privacy-policy-drafting

# Privacy Policy Drafting

Draft legally informed privacy-policy language that addresses potentially applicable privacy frameworks and exposes unresolved business inputs. Treat the result as a working draft and review checklist, not proof of compliance. Verify current law, regulator guidance, product behavior, and jurisdiction with qualified counsel before publication.

## Workflow

1. **Gather Business Information** — Collect details about the business entity (name, jurisdiction, contact info), the product or service offered, target user demographics, and geographic reach. Determine which regulations apply based on where users are located, not just where the business is incorporated. A US-based SaaS serving EU customers must address GDPR.

2. **Identify Data Collection Practices** — Map every category of personal data collected: direct inputs (forms, account creation), automatic collection (cookies, analytics, device info, IP addresses), third-party sources (OAuth providers, data brokers), and derived data (usage patterns, preferences). For each category, document the collection method, storage location, retention period, and whether it includes sensitive/special category data.

3. **Map Legal Requirements** — Cross-reference collected data types against applicable frameworks. GDPR requires lawful basis for each processing activity, CCPA requires disclosure of sale/sharing practices and opt-out mechanisms, COPPA applies if users under 13 may access the service, and sector-specific rules (HIPAA, FERPA, GLBA) may layer additional requirements. Identify all required policy sections.

4. **Draft Policy Sections** — Generate each section with plain-language explanations alongside legally precise disclosures. Required sections include: data collected and purposes, legal basis for processing (GDPR), data sharing and third parties, cookies and tracking technologies, data retention, user rights and how to exercise them, international data transfers, children's privacy, security measures, and policy change notification procedures.

5. **Review for Compliance Gaps** — Audit the draft against a regulatory checklist. Verify that every data processing activity has a stated legal basis, all required rights are enumerated, contact information for DPO or privacy inquiries is included, cookie consent mechanisms are described, and data breach notification procedures are referenced. Flag any gaps or areas needing business input.

## Usage

Describe your business, what data you collect, and which jurisdictions your users are in. Include technical details about cookies, analytics tools, and third-party integrations.

**Example prompt:**
```
Draft a privacy policy for my SaaS app "TaskFlow" — a project management tool. We collect email, name, and usage analytics via Mixpanel. Users are in the US and EU. We use Stripe for payments and Google OAuth for login.
```

## Examples

### Example 1: SaaS App with Email and Usage Data

**Input:** TaskFlow, a project management SaaS. Collects email, name, profile photo, usage analytics (Mixpanel), payment info (Stripe), Google OAuth login. Users in US and EU.

**Output (key sections):**

**Information We Collect**

*Information you provide:* When you create an account, we collect your name, email address, and profile photo (if provided via Google OAuth). When you subscribe to a paid plan, our payment processor Stripe collects your payment card details — we do not store full card numbers on our servers.

*Information collected automatically:* We collect usage data including features accessed, session duration, and interaction patterns through Mixpanel. We collect device information (browser type, operating system, screen resolution), IP address, and approximate location derived from IP. We use cookies and similar technologies as described in our Cookie Policy section below.

*Information from third parties:* If you sign in via Google OAuth, we receive your name, email, and profile photo from Google per your Google account settings.

**Legal Basis for Processing (EEA/UK Users)**

| Processing Activity | Legal Basis |
|---------------------|-------------|
| Account creation and service delivery | Performance of contract |
| Payment processing | Performance of contract |
| Usage analytics for product improvement | Legitimate interest (improving service quality) |
| Email notifications about your account | Performance of contract |
| Marketing communications | Consent (opt-in) |

**Your Rights**

Under GDPR (EEA/UK users): access, rectification, erasure, restriction, portability, objection, and withdrawal of consent. Under CCPA (California residents): right to know, right to delete, right to opt-out of sale (we do not sell personal information), and right to non-discrimination.

### Example 2: Mobile App with Location Tracking

**Input:** FitRoute, a fitness tracking mobile app. Collects GPS location (continuous during workouts), health data (heart rate from wearables), email, age, weight. Users are global.

**Output (additional sections):**

**Location Data**

FitRoute collects precise GPS location data during active workout sessions to map your route and calculate distance. Location tracking begins only when you start a workout and stops when you end it. We do not track your location in the background. You can revoke location permissions at any time through your device settings, though this will prevent route mapping features from functioning.

**Health and Sensitive Data**

We collect health-related data including heart rate (synced from connected wearables), workout duration, calories burned, and body metrics you voluntarily provide (age, weight, height). Under GDPR, health data is a special category requiring explicit consent — we obtain this consent during onboarding. Under California law, this constitutes sensitive personal information subject to additional protections. This data is encrypted at rest using AES-256 and in transit using TLS 1.3.

**Consent Requirements*