Privacy policy

Last updated: 28 October 2026

This policy explains what personal data Elio collects, why, who helps us process it, how long we keep it, and the rights you have. It covers the website at eliostudy.com and the Elio app at app.eliostudy.com.

In short

• We collect what Elio needs to plan your study, teach you, and estimate where your grades stand, plus what we need to run your account and take payment.
• Your study data is stored in the European Union.
• Some features use AI to write explanations, hints and replies and to mark written answers. We send the model provider the question and what you wrote, never your name or email, and its terms do not allow it to train on it.
• We do not sell your data. We do not show ads inside Elio.
• Advertising cookies and tags run only if you accept them, and you can change your mind at any time.
• Elio is for people aged 13 and over. Under 16, a parent or guardian must give consent before a plan can start. Under 13, we refuse the account and delete it.
• You can delete your account, and everything in it, from the Account screen.

1. Who is responsible for your data

The controller of your personal data is Federico De Visdomini, an individual based in Milan, Italy (20123 Milano), who runs Elio until its company is formed ("Elio", "we", "us"). When the company is formed it becomes the controller in his place; we will update this policy and tell you before that happens.

Contact for anything about your data: support@eliostudy.com.

[LAWYER: confirm whether a Data Protection Officer is required. Elio systematically tracks study behaviour, including of minors from 13 upwards, which may count as regular and systematic monitoring (GDPR art. 37). If one is appointed, add their contact details here.]

2. What we collect, why, and on what legal basis

2.1 Setting Elio up before you have an account

You can start setting Elio up without an account. When you do, we create an anonymous session with a random identifier and store the answers you give during setup (your exam session, subjects, levels, targets, study days and times, how far your classes have got, and how confident you feel about each topic).

• Why: to build your plan and show you Elio working before you decide to create an account.
• Legal basis: steps taken at your request before entering into a contract (GDPR art. 6(1)(b)).
• Kept: if you do not create an account, the session and its answers are deleted after [N] days.

We also run a bot check (Cloudflare Turnstile) when the session starts, to stop automated abuse. Legal basis: our legitimate interest in keeping the service secure (art. 6(1)(f)).

2.2 Your account

• What: your name, email address, password (stored only as a secure hash by our authentication provider), your age confirmation or date of birth [LAWYER: choose which], and, if you are under 16, your parent or guardian's email address and the record of their consent.
• Your age range, on an Apple device. In the app we ask the device for an age band through Apple's Declared Age Range API, never for your birthdate. We store the band and nothing else. It is used for exactly two things: keeping anyone under 13 out, and knowing when to ask for a parent's consent. Deleting your account deletes it.
• Your acceptance of the terms. To create an account you accept the Terms of Service and confirm you have read this policy, by ticking a box (or turning on a switch in the app). We keep which version of the two documents you accepted and when, as the record of that agreement. If either changes in a way that matters, we ask you again before you carry on.
• Why: to create and secure your account, sign you in, and send account emails (confirming your address, resetting your password, asking for a parent's consent).
• Legal basis: performance of the contract with you (art. 6(1)(b)); for parental consent, the conditions of art. 8 GDPR.
• Kept: until you delete your account.

2.3 Your study data

• What: your exam session, subjects, levels and target grades; your study days, minutes and preferred time; how far your classes have got and how confident you feel about each topic; every answer you give, recorded with the exact version of the question and the time; your study sessions; the grade estimates Elio calculates, with their ranges; changes you make to your week; and your plan (Graphite or Brass).
• Why: this is the service. Elio uses your answers to decide what you study next, to adapt the questions, and to estimate where each grade stands. Your answers are kept as a permanent record because every estimate is recalculated from them.
• Legal basis: performance of the contract (art. 6(1)(b)).
• Kept: until you delete your account.

2.4 Conversations with Elio (Brass)

• What: the questions you ask Elio about your week and your progress, and its replies. Only your three most recent conversations are kept; older ones are deleted automatically.
• Why: so you can return to a recent conversation.
• Legal basis: performance of the contract (art. 6(1)(b)).
• Kept: your newest three conversations, until you delete your account.

2.5 Payments

In the app, Apple takes the payment. A subscription bought in the Elio app is bought from Apple and billed to your Apple Account. Your card details go to Apple and never reach us. Apple tells us, through RevenueCat, that a subscription exists: an app user identifier (which is your Elio account id), which product was bought, and the dates it starts, renews or ends. No card number, bank detail or billing address reaches us from this path.

