This notice explains which personal data we process when you use the Tipply website (tipply.dev), the Tipply web app and the Tipply browser extension, why and on what legal basis, for how long, who can access it, and what your rights are. It is based on Regulation (EU) 2016/679 (GDPR) and Hungarian Act CXII of 2011 on informational self-determination and freedom of information. This English version is provided for information; in case of any difference, the Hungarian version prevails.
1. Who is the controller?
Controller: [Company name] Kft.
- Registered office: [address]
- Company registration number: [number]
- Tax number: [number]
- Privacy contact: [[email protected]]
- Website: https://tipply.dev
Under Article 37 GDPR the controller [is not required to appoint / has appointed] a data protection officer [name and contact].
2. In short
- We only process data needed to provide the service, to invoice and to keep the system secure.
- Only you can see the material you upload. We do not sell it, publish it or use it to train artificial intelligence.
- To produce answers, we send your question and the relevant parts of your material to an AI provider (Anthropic), acting as our processor.
- We do not use advertising or tracking cookies.
- You can ask for a copy of your data, its correction or its deletion at any time.
3. What we process, why and on what legal basis
3.1. Registration and account
| Purpose | Creating and maintaining your account, letting you log in, recording your plan. |
| Data | Email address; password (stored only as a salted, irreversible hash); the invite code used (hashed); acceptance of the terms with time and version; plan; registration time; account status. |
| Legal basis | Article 6(1)(b) GDPR: performance of the contract. The service cannot be provided without an account. |
| Retention | Until the account is closed, then removed from backups within [30] days. |
3.2. Logging in and sessions
| Purpose | Keeping you logged in on the website and in the extension, and preventing unauthorised use. |
| Data | Session identifier (stored on the server only as a hash); session type (web or extension); creation and expiry time; IP address; browser identification data (user agent). Connecting the extension uses a one-time code valid for 60 seconds. |
| Legal basis | Article 6(1)(b) for the session; Article 6(1)(f) (legitimate interest, see 3.7) for abuse prevention. |
| Retention | Web sessions last at most 30 days or until you log out. Expired session data is deleted within [90] days. |
3.3. Providing the learning service
| Purpose | Processing and storing your material, answering your questions, practice questions, flashcards, exam rehearsals and tracking your progress. |
| Data | Uploaded material (in any format) and its searchable text version; subjects and material slots; questions you ask; your practice answers and results; credits used and the model chosen. |
| Legal basis | Article 6(1)(b) GDPR: performance of the contract. |
| Retention | Until the account is closed. The content of a material slot is kept for as long as the slot exists, as set out in the Terms. |
Third-party data in your material. If your material contains data about other people (for example people in a casebook), we process it only for your learning and on your instructions. Please upload only material you are entitled to use.
3.4. The browser extension
The extension reads the page you are on only when you press the hotkey or explicitly start a feature. It never fills in or submits anything.
| Purpose | Showing what your material says about a practice question; finding errors and improving quality. |
| Data | The question text and answer options; the page address (URL); Tipply’s answer with its source and confidence; processing time, model and cost; technical events (for example opening the extension, pressing the hotkey, how long a mark was shown, errors, settings changes). |
| Legal basis | Article 6(1)(b) for producing the answer; Article 6(1)(f) (legitimate interest) for technical event logging and quality improvement. |
| Retention | Questions and answers until the account is closed; technical events for [12] months. |
Page capture. If you explicitly start the “Scan page” feature, the extension sends the structure of the question parts of the page and a screenshot to improve recognition. Before sending, the extension tries to remove or mask your name and other identifying data shown on the page.
3.5. Use of artificial intelligence
Answers, explanations and practice content are generated by artificial intelligence (a large language model). For this we send the question and the relevant parts of your material to Anthropic, PBC (United States), acting as our processor (see section 5).
- Under our contract, Anthropic uses the data only to produce the answer and does not use it to train its models.
- To prevent abuse, Anthropic may keep requests for a limited period under its own terms: [retention period under the processing agreement].
- AI answers can be wrong. This is why every answer shows its source, so you can check it.
We do not make decisions based solely on automated processing that produce legal or similarly significant effects for you (Article 22 GDPR), and we do not profile you for such purposes.
