Privacy Policy

Last updated: 17 August 2026

Short version

Secretly is a moderated community app for adult users aged 18 and over in the context of universities and colleges, fields of study, and alumni communities. You can answer questions and see content from your group.

• We store the data you provide when you use the app, such as your first name, university or college (campus), field of study, optional profile picture, and your answers.
• Your answers appear in the feed without your name or profile picture, but with your gender and field of study.
• Other users in your group do not normally see your name as the author of an answer.
• If another user has Secretly Pro, they may see “Author Hints” for individual answers. These hints can include metadata such as the time of posting, device type, operating system version, gender, field of study, and a Secretly ID. This does not directly reveal your name, but it can narrow down the group of possible authors — particularly in small fields of study.
• We review content using automated systems and additional human review when something is reported or appears suspicious.
• If content breaks our rules, we may remove it and restrict or suspend accounts.
• You can send privacy-related questions to privacy@secretly.university.

The full version below explains everything in more detail.

1. Who is responsible?

The controller for the purposes of the General Data Protection Regulation (GDPR) is:
Follow Your Instincts UG (haftungsbeschränkt)
Birkenstr. 14
67067 Ludwigshafen am Rhein
Germany
Email: support@secretly.university
Website: https://secretly.university

For privacy-related requests, you can also contact us at privacy@secretly.university.

2. What is this Privacy Policy about?

This Privacy Policy explains which personal data we process when you use the Secretly app, our website, and related services, the purposes for which we do so, the legal bases we rely on, who receives data, and what rights you have. Secretly is intended exclusively for adult users aged 18 and over.

3. What data do we process?

3.1 Data you provide directly

• first name
• gender
• university or college (campus)
• field of study (major); either selected from a predefined list or entered by you as free text
• for accounts from earlier app versions instead: school and graduation year or grade
• optional profile picture
• answers to questions
• reports about content or users
• messages to support
• information you provide in privacy or support requests

3.2 Data collected automatically when you use the app

• Secretly ID
• sign-in information via Apple or Google
• technical device data, especially device type, operating system, and app version
• usage data, for example group membership, times of answers, reports, and moderation events
• log and security data for abuse detection, troubleshooting, and system security
• IP address and network-related information where technically necessary or relevant for security

3.3 Data related to purchases and subscriptions

• information on whether you use Secretly Pro
• store-related information about purchase status, duration, and renewal
• no full credit card details; payments are processed by Apple App Store or Google Play

3.4 Moderation, safety, and complaint data

• automated assessments of answers to detect prohibited content; these assessments are performed using the AI system Google Gemini on the Google Vertex AI platform (details in Section 8)
• moderation decisions, warnings, restrictions, suspensions, and appeals
• complaint contents and internal case notes

4. What do other users see?

Your answers are generally shown in the feed without your name or profile picture.

• Members of your group can see your first name, your field of study and, if provided, your profile picture in member lists or profile views.
• Gender and field of study are typically shown alongside answers (for accounts from earlier app versions, the graduation year or grade instead). In small fields of study, this can considerably narrow the set of possible authors.
• In the regular feed, your name is not shown as the author of an answer.

4.1 Author Hints (Secretly Pro)

Secretly Pro is a paid feature. If a user in your group accesses Author Hints for a specific answer, the following additional hints may be shown for that answer:

• time of the answer
• device type
• operating system version
• gender
• field of study (for accounts from earlier app versions: graduation year or grade)
• Secretly ID
• a list of possible users with matching metadata, where our system does not assume a unique identification

Author Hints do not automatically reveal your name as the author. However, especially in small groups and small fields of study, or when combined with additional knowledge of other users, they may increase the risk that other users infer who wrote an answer.

4.2 Screenshot notifications

As part of Secretly Pro, we may show a user when another user created a screenshot of that user’s answer. In that case, the screenshot-taking user’s name and profile picture may be shown.

5. Why do we process your data?

• to create and manage your account
• to verify the age requirement and enforce the 18+ restriction where necessary
• to assign you to a campus, field of study, and group
• to provide the feed, questions, and answers
• to provide Secretly Pro, including Author Hints and screenshot notifications
• to review content, detect abuse, and enforce our community rules
• to process reports, complaints, and support requests
• to ensure IT security, troubleshoot issues, and prevent abuse
• to enforce our rights and defend against claims
• to comply with legal obligations
• to improve and further develop our services where legally permitted

6. Which legal bases do we rely on?

Where the GDPR applies, we mainly rely on the following legal bases:

• Art. 6(1)(b) GDPR: processing necessary to perform the user contract, especially account creation, group functionality, display of answers, and provision of booked features.
• Art. 6(1)(f) GDPR: processing based on our legitimate interests, especially app security, abuse detection, moderation, complaint handling, enforcement of our Terms, product improvement to the extent necessary, and defence against legal claims.
• Art. 6(1)(c) GDPR: processing necessary to comply with legal obligations, for example when responding to lawful disclosure requests or retention obligations.
• Art. 6(1)(a) GDPR: where we separately ask for consent, for example for certain optional website processing or – if actually used – non-essential tracking or storage operations.