On the web, when we offer a web checkout, payment is taken by our web payment provider. Your card details go to that provider directly and never reach us. We receive and keep your plan, billing interval, subscription status, payment dates and amounts, and the billing country. [LAWYER / OWNER: name the web payment provider here, and in section 4, once a web checkout opens. As built, nothing on the web takes a payment.]

• Why: to charge for your plan, give refunds, and meet our accounting and tax obligations.
• Legal basis: performance of the contract (art. 6(1)(b)) and legal obligations (art. 6(1)(c)).
• Kept: for as long as the law requires accounting records to be kept (in Italy, ten years), then deleted. [LAWYER: confirm period and scope.]

2.6 Visiting the website

We measure visits to the website with Cloudflare Web Analytics, which uses no cookies and stores nothing on your device. It tells us how many pages were viewed and how fast they loaded, without identifying you.

• Legal basis: our legitimate interest in understanding and improving the website (art. 6(1)(f)).

2.7 Advertising measurement, only with your consent

If you accept advertising cookies, we measure whether our ads on Instagram, Facebook, TikTok, Google and YouTube lead people to Elio. With your consent:

• On the website, the tools of Meta, TikTok and Google receive that you visited, pressed Start, and chose an exam session, together with the identifier the ad placed in the link you clicked. These tools are run through Cloudflare Zaraz.
• In the app, we tell those platforms when you start setting Elio up, create an account, or choose a plan, with the same identifier [and, for account and plan events, a hashed version of your email address that the platform uses to match the event to its own records].

At present the app sends none of these events. They are switched off until the questions below are settled; only the website's tools above run, and only with your consent.

[LAWYER: (1) confirm whether any event about a visitor or user under 18 may be sent to advertising platforms at all, and if not, how to exclude them; (2) confirm whether hashed email matching is acceptable, or remove the bracketed text; as built on 2026-09-16 NO email leaves: the server sends the event, its time, an event id, the click id the platform itself set, the browser's user agent and a one-way hash of the account id, and nothing else (apps/web/src/lib/conversions/send.ts); (3) Meta and Google act as joint controllers with us for collecting and sending these events (CJEU C-40/17, Fashion ID): add the joint-controller information required by art. 26.]

• Legal basis: your consent (art. 6(1)(a) GDPR and art. 122 of the Italian Privacy Code). You can withdraw it at any time from Cookie settings at the bottom of every page. Withdrawing does not affect what was done before.
• Kept: see the cookie policy for how long each tool keeps its identifiers.

2.8 Security and logs

Our providers record technical data (IP address, device and browser details, times of requests) to keep the service running and secure and to investigate abuse.

• Legal basis: legitimate interest in security (art. 6(1)(f)).
• Kept: [N] days, unless needed to investigate a specific incident. [LAWYER: confirm with each provider's log retention.]

2.9 Device study reminders

If you turn reminders on, we store the address your device's push service gave us (a push token or subscription address) and its public encryption material, together with your quiet hours and a requested snooze. Section "Device study reminders" at the end of this policy describes the feature in full.

• Why: to send the reminder you asked for to the device you asked for it on. It is the address, not you: it identifies a device, not a person.
• Legal basis: performance of the contract (art. 6(1)(b)); you switch the feature on and off yourself.
• Kept: while the subscription exists. Turning reminders off, connecting a different device, or deleting your account removes it, and the delivery bookkeeping is removed after 30 days.

2.10 When you contact us

If you write to us, we keep the message and our reply to answer you and, where relevant, to handle a complaint or a request about your rights. Legal basis: legitimate interest (art. 6(1)(f)) or legal obligation (art. 6(1)(c)). Kept for [N] months after the matter is closed.

2.11 The waitlist

Before Elio opens to everyone, you can join its waitlist on eliostudy.com. We collect your email address, the exam session you sit, the subjects and levels you choose to tell us, your school if you give it, whether you would pay for Elio, and that you confirmed you are 16 or over. We also record the country your connection comes from (from our hosting provider's network, never your precise location), the campaign tags in the link you arrived through, and, if a friend's link brought you, which entry referred you.

We use this to confirm your email, to show you your place in the queue, to let you in when your batch opens, and to decide which subjects to build first. We send you the confirmation email and the email that lets you in, and nothing else unless you ask. Your email is never shown to anyone else; the person whose link you used sees only a count. Legal basis: your consent (art. 6(1)(a)), which you can withdraw at any time by writing to support@eliostudy.com, and we delete your entry. We delete it ourselves 30 days after you are let in, and in any case 12 months after you joined.

