Do-Do Privacy Policy

1. Introduction

Do-Do is a progressive web app (PWA), available through a web browser, that supports parents and guardians in jointly managing a child's matters — currently aimed mainly at parents sharing alternating custody after a separation or divorce. The App includes a shared custody calendar with Handover days marked, a communication module (Messages), financial settlements, a shared Child Profile and AI Suggestions that support day-to-day logistics.

This Privacy Policy explains how, for what purpose and on what legal basis we process the personal data of Users and of Children whose data is entered into the App by Parents.

2. Data controller

The controller of the personal data of Do-Do Users is Biznesteka sp. z o.o., ul. Bluszczańska 65/26, 00-712 Warsaw, Poland.

• e-mail: kontakt@biznesteka.pl
• phone: +48 508-034-721 (working days)

The Controller has not appointed a Data Protection Officer — the processing of personal data in the App is neither large-scale processing of special categories of data nor large-scale systematic monitoring of individuals within the meaning of Art. 37 GDPR. In all matters relating to personal data protection, the Controller can be contacted using the contact details above.

3. Definitions

Controller — Biznesteka sp. z o.o., as set out in section 2.

App / Product / Do-Do — a progressive web app (PWA), available through a web browser, enabling joint management of the care of children.

User / Parent / Guardian — an adult natural person who creates an Account and uses the App and who, when registering or accepting an invitation, declares that they hold parental authority over the Child or are the Child's court-appointed legal guardian. Access to one Child Profile is limited to the two Parents/Guardians indicated when the Account is created and invited by them. The Controller does not formally verify the User's legal title to care for the Child or the legitimacy of the invitation of the other Parent/Guardian — responsibility for the accuracy of such declaration and invitation lies with the User.

Other Parent / Co-parent — the other of the Parents/Guardians with access to the same Child Profile.

Child / Child Profile — a minor whose data is entered into the App by a Parent/Guardian. The Child is not a User, has no own access to the App and does not accept this Policy or the Terms.

Personal Data — information relating to an identified or identifiable natural person within the meaning of Art. 4(1) GDPR.

AI Suggestions — an optional App feature, off by default and switched on by the User, which uses the Claude language model (Anthropic) to fill in Card fields and to generate summaries and suggestions — see section 9.

Event Log — an unmodifiable, append-only record of communication (Messages), financial settlements and the change history of cards (tasks, expenses, events) between the Parents, including cards relating to Handover — see sections 13 and 14.

GDPR — Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.

Processor — an entity to which the Controller entrusts the processing of personal data under a data processing agreement (Art. 28 GDPR).

4. Principles of data processing

Personal data in the App is processed in accordance with the principles set out in Art. 5 GDPR.

5. Scope of the Policy

The Policy covers all processing of personal data connected with the use of the App (PWA) and with the Controller's communication with Users (e-mail, push notifications).

6. Whose data we process

• Users (Parents/Guardians) — persons who create an Account; access to the Child Profile is limited to the two Parents/Guardians. The App provides for access only by third parties invited by a Parent.
• Children — as data subjects whose data is entered into the App by the Parents/Guardians. The Child has no own access to the App (see section 19).
• The Other Parent/Guardian invited to the Child Profile — if the first Parent invites them by e-mail, the Controller processes that e-mail address even before the invited person creates an Account and accepts this Policy; such data is then not obtained directly from the data subject (Art. 14 GDPR), and the legal basis for processing it is the legitimate interest of enabling joint use of the App for the joint care of the Child (Art. 6(1)(f) GDPR). If the invitation is given as a link passed on outside the App, the Controller processes no data of the invited person before they create an Account. The invitation message or the invitation acceptance screen contains a reference to this Policy.

7. What data we process and where it comes from

7.1 Parent account data

First name and surname, e-mail address, optionally phone number, optionally bank account number, password (stored in encrypted form), login data when authenticating via a Google account (OAuth).

7.2 Child Profile data

The Child Profile comprises only the Child's first name — used to indicate which Child the entries in the custody calendar, communication, settlements and other App modules kept by the Parents within the shared Account relate to. Other information about the Child — including day-to-day organisational notes passed to the other Parent at a change of custody (e.g. about the need to bring a specific item) — is not part of a separate, structured Profile, but the content of Handover entries and of the Event Log (see section 7.5).

7.3 Documents

The App does not currently provide a shared document repository. If a Parent/Guardian presents the Controller — outside the App, e.g. by e-mail — with a final court decision on parental authority or contact, for verification under the rules described in the Terms, the Controller processes only the content of that document, to the extent necessary to verify it and take it into account.

