Scope. This policy applies to the Structuro web app (structuro.ai) and the website structuro.eu.
1. Who we are
Structuro is a service of Structuro AI, a sole proprietorship registered at Machinekamerplein 32-325, 5617AP Eindhoven, the Netherlands. Registered with the Dutch Chamber of Commerce under number 97938289. Privacy contact: info@structuro.eu. We are the controller for the data we process about you through the Structuro web app.
2. What data we process
Account data: email address, password hash, the name you set in your profile, timestamps of creation and last login, and (if you set it) your analytics choice.
Planning and usage data: tasks (title, deadline, priority, status, micro steps, estimated duration, energy level), day starts (energy and top-3 selection), wind-downs (completed tasks, energy, satisfaction, optional reflection text, optional notes), parked thoughts (free text you enter), focus sessions (start and end time, number of attempts per task), and daily aggregates such as completed tasks and total focus minutes.
Cycle tracking (optional): only if you enable this feature in Settings, we process the start date of your last period, your average cycle length and menstruation duration, plus the date on which you gave consent. We use this data solely to colour your day-start context. You can turn the feature off at any time; the fields are then erased.
Payment data: we do not process full payment details ourselves. When you pay, you are redirected to our payment provider Stripe. We receive from Stripe only your payment status, subscription type, amount, and a tokenized reference to your payment method (no full card number or bank account).
Notifications: web push endpoints and encryption keys per browser or device (only when you enable notifications), and log records of sent reminders so we do not send duplicates.
Technical data: cookies and local storage for session handling, language preference, and your analytics choice (see chapter 7). Limited error and load logs at our infrastructure partner Supabase, only as needed for security and availability.
TikTok attribution: if you arrive at Structuro via TikTok (or a TikTok ad), the URL may include parameters such as ttclid and UTM tags (utm_source, utm_medium, utm_campaign, utm_content). We read those parameters to know which channel brought you. See chapter 5.
3. Special categories of personal data
In the parked thoughts and reflection fields you can enter free text. These may contain mental or health-related notes. Optional cycle tracking also falls under health data. We process these only because you enter them yourself or enable the feature yourself. We do not share these fields with third parties for analysis or training. We do not make automated decisions with legal effects on you. Suggestions in the app (such as top-3 selection or focus suggestions) are aids that you accept or ignore. You can erase this data at any time through the app.
4. Why we process this
We process personal data only on a valid lawful basis under the GDPR: performance of our contract with you, your consent, a legal obligation, or our legitimate interest (balanced against your interests).
Account, sign-in and core functionality: tasks, day start, wind-down, parked thoughts, focus: needed to deliver the service.
Payment and billing: needed to handle your subscription and keep records.
Cycle tracking: only with your consent via the toggle in Settings.
Web push notifications: only with your consent via browser or app; can be turned off in Settings.
Product analytics (PostHog): only with your consent via the cookie banner and toggle in Settings. Without consent we only measure anonymously and cookieless.
TikTok attribution: legitimate interest and/or your analytics consent: to measure whether TikTok traffic leads to use or sign-up. See chapter 5.
Error tracking and security: technical error reports, rate limits and audit logs: needed to keep the service secure and available. We do not record the content of your tasks, parked thoughts or cycle tracking.
5. TikTok-related data
Structuro has landing pages and campaigns that receive traffic from TikTok (for example via structuro.ai/tiktok). If you click through from TikTok or a TikTok ad, the following data may reach us:
Click and campaign data: URL parameters such as ttclid (TikTok click ID) and UTM tags. We use these to attribute the visit to TikTok as a source in our own product analytics (PostHog).
What we do not do without separate consent: we do not place a TikTok Pixel on our sites as default tracking, and we do not share your account data, tasks, parked thoughts or cycle data with TikTok. If a TikTok Pixel or Events API is later used for ad measurement, that will only happen with your prior consent via the cookie banner, and we will state that explicitly here.
Retention: TikTok attribution parameters follow the product analytics retention period (maximum 12 months in PostHog), unless you withdraw analytics consent or delete your account.
