag Manager is used to manage tags. Marketing and conversion-measurement tags may include Google Ads, Meta (Facebook), TikTok and LinkedIn. These technologies may process technical information, page visits and interaction or conversion events.

Analytics information may include:

• feature usage;
• session duration;
• navigation;
• device information;
• technical performance;
• errors; and
• aggregated learning behaviour.

Where appropriate, we minimise, aggregate or pseudonymise analytics data.

Analytics providers may process certain information on behalf of Sailabus subject to applicable agreements and safeguards.

20. Marketing communications

Sailabus may send information relating to its own products, features or offers where legally permitted.

Users may unsubscribe from optional marketing communications.

Unsubscribing from marketing does not prevent Sailabus from sending necessary transactional or service communications, such as:

• account security messages;
• payment information;
• subscription changes;
• important service notices; and
• legal updates.

21. Legal disclosure

Sailabus may disclose personal data where reasonably necessary to:

• comply with applicable law;
• respond to valid legal requests;
• protect Users;
• protect Sailabus;
• investigate fraud;
• enforce contractual rights; or
• establish, exercise or defend legal claims.

Requests from authorities will be assessed in accordance with applicable law.

22. Business transfers

If Sailabus or Good Ventures SAGL is involved in a merger, acquisition, investment, restructuring, financing or sale of all or part of its business, personal data may be transferred as part of that transaction where legally permitted.

Any recipient will remain subject to applicable data-protection obligations.

23. Data minimisation

Sailabus aims to collect and process only the personal data reasonably necessary for legitimate purposes associated with the Service.

This reflects the principles of purpose limitation and data minimisation under modern data-protection law. (European Commission)

24. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

Changes may be made because of:

• changes to Sailabus;
• new features;
• new technology providers;
• legal developments;
• changes to data-processing practices; or
• security requirements.

The updated version will be published with a revised "Last updated" date.

Where required, Users will receive additional notice of material changes.

25. Complaints

If a User has concerns about how Sailabus processes personal data, we encourage them to contact Sailabus first so that the matter can be investigated.

Users may also have the right to contact the competent data-protection authority.

For users in Switzerland, the relevant federal authority is the Federal Data Protection and Information Commissioner (FDPIC).

Users in the EU or EEA may also have the right to complain to the supervisory authority responsible in their country.

26. Contact

Questions, requests or concerns relating to privacy can be sent to:

Good Ventures SAGL
Via Chioso 25
6983 Magliaso
Switzerland

Company number: CHE-453.811.708

Email: support@sailabus.com
Website: homepage-real-dev.sailabus.com