7.4 Financial and settlement data

Expense entries with an optional photo of the receipt, and the balances between the Parents calculated from them (who owes the other party how much). A Parent may send the other Parent a request to pay the balance through the App — this is only a notification/reminder. The actual transfer of money between the Parents always takes place outside the App, by a method they choose (e.g. bank transfer, BLIK) — the App does not mediate these payments and is not a party to any payment transaction between the Parents; it may only record a confirmation of such a payment given voluntarily by a Parent. The App processes data in the form of bank account numbers and phone numbers provided by Users for the transactions made. Separately, the User pays the fee for using the App (subscription) to the Controller through an external payment operator (see section 10).

7.5 Communication data and Event Log

Messages and Handover entries — stored in the unmodifiable Event Log, which forms the shared history of arrangements between the Parents (see sections 13 and 14).

7.6 Custody schedule data

Alternating custody calendar events, including busy times read from the Google Calendar calendars selected by the Parent, if they authorise such integration. The App writes events to the User's Google Calendar and shows the User's "Busy" blocks to the other Parent. Sign-in and the calendar integration use the User's Google account and the User's own consents given to Google — the User may withdraw the App's access to their Google account at any time in their Google account settings.

7.7 AI Suggestions interaction data

Text entered or dictated by the User and passed to the language model, and its output (e.g. filled-in Card fields, daily summary) — see section 9.

7.8 Technical and device data

IP address, device identifier, operating system and app version, diagnostic data (error logs), push notification token. The App does not collect location data. Voice dictation (the microphone icon on a Card) uses the speech recognition built into the User's browser (Web Speech API), not a service provided by the Controller — the voice recording is not sent to the Controller's infrastructure but directly to the browser provider: in Chrome to Google's servers, in Safari to Apple's speech recognition (on the device or on Apple's servers, depending on the device). Google or Apple then process the recording as separate controllers under their own privacy policies. Only the finished text recognised by the browser reaches the App, where it is processed like ordinary typed text (sections 7.2, 7.6).

We obtain data: directly from the Parent (registration forms, entries in the App), automatically while the App is used (technical data) and from calendar integrations — only after the Parent's authorisation (OAuth 2.0).

Providing personal data in the App is voluntary but necessary to use the relevant features — in particular, creating an Account requires the data listed in section 7.1, and creating a Child Profile requires the Child's first name (section 7.2). Not providing this data prevents use of the given App feature but does not affect the use of other, independent features.

8. Purposes and legal bases of processing

9. AI Suggestions

AI Suggestions is an optional App feature, off by default, which the User may switch on in the Account Settings. Once switched on, AI Suggestions use the Claude language model, provided by Anthropic, to: fill in Card fields based on text typed or dictated by the User (e.g. title, description, date, amount); generate a daily summary of the shared board; and give suggestions when dates clash. AI Suggestions only propose content for fields, summaries or suggestions — they do not save any data on their own; saving a Card or any change requires a separate action by the User.

To provide these features, the App sends to Anthropic: the text entered by the User, the first names of both Parents and the first names of the Children — only to the extent needed for the given feature, not all the data held in the App. Before sending, the App's server removes line breaks and special characters from the text entered and shortens it — as protection against manipulation of the instructions given to the language model. On the App's side, only the total number of AI Suggestions calls per User is stored (to prevent abuse) — without storing the content of requests or responses.

• A data processing agreement (Art. 28 GDPR) is in place with Anthropic, forming part of the commercial terms that apply to the use of the Anthropic API.
• Anthropic undertakes not to use data sent via the API to train its models.
• Because Anthropic is established outside the EEA (USA) and requests are processed on infrastructure located in the USA, the data transfer is safeguarded by Standard Contractual Clauses approved by the European Commission (Art. 46(2)(c) GDPR), incorporated into the data processing agreement concluded with Anthropic.
• The User can use the App without switching on AI Suggestions, entering data in basic mode (forms/manual entry).

Processing within AI Suggestions is not automated decision-making producing legal effects within the meaning of Art. 22 GDPR — AI Suggestions take no decisions and perform no actions on their own, but only propose content that the User must save separately (see also section 15).

10. Integrations with external services

The App uses the following services of external entities, to which personal data may be entrusted to the extent necessary for the given feature:

Push notifications are sent entirely through the Controller's own infrastructure (Web Push/VAPID standard) — with the involvement of an external push notification provider and without transferring data outside the infrastructure described in section 12.

11. Cookies and tracking technologies

The App does not use cookies — neither to maintain the session nor for any other purpose. Only data strictly necessary for the App to work is stored on the User's device, in the browser's local storage: the sign-in session; settings (e.g. language, currency, theme, calendar view); shared board data and changes waiting to be synchronised (offline use); the fact that a tip or message in the App has been closed. Because this data is strictly necessary, storing it does not require the User's consent (Art. 399 of the Polish Act of 12 July 2024 – Electronic Communications Law (Prawo komunikacji elektronicznej), which from 10 November 2024 replaced the Polish Telecommunications Law in this respect). The Controller's websites (landing page, calculator, generator) store nothing on the User's device.