TikTok itself may process its own data when you use the TikTok app or website; that is covered by TikTok's privacy policy, not this policy.
6. Processors
We use the parties below to process data on our behalf. We have a Data Processing Agreement with each of them.
Supabase, Inc.: database region EU (Stockholm). Database and authentication.
Vercel Inc.: United States. Web application (rendering, edge routing). Certified under the EU-US Data Privacy Framework.
Stripe Payments Europe, Limited: Ireland. Payments, subscriptions and billing (retention in line with statutory tax requirements).
PostHog Inc.: United States, data region EU. Product analytics and error tracking as described in chapters 4 and 7, including optional TikTok attribution parameters. Certified under the EU-US Data Privacy Framework.
Resend (Resend.com Inc.): United States. Transactional emails; receives only the email address and content of that email.
Upstash, Inc.: United States. Rate-limiting of public endpoints; receives your IP address or a hashed form of it.
Browser push providers: Apple, Google, Mozilla, Microsoft: delivery of push messages. We only send text you activate in your settings.
Transfers to countries outside the EU are based on the EU-US Data Privacy Framework or Standard Contractual Clauses (SCCs). An up-to-date sub-processor list is available on request via info@structuro.eu.
7. Cookies and local storage
We place no tracking cookies without your consent. We always use the following storage because the service does not function without it:
A Supabase session cookie (HttpOnly, Secure, SameSite=Lax) to keep you signed in.
localStorage keys for language preference, your analytics choice, and (offline) tasks not yet synced. Lifetime: until you erase them yourself or delete your account.
Stripe places its own cookies during the payment flow for fraud prevention and session handling; these are necessary for the payment function and fall under Stripe's own privacy policy (stripe.com/privacy).
With your consent, PostHog may use cookies and localStorage to recognise your session and link events to your account. Without consent we use cookieless mode: anonymous counting without personal linkage. You set your choice via the cookie banner on your first visit, or later via Settings, toggle Anonymous product analytics.
TikTok attribution parameters (such as ttclid) come from the URL on arrival; they are not cookies we set ourselves. Any cookies from TikTok inside the TikTok app fall under TikTok.
8. Retention periods
Account and planning data: kept while your account is active.
Upon account deletion: via Settings we remove your account data, planning data and cycle tracking from the production environment immediately, and delete your login account. We keep an anonymised audit record (without personal data) for security purposes. Backups at Supabase are rotated within 30 days; after that the data is also gone there.
Payment history: invoice and payment data are retained by Stripe in accordance with statutory retention requirements (seven years), even after you delete your Structuro account. This covers invoice number, date, amount, VAT and data legally required on an invoice; not planning data or free-text fields.
Server and security logs: maximum 30 days.
Reminder send logs: log records of sent day-start, lunch and shutdown reminders: maximum 90 days.
Product analytics (PostHog): analytics events are kept for a maximum of 12 months and then automatically deleted.
9. Your rights
You have the right to access, rectify, erase, restrict, port (data portability), or object to the processing of your data. For most rights you can use the app:
Access and edit: profile settings and the Tasks, Day start, Wind-down and Parked tabs.
Erase: Settings, button 'Delete account'.
Withdraw consent for analytics: Settings, toggle 'Anonymous product analytics'.
Withdraw consent for cycle tracking: Settings, Cycle section, turn the toggle off.
For access, rectification or data portability requests, and for other requests that cannot be made directly in the app, email info@structuro.eu. We respond within 30 days. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) via https://www.autoriteitpersoonsgegevens.nl/nl/zelf-doen/privacyrechten/klacht-indienen-bij-de-ap.
10. Security and data breaches
We use TLS, row-level security in the database, separated service-role keys, and rate limiting on sensitive endpoints. In case of a data breach that creates a risk for you, we report it to the Dutch Data Protection Authority within 72 hours and, where applicable, also to you.
11. Changes
This policy may change. The current version is always on this page. We announce significant changes in the app.
