Privacy · V2 v1.2.2

A minimal product questionnaire, including some younger participants

The questionnaire is used to make concrete app-design decisions. It is neither a diagnostic tool nor medical research.

What is stored

AnswersClosed choices about interface and features.

Pseudonymous sessionA private token enables save, resume and deletion. No account.

CohortThe database distinguishes adult / minor only. Exact country is not stored as an answer.

Not requestedName, date of birth, diagnosis, medication, school, workplace or participant email.

Ages 13–17: regional routing

Country is asked before a session is created only to choose the privacy route. The exact selection stays in the browser. The server validates only a coarse eligibility code and does not persist it in questionnaire tables.

France, Belgium, Luxembourg: ages 13–17 accepted without a parent email.
United States: ages 13–17 accepted; under 13 excluded.
Canada outside Quebec: ages 13–17 accepted.
Quebec: ages 14–17 accepted; at age 13 the survey stops without asking for parent contact details.
Switzerland: ages 14–17 accepted for this round; age 13 is not currently accepted. This is a cautious project rule, not a universal Swiss legal threshold.
Other countries: minors are not currently accepted.

Legal basis — France, Belgium, Luxembourg

For younger participants in these countries, minimal processing relies on legitimate interests under GDPR Article 6(1)(f): testing concrete design choices before development while avoiding identifying or health information.

The route does not rely on Article 6(1)(a) consent as the GDPR legal basis. Article 8 provides special rules where consent is the basis used for an online service offered to a child. Younger participants still merit specific protection and an enhanced balancing assessment.

Voluntary participation is not the same as “consent” as the GDPR legal basis.
The participation checkbox records the young person’s choice and understanding; it is not presented as the GDPR legal basis for the supported-EU minor route.

Safeguards

no diagnosis or medication questions;
no free text;
no account, advertising, commercial profiling or third-party analytics;
no young participant or parent email in the new route;
optional modules clearly separated;
exact country not retained;
response deletion while the private token remains available.

Objection and deletion

Where legitimate interests are used, the person can object to processing. Here the practical mechanism is the “Delete my response” button available from the pause screen and after submission while this browser still holds the private session token.

If the token is lost, deliberate lack of identifiers may make it technically impossible to identify the relevant response without collecting more personal data.

Legacy guardian route

From v1.2.2 onward, no new guardian request is created. Existing private links already sent remain functional so historical withdrawal options are preserved.

Retention

unfinished sessions: eligible for deletion after 30 days of inactivity;
submitted answers: up to 12 months for this cycle, then deletion or irreversible aggregation;
legacy pending guardian requests: expiry after 7 days under the existing mechanism.

A cautious approach for the current minimal scope, not universal legal certification. New countries, health data, free text, accounts, profiling or advertising require a fresh review.

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