The Controller does not currently use any cookie-based marketing tools (e.g. the Meta Pixel) or external analytics tools. If such tools are introduced in the future, the Policy will be updated accordingly under section 20, and their use will in each case be preceded by obtaining the User's freely given consent through a cookie banner (with "Accept" and "Reject" options shown equally prominently).

The App has no native mobile version (iOS/Android) and does not use cookies in any of its versions — technical data collected while the App is used is described in section 7.8.

12. Recipients of data and transfers outside the EEA

Personal data may be disclosed to the following categories of the Controller's recipients: employees and associates of the Controller authorised to process data, IT and hosting service providers, payment operators, Anthropic (provider of AI Suggestions) and the Controller's legal and accounting advisers.

Independently of the above, the export feature (section 14) allows a Parent to pass exported data on themselves to a court, mediator, legal representative or specialist (e.g. a psychologist). Such further disclosure happens on the Parent's initiative and under the Parent's control, outside the App, and not as processing carried out directly by the Controller — the rules and limits of the Controller's responsibility in this respect are described in section 14.

The App's main infrastructure (database, API server hosting, e-mail sending) is physically located in the European Economic Area (Frankfurt, Ireland). The providers of this infrastructure — Vercel Inc. and Resend Inc. — are, however, companies established in the USA; transfers to them are safeguarded by their certification under the EU-US Data Privacy Framework, recognised by a European Commission decision as ensuring an adequate level of protection (Art. 45 GDPR) — see section 10. Independently of this, requests sent to AI Suggestions are processed on Anthropic infrastructure located in the USA — safeguarded by Standard Contractual Clauses approved by the European Commission (Art. 46(2) GDPR), incorporated into the data processing agreement concluded with Anthropic.

13. Data retention

Do-Do is designed as a long-term companion for Users — Parents may continue to use the App after the Child reaches adulthood (e.g. for the shared calendar or settlements). Retention periods are therefore tied mainly to the life cycle of the Account, not to fixed calendar deadlines based on the Child's age:

• Account, Child Profile, calendar and Event Log data — kept for the whole time the Account is active, without automatic clean-up while the App is in use (it is the core of the product's value — the Parents' shared "working memory"). The Child's data may be processed within an active Account also after the Child reaches adulthood, as long as the Parents continue to use the App.
• AI Suggestions interaction data (section 7.7) — content saved in the App as a result of the User saving the filled-in Card fields is subject to the same rules as the Account and Event Log data above. Independently of this, input data may be stored by Anthropic for a short period solely for security and abuse prevention, in accordance with the data processing agreement concluded with Anthropic — see section 9.
• Account deletion by a Parent — given the jointly created nature of the data on the shared board (cards, messages), deletion of an Account by one Parent does not delete content on which the other Parent still relies. In particular: immediately after the request to delete the Account, the deleting Parent's profile is erased and their name is removed from the cards and messages they created (author shown as "deleted user"); messages and cards, however, remain with their full content on the shared board for the other Parent — they are not permanently deleted. A permanent system entry with the deleting Parent's name and the date of the Account deletion request is added to the shared history; this entry is not deleted and contains the deleting Parent's name indefinitely — the name is not replaced with a neutral label. The deleting Parent's profile and access to the App are removed immediately; the authentication account itself is permanently deleted 12 months after the request, when the deleting Parent's name is additionally cleared from the remaining comments and the card change history. The basis for keeping the shared content is the legitimate interest of the other Parent, as co-author/recipient of the shared record, in preserving its integrity (Art. 6(1)(f) GDPR), and additionally — the establishment, exercise or defence of legal claims, including in family proceedings (Art. 17(3)(e) GDPR).
• Data the Controller is required to keep longer under the law — in particular accounting records for 5 years from the beginning of the year following the financial year concerned (Art. 74 of the Polish Accounting Act), and tax liabilities connected with settlements until they become time-barred, i.e. as a rule 5 years from the end of the calendar year in which the tax payment deadline expired (Art. 70 § 1 of the Polish Tax Ordinance).
• Technical data and security logs — 12 months.
• Backups of the whole App — kept for 7 days, regardless of the periods described above.
• Data processed on the basis of consent (e.g. calendar synchronisation) — until consent is withdrawn.
• Test phase (beta): if the Controller ends the test phase without moving to a production version, testers' data will be deleted within 30 days of the end of testing, of which testers will be informed in advance electronically — independently of the rules for deleting an individual Account described above.