Where information is stored on or accessed from your end device, Section 25 TDDDG may also apply. Such operations are carried out only where technically necessary or where valid consent has been obtained.

7. Sign-in with Apple or Google

You can sign in using Apple or Google. In this case, we receive the information necessary from the respective provider to authenticate you and assign your account. The exact data transmitted depends on your settings with that provider.

8. Moderation, automated review, and human review

We use automated systems, including AI-assisted content review, to check answers submitted by users for rule violations, abuse, and circumvention attempts before they are published. If a published answer is reported, it is reviewed again – even if it passed the first AI check – both by a second AI assessment and by human moderators in Germany. The same applies to reported profile names and other suspicious content.

These reviews are intended to protect users, enforce our rules, and prevent abuse. Automated systems are not perfect, so content may also be reviewed manually if there is a complaint or uncertainty.

8.1 AI technology and processors used

For AI-assisted content moderation, we use current models of the Google Gemini family, provided via the Google Vertex AI platform of

Google Cloud EMEA Limited
70 Sir John Rogerson's Quay
Dublin 2, Ireland
(hereinafter “Google”)

Inference, that is, the AI-assisted review of submitted content, takes place exclusively in data centres within the European Union (Google Cloud EU multi-region).

8.2 What data is transmitted to Google

When reviewing answers, only the following content is transmitted to Google:

• the text of the underlying question
• the text of the answer to be reviewed
• a technical moderation instruction (“system prompt”)

In this case, no user IDs, first names, email addresses, IP addresses, or other directly identifying attributes are transmitted to Google. The inputs to be reviewed are not linked to a natural person when sent to Google.

Note to users: If users name personal data of third parties (e.g., real names, university, field of study, courses, addresses) in the answer text they write, this data is also transmitted to Google. Naming personal data of third parties without their consent is prohibited under our Terms.

If a profile name is reported, the reported profile name (usually a first name) is transmitted to Google Vertex AI for review. Transmission only takes place in the event of a report; the profile name itself is not continuously transmitted to Google.

8.3 Storage, no model training

Content transmitted to Google as part of moderation is not used to train Google's AI models. This assurance follows from the Google Cloud Service Specific Terms for Vertex AI, which are part of our contractual relationship with Google.

Inputs may be cached by Google for a short period to the extent necessary for abuse detection and to ensure the service. No permanent storage of inputs at Google beyond this takes place.

8.4 Legal basis

Processing is carried out on the basis of Art. 6(1)(b) GDPR (performance of contract — content moderation is an essential component of our service and a prerequisite for publication of content in a group) and Art. 6(1)(f) GDPR (legitimate interest in protecting our users and third parties from unlawful, insulting, or abusive content).

8.5 Data processing agreement

A data processing agreement within the meaning of Art. 28 GDPR exists with Google in the form of the Google Cloud Data Processing Addendum (CDPA), available at cloud.google.com/terms/data-processing-addendum. Google processes the transmitted data exclusively in accordance with our documented instructions and not for its own purposes.

8.6 No automated decision with legal effect

AI-based moderation does not constitute an automated decision in an individual case within the meaning of Art. 22 GDPR. The only consequence of a negative review is that the relevant answer is not published and not permanently stored; the user can submit a new answer at any time.

Suspension or restriction of accounts does not take place solely based on the AI assessment, but rather within the framework of our reporting system with the option of human review.

9. Payments and subscriptions

Secretly Pro is offered as an in-app subscription via Apple App Store or Google Play. Payment processing, subscription management, and any refunds are handled by the respective store operator under its own terms. We generally do not receive full payment data from Apple or Google, but only information about purchase status and entitlement to use Secretly Pro.

10. Which service providers and recipients do we use?

We use external service providers who may process data on our behalf or, where applicable, as independent controllers to the extent necessary for operating our services.

• Google Firebase / Google Cloud for hosting, database, storage, authentication, analytics, technical infrastructure, and comparable backend services
• Google Vertex AI (Google Cloud EMEA Limited, Dublin) for AI-assisted content moderation; inference in data centres within the EU (details in Section 8)
• Apple App Store / Google Play for in-app purchases and subscription management

Firebase itself states that, unless a service offers data location selection, data may be processed or stored wherever Google or its subprocessors maintain facilities.

11. Are data transferred to third countries?

AI-assisted content moderation via Google Vertex AI (Section 8) takes place exclusively in data centres within the European Union. The content processed there is not transferred to third countries.

In connection with other service providers we use, in particular Firebase and Google Cloud services outside of Vertex AI inference, personal data may also be processed outside the European Union or the European Economic Area, especially in the United States. Where an adequate level of protection is not already recognised by law, we base such transfers on appropriate safeguards, in particular Standard Contractual Clauses, where legally required.

