Pagino Privacy PolicyEffective Date: 15 September 2025
Company: Syntraq Labs Ltd (United Kingdom)
App: Pagino⸻1. IntroductionPagino (“we,” “our,” or “us”) is a study application developed by Syntraq Labs Ltd (UK). We help students scan, summarize, and learn from study materials using AI.We respect your privacy and comply with global data protection laws, including:
• GDPR (EU/UK)
• CCPA (California, US)
• COPPA (US Children’s Privacy Act)
• FERPA (US Family Educational Rights and Privacy Act, for institutional use)By using Pagino, you agree to this Privacy Policy.⸻2. Information We CollectPagino collects only what is necessary for app functionality.Content Data
• Scanned or uploaded content → sent to Google Cloud Vision API for text extraction (OCR). Not permanently stored by Pagino.
• Text summaries, flashcards, quizzes → sent securely to OpenAI API for AI processing. No data is used for AI training.
• Saved content → stored only on your device. If you delete the app or clear storage, your saved content is deleted.Account & Payment Data
• Pro users → subscription handled entirely by App Store / Play Store. Pagino does not store payment card details.
• Basic account info (email, subscription status) may be stored by the app stores for entitlement checks.Technical Data
• Device type, app version, OS → used for compatibility.
• Crash logs & performance analytics → anonymized, temporary (90 days max).
• Cookies/trackers → Pagino does not use advertising or social media trackers.⸻3. Legal Basis for Processing (GDPR)We process data under these grounds:
• Consent – when you scan, upload, or request AI processing.
• Contract performance – to deliver paid features (subscriptions).
• Legitimate interest – improving app reliability and security.
• Legal obligation – compliance with laws (e.g., payment records).⸻4. How We Use Information
• Provide OCR, summaries, translations, flashcards, and quizzes
• Store study content locally on your device (if you choose)
• Process subscriptions via App Store/Play Store
• Improve app performance through anonymized analytics
• Respond to support requests
• Ensure compliance with legal and security obligations⸻5. Third-Party ServicesPagino relies on trusted third-party providers:
• OCR: Google Cloud Vision
• AI Summaries & Quizzes: OpenAI API
• Payments: Apple App Store & Google Play Store (subscription billing)
• Analytics: Privacy-focused crash and performance tools (no personal identifiers)We ensure all partners comply with applicable privacy laws.⸻6. Children’s Privacy (COPPA)
• Pagino is for users 13+ (or local minimum age).
• Users under 13 require verifiable parental consent.
• No behavioral advertising or personal profiling of minors.
• Parents can review or request deletion of their child’s data at: [email protected]⸻7. Educational Privacy (FERPA)For institutional users (e.g., schools/universities):
• Pagino complies with FERPA when processing student data.
• Student-generated content is treated as educational records.
• Institutions maintain full control over student data.
• No unauthorized disclosure to third parties.
• FERPA-specific Data Processing Agreements (DPAs) are available.⸻8. Data Retention & DeletionBecause Pagino does not run central servers, most data is transient or stored locally on your device.
• Scans/uploads → deleted after OCR processing.
• Summaries/flashcards/quizzes → deleted when you delete them or uninstall the app.
• Crash logs/analytics → deleted automatically after 90 days.
• Payment records → retained only by App Store/Play Store in line with financial regulations (up to 7 years).You can request deletion of any support communications or account-related data via [email protected].⸻9. Your Privacy RightsGDPR (EU/UK users): Right to access, correct, delete, object, restrict, and port data.
CCPA (California users): Right to know, delete, opt-out of sale (Pagino does not sell data), and non-discrimination.
FERPA (educational users): Rights to inspect, review, amend, and control disclosure of student records.Requests: [email protected]⸻10. Security & International Transfers
• Encryption: TLS 1.3 (in transit), AES-256 (at rest where applicable).
• Zero storage principle: Pagino minimizes stored data.
• International processing: Google & OpenAI may process data in US/EU. Safeguards: SCCs + GDPR compliance.
• Incident response: GDPR’s 72-hour breach notification rule is followed.⸻11. Cookies & TrackingPagino uses only essential cookies for authentication and fraud prevention.
Optional anonymized analytics can be disabled in-app.
No ads, no social media trackers, no cross-site tracking.⸻12. Accessibility CommitmentPagino is committed to inclusive learning:
• Clear summaries and simplified text modes
• Translation support for multilingual students
• Compatibility with standard device accessibility features (screen readers, font scaling)
• Ongoing improvements based on user feedback⸻13. Changes to This PolicyWe may update this policy to reflect new features, laws, or practices. Updates will be posted here with a new “Last Updated” date.⸻14. Contact InformationCompany: Syntraq Labs Ltd
Jurisdiction: United Kingdom
Support: [email protected]
Privacy: [email protected]
Institutional Inquiries: [email protected]
Accessibility Issues: [email protected]If required by law, we will appoint an EU representative and/or Data Protection Officer (DPO).