14. Data export

The App provides three separate export tools in the Account Settings, serving different purposes:

• "Download my data" (Art. 20 GDPR, right to data portability) — a JSON file containing only the personal data of the requesting Parent: their profile, the cards they created, the messages they sent, the shopping items they added and the list of children in the family. It does not contain data entered by the other Parent.
• "Download legal record (PDF)" — export of the pair's full shared history: cards and messages of both Parents with the change history. Intended for disputes or proceedings concerning the care of the Child — described in detail below.
• Expense export (JSON/CSV) — accounting/settlement records only, for settlements between the Parents.

By using the "Download legal record (PDF)" feature, the User acknowledges that the full shared history — cards and messages of both Parents with the change history — may be exported and used as supporting material in dealings with a court, mediator, legal representative or specialist (e.g. a child psychologist).

• The export is generated independently, on request and under the control of the Parent who orders it; the Controller has no obligation to inform the Other Parent separately each time an export is generated — information about the possibility of using the data in this way is given in advance, in this Policy and in the Terms.
• The PDF file contains a Note on the unchangeability of the record: entries are time-stamped by the server at the moment of creation, neither party can retroactively change records created by the other party, and every change is logged with the time and the user identifier. The export reflects the content of the unmodifiable Event Log at the time it is generated — which is not a guarantee of its admission as evidence in particular proceedings; that is decided by the court or other authority conducting the proceedings. The Controller may in future introduce additional mechanisms for verifying the authenticity of the exported file (e.g. a checksum), of which Users will be informed.
• The export and its further transfer to a third party (court, mediator, legal representative, specialist) is an action taken independently by the Parent outside the App; the Controller provides only the technical export function, does not verify or certify the authenticity or completeness of the exported data, and is not responsible for how the Parent further uses it.
• None of the above export tools requires separate consent — their availability follows from the nature of the App as a shared register of arrangements between the Parents and from the rights of access and data portability, of which the User is informed when creating the Account.

15. Automated decision-making and profiling

The App does not profile Users or Children and does not take any automated decisions producing legal effects or similarly significantly affecting the User or the Child within the meaning of Art. 22 GDPR. AI Suggestions (see section 9) are only a technical tool proposing content based on data entered by the User — they do not form independent assessments or conclusions and do not save any data without a separate action by the User.

• Every AI Suggestions proposal must be saved separately by the User — without that action no data is changed or saved.

16. User rights

Under the GDPR, the User has the following rights:

• right of access to data, including obtaining a copy (Art. 15 GDPR),
• right to rectification (Art. 16 GDPR),
• right to erasure, "right to be forgotten" (Art. 17 GDPR), subject to the limitations concerning shared content (cards, messages, Event Log) described in section 13, justified by the other Parent's interest in preserving the shared record (Art. 6(1)(f) GDPR) and — additionally — by the establishment, exercise or defence of legal claims (Art. 17(3)(e) GDPR),
• right to restriction of processing (Art. 18 GDPR),
• right to data portability (Art. 20 GDPR),
• right to object to processing based on legitimate interest and to profiling (Art. 21 GDPR),
• right to withdraw consent at any time, without affecting the lawfulness of processing carried out before its withdrawal,
• right to lodge a complaint with the President of the Polish Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych).

17. Rules for disputes concerning the Child's data

• the rights concerning the Child's data are exercised on the Child's behalf by each of the Parents/Guardians as legal representative; both Parents in principle have equal rights to view and edit the shared data of the Child;
• the Controller does not resolve parental disputes about the scope or manner of processing the Child's data — in the case of conflicting requests from the two Parents (e.g. one demands deletion of data, the other objects), the Controller refrains from carrying out the disputed request until the Parents reach an amicable agreement or a decision of a court or mediator is presented, unless the law requires immediate action;
• if the Controller is presented with a final court decision governing parental authority or contact, the Controller will take its content into account when handling requests concerning the Child's data;
• entries saved in the Event Log remain unmodifiable and are not deleted at the request of only one Parent, because of their function as a shared register of arrangements — it is only possible to delete all data after both Parents have closed their Accounts or in accordance with section 13.

18. Data security

The Controller applies appropriate technical and organisational measures to protect personal data, in particular: encryption of data at rest and in transit (TLS), role-based access control, hosting of infrastructure in the EU, regular security reviews and procedures for reporting personal data breaches in accordance with Art. 33–34 GDPR.

19. Changes to the Privacy Policy

This Policy will be updated as the App develops — in particular as new features affecting the scope of processed data are introduced. The current version of the Policy is always available in the App, with the date of its last update.

Users will be informed of material changes to the Policy (in particular changes to the purposes or legal bases of processing, categories of recipients or retention periods) electronically, reasonably in advance, before they take effect.

20. Contact and complaints

In all matters concerning the processing of personal data and the exercise of the rights referred to in section 16, the Controller can be contacted at the e-mail address given in section 2. The User also has the right to lodge a complaint with the President of the Polish Personal Data Protection Office (ul. Stawki 2, 00-193 Warsaw).