3.6. Payment and invoicing
| Purpose | Collecting subscription fees, issuing invoices, meeting accounting and tax obligations. |
| Data | Billing name and address; tax number for business purchases; email; plan purchased, amount, currency, time; transaction identifier and result. We do not process card data: it is handled only by the payment provider. |
| Legal basis | Article 6(1)(b) for payment; Article 6(1)(c) (legal obligation under the Hungarian VAT Act, sections 159 and 169, and Accounting Act, section 169) for invoices. |
| Retention | Invoices and accounting records for [8] years as required by the Accounting Act. |
3.7. Security logging
| Purpose | Protecting the system, preventing and detecting attacks, abuse and fraud, fixing errors. |
| Data | Full IP address; time; the page or endpoint requested (without security codes and passwords); response status and duration; browser identification data; failed login attempts; rate-limit events. |
| Legal basis | Article 6(1)(f) GDPR: legitimate interest in protecting the service, user accounts and the system. The result of the balancing test is available on request. |
| Retention | [12] months, or until a security incident is closed. |
We never log passwords, session identifiers, login codes or API keys.
3.8. Contact and complaints
| Purpose | Answering your questions, requests and complaints; statutory complaint handling. |
| Data | Name (if given), email, message content, the complaint and our answer. |
| Legal basis | Article 6(1)(f) for general contact; Article 6(1)(c) for consumer complaints (Hungarian Consumer Protection Act, section 17/A). |
| Retention | General correspondence: [1] year after closing the matter; complaints: the record and our answer for 3 years. |
4. Cookies and browser storage
We only use cookies that are strictly necessary for the service, which do not require consent.
| Name | Purpose | Duration |
|---|---|---|
__Host-tipply_session | Keeps you logged in. HttpOnly, Secure, tipply.dev only. | Up to 30 days or until you log out |
tipply_lang | Remembers your language. | 1 year |
We use no advertising, tracking or third-party analytics cookies. The browser extension stores your login identifier, settings and a cache of earlier answers in your browser’s local storage. You can delete these by logging out or removing the extension.
The website remembers in your browser’s local storage, without any identifier, whether you are logged in (so the right menu appears straight away) and the subject, chapters and model you last chose for practice. These stay in your browser, never reach us, and you can remove them by clearing your browser data.
5. Who can access your data?
Only authorised staff of the controller, to the extent needed for their work. The following processors handle data on our behalf under written processing agreements:
| Processor | Activity | Location |
|---|---|---|
| Railway Corporation [address] | Server and database hosting | Data stored on servers in the EU (Netherlands); provider based in the United States |
| Cloudflare, Inc. [address] | Domain management, network protection, traffic routing | Worldwide, mainly in the EU |
| Anthropic, PBC [address] | AI model producing answers | United States |
| [Payment provider, e.g. SimplePay Zrt.] [address] | Card payments (independent controller for card data) | Hungary |
| [Invoicing provider] [address] | Electronic invoicing and reporting to the tax authority | Hungary |
| [Accountant] [address] | Accounting | Hungary |
We may disclose data to authorities or courts where required by law.
6. Transfers outside the EU
Some processors (Anthropic, PBC; Railway Corporation; Cloudflare, Inc.) are based in the United States. Transfers take place with appropriate safeguards under Chapter V GDPR: [certification under the EU–US Data Privacy Framework and/or the European Commission’s standard contractual clauses]. A copy of the safeguards is available on request.
7. How we protect your data
- Traffic is encrypted (HTTPS/TLS), and the service runs with strict security headers.
- Passwords and session identifiers are stored only in irreversible form.
- The login cookie cannot be read by JavaScript and is valid only on tipply.dev.
- Connecting the extension uses a one-time, short-lived code bound to the extension (PKCE).
- The database cannot be reached directly from the internet, and administrative access is protected by a separate key.
- Excessive attempts are limited automatically.
8. Your rights
You can send requests to [[email protected]], preferably from your account email. We answer without undue delay and within one month, which can be extended by two further months if needed; we will tell you if so. It is free of charge.
- Access (Article 15): information about and a copy of your data.
- Rectification (Article 16).
- Erasure (Article 17). Closing your account deletes its data, except data we must keep by law (for example invoices).
- Restriction (Article 18).
- Data portability (Article 20).
- Objection (Article 21) to processing based on legitimate interest.
- Withdrawing consent, where processing is based on consent, without affecting earlier processing.
9. Remedies
If you think we have infringed your data protection rights, please contact us first. You can also complain to the supervisory authority:
Hungarian National Authority for Data Protection and Freedom of Information (NAIH)
- Address: 1055 Budapest, Falk Miksa utca 9–11., Hungary
- Postal address: 1363 Budapest, Pf. 9.
- Phone: +36 1 391 1400
- Email: [email protected]
- Website: https://naih.hu
You may also go to court, including the court of your place of residence. If you live in another EU country, you can also complain to the supervisory authority there.
10. Minors
Tipply is for users aged 16 and over. A person under 16 may only use the service with the consent of a parent or guardian. If we learn that someone under 16 registered without such consent, we delete the account and its data.
11. Changes
We may update this notice when the service or the law changes. We will announce material changes by email and on the website before they take effect.
Version: 1.0 · Effective: [effective date]