12. How long do we keep data?

We do not store personal data indefinitely, but only for as long as necessary for the relevant purposes. The key purposes are in particular providing our services, preventing abuse, handling complaints, defending legal claims, and complying with legal obligations. The storage-limitation principle follows from the GDPR; deletion concepts and retention periods are intended to implement this obligation in practice.

• Account data: generally until account deletion, then deletion or anonymisation, unless further retention is necessary for security or legal reasons.
• Answers: for as long as they are displayed in the product or necessary for moderation, abuse prevention, or legal defence; once removed from the feed, content may remain in a protected review or evidence area where required.
• Reports and moderation data: for as long as necessary for processing, follow-up, and abuse prevention.
• Log and security data
• Support and legal requests
• Billing and transaction data

13. Account and content deletion

You can request deletion of your account and personal data using the deletion function offered in the app or by emailing support@secretly.university. We then assess which data must be deleted and which data may or must still be retained for a limited period for legal, safety, or abuse-prevention reasons.

Retention of Answers After Account Deletion

If you delete your account, we remove your profile, your entry from member lists, and directly account-related profile data from the visible use of the app. However, answers you previously published may continue to be displayed within the app, provided that they are no longer displayed as linked to the deleted profile and that their continued availability is necessary for the operation and integrity of the service and is lawful under applicable data protection law.

Regardless of this, we assess on a case-by-case basis whether answers must additionally be removed or retained only in a restricted manner due to moderation decisions, complaints, legal obligations, or data protection deletion claims.

When content is removed from the visible product, this does not necessarily mean that all technical copies immediately disappear from every backup. Backups are overwritten on a rolling basis.

14. Cookies, SDKs, and access to end devices

Our website and app may use technically necessary technologies. Where information is stored on or accessed from end devices and this is not strictly technically necessary, we obtain consent where legally required. Section 25 TDDDG is particularly relevant here.

15. No use by minors

Secretly is intended exclusively for adult users aged 18 and over. Minors may not use Secretly. If we discover or receive justified indications that an account is used by a minor, we may restrict access, suspend or delete the account, and take any further necessary measures.

Data processing is based on the assumption that users are of legal age or have confirmed their majority during use. Where, by way of exception, data of minors is processed, for example due to false information, reports, or third-party content, we examine appropriate measures on a case-by-case basis.

The Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13 (as defined by the US Children's Online Privacy Protection Act, COPPA). If we learn that we have collected such information, we delete it.

16. Information for users in the United States

This section provides additional disclosures for users in the United States, in the style of US state privacy laws such as the California Consumer Privacy Act (CCPA/CPRA). We honor the requests described here for all US users, regardless of whether a particular state law technically applies to us.

Categories of personal information we collect (details in Section 3): identifiers (first name, Secretly ID, sign-in identifiers); characteristics (gender, if provided); education-related information (university, field of study); audio/visual information (optional profile picture); internet or other electronic network activity (device type, operating system, app version, usage and log data); and the content you submit (answers, reports, support messages). We do not collect precise geolocation, biometric information, or government identifiers.

We do not sell your personal information and we do not share it for cross-context behavioral advertising. We disclose personal information only to the service providers listed in Section 10 for the purposes described in Section 5.

Your rights: you can request access to the personal information we hold about you (right to know), request deletion, and request correction of inaccurate information. We will not discriminate against you for exercising these rights. You can exercise them via the in-app functions or by emailing privacy@secretly.university. We may need to verify your identity (for example via the email or sign-in method associated with your account) before acting on a request. An authorized agent may submit a request on your behalf with proof of authorization.

17. Your rights

Subject to the legal requirements, you have the following rights in particular:

• right of access
• right to rectification
• right to erasure
• right to restriction of processing
• right to data portability
• right to object to processing based on legitimate interests
• right to withdraw consent at any time with future effect
• right to lodge a complaint with a data protection supervisory authority

To exercise your rights, contact us at support@secretly.university or privacy@secretly.university.

18. No disclosure to third parties without legal basis

We do not disclose identity or usage data merely because third parties, universities, colleges, former institutions, student bodies, employers, parents, lecturers, or other persons request it. Disclosure only takes place where there is a valid legal basis or where we are legally required to do so.

19. Data security

We take appropriate technical and organisational measures to protect personal data against loss, misuse, unauthorised access, unauthorised disclosure, and unauthorised alteration. However, no electronic communication and no data storage can ever be completely secure.

20. Changes to this Privacy Policy

We may update this Privacy Policy if our services, our processing activities, or the legal situation change. The version published on our website applies in each case.

21. Contact

For privacy questions or to exercise your rights, contact us at privacy@secretly.university. You can also submit reports of inappropriate activity via the in-app reporting functions or by email to support@secretly.university.