Privacy Policy

1. Introduction

Homeschowl ("we", "us", "our") operates the Homeschowl platform at homeschowl.com and app.homeschowl.com. This policy explains how we collect, use, store, share, and protect personal data when you use the service.

2. Who we are

Homeschowl is operated by Jefersson from Brazil. Homeschowl is a homeschool management platform created to help families plan, organize, and keep track of learning at home. Our initial supported markets are Brazil and the United States.

Privacy contact: [email protected]. General contact: [email protected].

3. Data we collect

Data you provide

Category	Data	Required
Account	Name, email, password (stored as a hash)	Yes
Profile	Display name, preferred language, avatar	Partially
Family	Family name, timezone, school year configuration	Yes
Students	Name, date of birth, grade level, avatar color	Yes
Academic	Subjects, lesson plans, grades, attendance, instruction hours	Yes
Materials	Book titles, authors, reading progress	No
Financial	Educational expenses, categories, receipts	No
Billing	Billing name, email, address and tax information when provided; plan, subscription, invoice and payment references. Card details are entered directly with Stripe and are not stored by Homeschowl.	For paid plans

Data collected automatically

• IP address (server logs) — security and abuse investigation
• User-Agent (HTTP headers) — compatibility and debugging
• Access timestamps (application logs) — auditing and security
• Language preference (browser Accept-Language) — personalization
• Cookie-free audience measurement — Plausible receives a privacy-filtered page URL containing only the page path and valid allowlisted UTM campaign fields. Its request can also support aggregate source, device, and approximate location reports.
• Optional advertising measurement — only after you allow Meta, the browser Pixel can process PageView and CompleteRegistration events, the page path, browser and request information, and Meta advertising identifiers available in the browser.
• Optional Google Ads measurement — only after you accept optional cookies, the Google tag can process public page visits and one Sign-up conversion after a parent account is confirmed. It may receive the sanitized page path, valid UTM campaign fields and Google click identifiers (gclid, gbraid, wbraid), browser and request information, and Google advertising cookies. It does not run on private pages.
• Consented signup attribution — source, medium, campaign, content, term, first landing path, referring hostname, consent date, and consent version. Invalid, email-like, overlong, and full-URL values are discarded.

Data we do NOT collect

• Precise geolocation
• Biometric data
• Mandatory photos of children
• Social media profile details through Meta Pixel
• Email addresses, phone numbers, or student information for Meta Advanced Matching
• Raw fbclid, _fbp, or _fbc values in the Homeschowl product database
• Raw gclid, gbraid, wbraid, or _gcl_* values in the Homeschowl product database
• Academic activity for advertising or behavioral profiling

4. How we use your data

Purpose	Legal basis (GDPR)	Legal basis (LGPD)
Providing the service (planner, grades, attendance)	Contract performance (Art. 6(1)(b))	Contract performance (Art. 7, V)
Creating your account and authenticating you	Contract performance	Contract performance
Processing subscriptions, payments, taxes, cancellations, and billing recovery	Contract performance and legal obligation	Contract performance and legal obligation
Sending transactional emails (password reset, confirmations)	Contract performance	Contract performance
Generating academic reports (PDF)	Contract performance	Contract performance
Protecting against fraud and abuse	Legitimate interest (Art. 6(1)(f))	Legitimate interest (Art. 7, IX)
Maintaining and improving the service using operational, aggregated, or anonymized information	Legitimate interest	Legitimate interest
Measuring aggregate marketing-site visits and signup goals with cookie-free Plausible	Legitimate interest	Legitimate interest
Measuring Meta advertising results and retaining sanitized signup attribution	Consent	Consent
Measuring Google Ads results from public visits and confirmed parent signups	Consent	Consent

5. Legal basis for processing

• Consent: when explicitly requested for optional Meta advertising measurement and signup attribution, or for another specific purpose where applicable.
• The same optional-cookie choice also applies to Google Ads measurement of public pages and confirmed parent signups.
• Contract performance: everything necessary to provide the service, subscriptions, and billing.
• Legal obligation: records that applicable law requires us to keep.
• Legitimate interest: security, fraud prevention, and service improvement using operational, aggregated, or anonymized information.

