Privacy statement
Version: 2026-10-02.5
Dieses Dokument ist auf Englisch verfügbar. Bei Abweichungen gilt die niederländische Fassung.
Retrieva helps you study with homework, tests and practice questions. To do that we need some data about you. This statement explains which data, why, how long we keep it and what you can do yourself. We never sell data and we do not track you across the internet.
1. Who is responsible?
The controller for your personal data is Codea Solutions. Retrieva is a service of Codea Solutions. Registered with the Dutch Chamber of Commerce (KvK) under number 42180669. VAT number: to follow. The business address is listed under company details.
Questions about privacy? Email privacy@retrieva.nl. We have not appointed a data protection officer because it is not mandatory for our activities; that email address is your point of contact.
2. Which data do we process, for what purpose and on what legal basis?
The table below shows, per type of data, why we use it and on which legal basis under the GDPR this happens.
| Data | Purpose | Legal basis |
|---|---|---|
| Account: name, email address and password (we store the password only as a hash). If you log in with Google or Apple: the link identifier and the email address they pass on to us. | Creating an account, logging in and letting you find your data again. | Performance of the contract (Art. 6(1)(b) GDPR) |
| What you create and upload: subjects, questions, answers, notes, flashcards, tests, planner entries, results, and photos or files of homework and tests. | Providing the service: making explanations and practice questions, showing your progress and having you repeat things at the right moment. | Performance of the contract |
| Settings: language, theme, daily goal, reminders and, if you enter one yourself, your own API key (stored encrypted). | Making the app work the way you want. | Performance of the contract |
| Usage data: the days and hours you were active and how many AI actions you used. | Showing your progress, safeguarding fair use and keeping AI costs manageable. | Performance of the contract and our legitimate interest (Art. 6(1)(f)) |
| Payments: chosen subscription, amount, date, status, the Mollie reference and the identifier of your customer record and mandate at Mollie (for automatically renewing a monthly subscription). We never see your bank or card details; they go straight to Mollie. | Processing payments, automatically renewing a monthly subscription, emailing you beforehand about a renewal or the end of your subscription, sending invoices and keeping our accounts. | Performance of the contract and legal obligation (Art. 6(1)(c): tax record-keeping) |
| Agreement: when you agreed to the terms and privacy statement, the version, and your confirmation of your age. For a payment also your express consent to start immediately. | Proving that you agreed, and that you expressly waived the right of withdrawal. | Legal obligation and legitimate interest |
| Origin at sign-up: the channel you came from (for example “tiktok”), the campaign, the language page and your country, derived from your browser’s language setting. So not from your IP address. | Finding out whether our promotion works. One line per account; no profile and no tracking pixels. | Legitimate interest (Art. 6(1)(f)). You can object. |
| Counting site visitors: without cookies. We make a daily hash of address and browser with a secret that changes every day and is never stored. The next day the hash can no longer be traced back. | Knowing how many people visit the site and click through. | Legitimate interest. No personal data remains. |
| Security: we keep your IP address only briefly in working memory to limit too many login attempts. It does not enter the database. | Preventing abuse and attacks. | Legitimate interest |
| Email: a reminder email (only if you switch it on), notices about your subscription and, only if you set it up, a weekly summary to the address of a parent or carer. That parent or carer first gets one email to confirm it themselves; without that confirmation we send nothing. | Helping you repeat in time and informing you about your subscription. | Consent (Art. 6(1)(a)) for reminders and the weekly summary; performance of the contract for subscription notices. |
| Family: with a Family subscription, the email address the payer invites, and who is in which family. The payer only sees the name and email address of family members. | Inviting family members and giving them access. | Performance of the contract (Art. 6(1)(b)). |
| News and messages: now and then an email about new features or a Retrieva promotion, only to people with an account. Every email has an unsubscribe link, and you can switch it off in Settings. | Telling you what is new in the service you already use. | Legitimate interest (Art. 6(1)(f)) and Art. 11.7(3) Dutch Telecommunications Act (own customers, own service). |
| Messages to us: what you email or write to us. | Answering your question. | Legitimate interest and performance of the contract |
We do not use your data for advertising, we do not sell it and we do not share it with data brokers.
3. How the AI works with your data
Retrieva creates explanations, practice questions and summaries with artificial intelligence from Anthropic. When you offer a photo, file or text, we send its content (and settings such as language and level) to Anthropic to have an answer made. We do not send your name or email address along.
According to Anthropic’s terms for commercial API users, data submitted through the API is not used to train their models. Anthropic may retain it temporarily for safety and abuse prevention. Please read their current terms for the exact periods.
What we ask of you: do not photograph or upload health data, names or data of classmates or other people, or passwords. If that is on a sheet, cover it up. What you upload we process as described above.
No automated decisions with effects: the AI can assess an answer to a practice question, but that is feedback for yourself. No decisions with legal or similarly significant effects are taken about you. You can always change the assessment yourself. AI can make mistakes; always check important answers against your own course material.
4. Children and young people
Retrieva is intended for pupils and students. You must be 16 or older to create an account yourself. If you are younger, permission from a parent or carer is required. When creating an account we ask you to confirm that you are 16 or older, or that a parent or carer gives permission. We do not verify this ourselves; the parent or carer is responsible for that permission.