6. Children's data

Parent-managed accounts

• The service is intended for parents and legal guardians aged 18 or older.
• Children do not create the family account directly — the parent enters and manages the children's data.
• The account holder must have legal authority to provide and manage the child's data.
• We do not monetize children's data — no ads, no data sales.
• Parents can review and request access, portability, or deletion of their child's data, subject to applicable law and the retention periods below.

Children in Brazil and the United States

• We handle children's and adolescents' data with their best interests, safety, and age-appropriate privacy in mind.
• Where applicable law requires parental notice, authorization, or specific consent, the parent or legal guardian must complete that step before the relevant processing begins.
• Information about processing is provided in simple, clear, accessible language.

Student portal

• The parent creates the child's login and authorizes access.
• The student only sees their own data (grades, schedule).
• The parent retains full control and can revoke access at any time.
• Neither Plausible nor Meta Pixel runs in the Student Portal. We do not send student or academic information to either provider.
• Google Ads also does not run in the Student Portal or receive student or academic information.

7. Sharing with third parties

Third party	Data shared	Purpose
Stripe	Billing contact details, billing address and tax information when provided, subscription and payment information	Checkout, recurring billing, invoices, taxes, fraud prevention, and Customer Portal
Cloudflare R2	Uploaded files (avatars, receipts, PDFs)	File storage
Cloudflare	IP address, request metadata	DNS, edge proxy, and traffic protection
Resend	Recipient email, name	Transactional email delivery
Hetzner	All data (hosting)	Infrastructure hosting
Plausible Cloud	Privacy-filtered page URL, sanitized UTM campaign fields, referring source, and technical request data	Cookie-free aggregate visits and the Signup CTA Click and Account Created goals
Meta	Only after consent: Pixel events, page path, browser and request data, and Meta advertising identifiers available in the browser	Advertising measurement through PageView and CompleteRegistration
Google Ads	Only after consent: public-page visits, confirmed parent Sign-up conversions, sanitized page path and campaign fields, valid Google click identifiers, browser and request data	Advertising measurement on the public marketing site and parent signup route; no personalized-advertising signal is requested

• We do NOT sell data to third parties.
• We do NOT use children's or academic data for advertising, and Homeschowl does not display third-party ads.
• Meta Advanced Matching and Conversions API are disabled. We do not send email addresses, phone numbers, or student data to Meta.
• We do not send email addresses, phone numbers, student data, or academic activity to Google Ads. We do not request remarketing or ad personalization.
• We use service providers only as needed to operate, secure, bill for, and support Homeschowl.
• The providers used can vary by feature and deployment configuration. We update this policy when a material provider change affects how personal data is handled.

8. Storage and security

• Encryption in transit: HTTPS is enforced with HSTS.
• Passwords: parent passwords are hashed with Argon2id.
• Tokens: JWTs are stored in Secure, HttpOnly cookies. Production authentication cookies use SameSite=Strict.
• MFA: TOTP two-factor authentication available.
• Database access: internal network only — the database is not reachable from the internet.
• Data isolation: each family sees only its own data.

9. Data retention

• While an account is active, we retain the data needed to provide the service.
• When paid access ends, a family that fits the Free plan limits returns to writable Free access. A family above those limits becomes read-only until it reduces usage or reactivates a paid plan.
• Automated product-data and uploaded-file deletion is not active for the commercial launch. We do not publish or promise an automatic deletion deadline while that automation is disabled.
• Self-service account deletion is not available yet. To request closure, access, export, correction, or deletion, email [email protected]. We may verify the account owner and parental authority before fulfilling a request.
• At launch, verified requests follow the controlled manual process documented for Operations. That procedure and the privacy contact were approved for this effective version.
• The marketing-consent cookie lasts up to 180 days unless you change your choice sooner or Global Privacy Control requires Meta to remain disabled.
• Global Privacy Control also keeps Google Ads disabled regardless of a saved cookie choice.
• Sanitized account-acquisition fields are retained with the parent account for acquisition reporting and follow the same closure, deletion-request, backup, and provider-retention boundaries described in this section.
• Aggregate Plausible reports and Meta event records remain in those provider accounts according to their configured retention and applicable provider terms. Homeschowl does not copy raw browser-event logs into the product database.
• Google Ads event records remain in the Google Ads account under its configured retention and applicable terms; Homeschowl does not copy those raw events into the product database.
• Limited copies can remain temporarily in backups or with service providers until their normal secure deletion or overwrite cycle completes.