Are you a parent or carer and do you want to see, correct or delete your child’s data? Email privacy@retrieva.nl. We will then check that you are the parent or carer. Even if a parent receives a weekly summary, the child’s answers and notes stay private: the summary contains only totals, such as time practised and the percentage correct.
5. Who do we share your data with?
We use companies that process data on our behalf (processors). We have made agreements with them about security and confidentiality. They are:
| Party | Purpose | Country |
|---|---|---|
| Anthropic, PBC | Artificial intelligence: explanations, practice questions, summaries and assessment of answers. | United States |
| Replit, Inc. | Hosting of the app, the database, uploaded files and backups. | United States |
| Google (Google Ireland Ltd. / Google LLC) | Google Drive, where we keep the backups encrypted (away from the server, so they are not lost together with it), and sending email (reminders, subscription notices, invoices). | Ireland / United States |
| OpenAI, L.L.C. | Only if photos for questions are switched on: a description of the desired photo that our AI writes for a question, to create an image for it. No name or email address. | United States |
| Mollie B.V. | Payments via iDEAL and card. Mollie is also responsible for payment data itself and has its own privacy statement. | Netherlands |
| Google Ireland Ltd. / Apple Distribution International Ltd. | Only if you log in with Google or Apple. They decide for themselves what they do with your login activity. | Ireland (may involve transfers outside the EEA) |
We otherwise only provide data to authorities or other parties if we are legally required to do so.
6. Transfers outside the European Economic Area
Anthropic, Replit, Google and OpenAI process data (also) in the United States, so outside the EEA. Such transfers only take place on the basis of a valid transfer mechanism under the GDPR: the EU-US Data Privacy Framework or the European Commission’s standard contractual clauses. If you want a copy, email privacy@retrieva.nl.
7. How long do we keep your data?
| Data | Retention period |
|---|---|
| Account and everything you made and uploaded | As long as you keep your account. If you do nothing in the app for 24 months, we automatically delete your account and everything in it. About 30 days beforehand we email you about this, if we have a working email address. An active paid subscription is never cleaned up. |
| After you delete your account | Immediately erased from the database and from disk, including photos and snapshots of your account. If an administrator deletes your account, for example at your request, we keep a snapshot for another 30 days so it can be restored; after that it is gone. We make one backup of the whole system per day, keep it encrypted (AES-256) and for no longer than 10 days; after that your data is no longer in them either. |
| Payments and invoices | 7 years, because tax law requires us to. Once your account is deleted we detach payments from you; invoices are kept as the law requires. |
| Agreement and consent | As long as your account exists, and afterwards as long as needed to prove that you agreed. |
| Login sessions | Until you close your browser (at most 24 hours), or 7 days if you tick ‘Remember me’; shorter if you log out. |
| Site visitor counts | No personal data; we discard the daily counts after about 13 months. |
| Origin data | As long as your account exists; deleted together with your account. |
| Which emails we sent you (to which address, the subject and whether it arrived; not the content) | 6 months, so we can check whether an email reached you; deleted sooner if you delete your account. |
| When you were active in the app, per hour | 90 days. We only use this to see which hours are busy; deleted sooner if you delete your account. |
| Payment attempts that were not completed (cancelled, failed or expired) | 30 days. A successful payment is kept for 7 years (see above). |
8. How do we protect your data?
- All connections use https.
- Passwords are never stored readably: only as a hash (bcrypt).
- An API key you enter yourself is stored encrypted (AES-256-GCM).
- Uploaded photos and files can only be retrieved by you, logged in; sharing a link does not give access.
- Login cookies cannot be read by scripts (httpOnly) and are not sent to other sites.
- The site loads no scripts, fonts or images from other parties, so no data leaks to third parties just by opening a page.
- Limits on login attempts, daily backups that are stored encrypted (AES-256), and administrator access only where necessary.
Despite all care, a data breach can happen. If it does and there is a risk to you, we will report it within 72 hours to the Dutch Data Protection Authority and, if the risk is high, to you as well.
9. Your rights
Under the GDPR you have the following rights:
- Access: knowing which data we hold about you.
- Rectification: having incorrect data corrected. You change your name, email address and password yourself in the app.
- Erasure: having your account and all your data erased. You do that yourself in the app under Settings; it happens immediately.
- Restriction and objection: objecting to processing based on our legitimate interest, for example the origin data.
- Portability: taking all your data with you. In the app you can download an export under Settings (JSON, CSV, ICS, Markdown), and your question bank and flashcards separately.
- Withdrawing consent: for example for reminders or the weekly summary. You switch these off in Settings, or via the unsubscribe link at the bottom of every email. Earlier processing remains valid.
If something does not work in the app, email privacy@retrieva.nl. We respond within one month. To be sure it is you, we may ask for confirmation.
Do you disagree with how we handle your data? Please contact us first. You also always have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, autoriteitpersoonsgegevens.nl) or your local supervisory authority.
10. Cookies and local storage
We only use cookies and storage that are necessary for the app to work, and no advertising or tracking cookies. See the cookie statement.
11. Changes
If something important changes in how we handle data, we will update this statement, raise the version date at the top and tell you in the app or by email. This statement is version 2026-10-02.5. The Dutch version is authoritative.