10. Your rights

Right	GDPR	LGPD	United States	How to exercise
Access	Where applicable	Where applicable	Where applicable by state law	Email [email protected]
Correction	Where applicable	Where applicable	Where applicable by state law	Edit in the interface or email us
Portability	Where applicable	Where applicable	Where applicable by state law	Email [email protected]
Deletion	Where applicable	Where applicable	Where applicable by state law	Email [email protected]
Consent withdrawal, restriction, or objection	Where applicable	Where applicable	Where applicable by state law	Email [email protected]
Non-discrimination for exercising privacy rights	Where applicable	Where applicable	Where applicable by state law	Guaranteed by policy

• We respond within the period required by the law that applies to your request.
• Available export formats depend on the records and reports currently supported by the service.
• You can change or withdraw optional-cookie consent at any time through Cookie preferences in the marketing-site footer or on the parent signup page.

11. Cookies and similar technologies

Cookie	Type	Purpose	Duration
hs_access_token	HttpOnly, Secure, SameSite=Strict	Parent authentication	15 minutes
hs_refresh_token	HttpOnly, Secure, SameSite=Strict	Parent session renewal	Session or 7 days
hs_remember_me	HttpOnly, Secure, SameSite=Strict	Parent session preference	Session or 7 days
hs_student_access_token	HttpOnly, Secure, SameSite=Strict	Student Portal authentication	Session or 24 hours
hs_student_remember_me	HttpOnly, Secure, SameSite=Strict	Student Portal session preference	Session or 24 hours
hs_marketing_consent	First-party, Secure, SameSite=Lax	Records your Meta choice, consent version and date, and — only when allowed — sanitized first-touch attribution	180 days
_fbp and _fbc	Meta marketing cookies, only after consent	Advertising measurement and attribution by Meta	Set by Meta; removed when you revoke consent where browser access allows
_gcl_*	Google advertising cookies, only after consent	Google Ads measurement and click attribution	Set by Google; removed when you revoke consent where browser access allows

• The same optional-cookie choice recorded in hs_marketing_consent also controls Google Ads. Older choices are not reused for this updated version.
• Plausible uses no cookies and is active only on the marketing and legal site and the public parent signup route.
• Meta Pixel is optional. Before consent, we do not request fbevents.js or create known Meta cookies.
• Google Ads is optional. Before consent, we do not request gtag.js or create known Google advertising cookies.
• Meta Pixel never runs in the authenticated parent dashboard or Student Portal.
• Google Ads never runs in the authenticated parent dashboard, Admin Portal, or Student Portal.
• Global Privacy Control is treated as a denial. Revoking consent asks Meta to stop processing new events and removes known _fbp and _fbc cookies where browser access allows.
• Revoking optional consent also asks Google Ads to stop new events and removes known _gcl_* cookies where browser access allows.

Authentication cookies are necessary to operate the service. The marketing site stores your selected language in browser localStorage. The application also uses localStorage for language, theme, and session coordination, and sessionStorage for temporary onboarding drafts and per-tab Student Portal context.

Before Plausible receives an event, Homeschowl removes arbitrary query parameters, fragments, fbclid, and email-like or invalid UTM values from the event URL. Valid utm_source, utm_medium, utm_campaign, utm_content, and utm_term values can remain for aggregate campaign reporting. After Meta consent, Meta can process its own browser identifiers, but Homeschowl does not persist raw fbclid, _fbp, or _fbc values as account attribution.

After consent, the Google tag sees only the public page path, valid UTM fields, and valid Google click identifiers until they are processed; Meta sees only its own valid click identifier. Arbitrary query parameters, fragments, and email-like campaign values are removed before either optional tag loads. Homeschowl does not persist raw advertising click IDs or provider cookies as account attribution.

12. International data transfers

• Service providers may process data in countries other than your own.
• Where applicable law requires transfer safeguards, we use the safeguards offered by our providers and any additional measures required for the transfer.

13. Changes to this policy

• We'll notify you of material changes by email and/or an in-app notice.
• Minor changes (clarifications) are published with an updated version date.
• When renewed acceptance is required, the app will show the updated policy and ask the parent account holder to accept it before continuing to use product features or starting a new Checkout.

14. Contact

Privacy questions and rights requests: [email protected]. We respond within the period required by applicable law and generally aim to respond within 30 days.