The waitlist is for people aged 16 and over.

3. How Elio uses AI

Elio's plan, the order of your questions and your grade estimates are calculated by Elio's own software, which follows fixed rules.

AI (a large language model) is used for four things:

1. explaining what went wrong with an answer;
2. writing a hint when you are stuck, or a short nudge before a second try;
3. marking written answers against the question's own mark scheme. The mark becomes part of your study record and so affects your grade estimate. If the AI cannot mark an answer, you mark it yourself. [LAWYER / PRODUCT: confirm whether a student can dispute an AI mark, and describe how here.]
4. replying when you ask Elio about your week or your progress (Brass), and when you talk with Elio on its own page about anything you are studying, on the plans that include it;
5. reading a photo of a question or of your own working that you share with Elio, so it can help with it (Brass).

What is sent: the question, what you chose or wrote, the subject and topic, and for conversations the study context needed to answer (such as your subjects, schedule and progress). A school timetable you upload during setup is sent to the model once to read the periods and is not stored, logged or kept in any form; only the routine it produced is. A photo you share with Elio is sent to the model once to read its text; the photo itself is not stored, and the text it was read as is kept in that conversation. Your conversations with Elio are kept in your account until you delete them (the newest 200 are kept), are included when you download your data, and are deleted with your account. If you use your browser's microphone to dictate a question, the speech is turned into text by your browser and its maker, not by Elio; Elio receives only the words. Your name and email address are never sent.

Who receives it. Every model call goes directly to Anthropic, PBC, the model provider for every feature:

Anthropic is in the United States, and receives the prompt Elio builds and the answer or sentence you wrote, as described above. Under the terms on which we use its interface, Anthropic is not permitted to use what we send to train models. Anthropic deletes what it receives through its interface within 30 days, except where it must keep content longer to enforce its usage policy or because the law requires it.

Generated explanations and hints are stored for reuse against the question they belong to, without any link to you.

Only with your consent. Nothing is sent to a model until you agree, on the website or in the app, to a notice that names the provider above and says what is sent. You are asked the first time you use a feature that needs it. If you say no, those features stay off and everything else in Elio works. You can withdraw your consent at any time from the Account screen (AI features, Turn off), and from then on nothing more is sent.

• Legal basis: your consent (art. 6(1)(a) GDPR). Withdrawing does not affect what was sent before.

No decision that has legal effects on you, or similarly significant effects, is made solely by automated means (art. 22 GDPR). Elio's grade estimates are a study aid. They are not your IB predicted grades and not your results.

4. Who processes your data for us

We use service providers who process personal data on our behalf under data-processing agreements (art. 28 GDPR):

With your consent only (section 2.7), data is also shared with Meta Platforms Ireland Limited, [TikTok legal entity for the EEA, to confirm] and Google Ireland Limited, which may transfer it outside the EU.

Apple is not only our processor. For the purchase itself Apple is the seller and its own controller, and what it collects from you when you buy is governed by Apple's privacy policy, not by this one. [LAWYER: confirm this characterisation of Apple's role for an in-app subscription, and whether the App Store relationship needs its own paragraph.]

We may disclose data where the law requires it, or to protect our rights in a dispute.

5. Transfers outside the European Union

Some providers process data in the United States. Where they do, the transfer relies on the EU-US Data Privacy Framework for certified companies or on the European Commission's Standard Contractual Clauses (art. 45 and 46 GDPR). [LAWYER: confirm the mechanism for each provider in section 4.]

6. How long we keep data

Deleting your account (Account screen) removes your account and all of your study data, including the record of your answers, permanently. Payment records we are legally required to keep are kept separately until that obligation ends.

7. Young people

Elio is for people aged 13 and over. We do not knowingly collect anything from a child under 13: in the app, an age band below 13 is refused at the door, and if we learn that an account belongs to someone under 13 we delete it and everything in it.

If you are under 16, you can use Elio only with the consent of a parent or guardian. We ask for their email address and they confirm by following a link we send them, and no plan can start until they do. If we learn that someone under 16 is using Elio without that consent, we hold the account and, if consent does not arrive, delete it.

On an Apple device we learn your age band, not your birthdate, from the system (section 2.2). It is not proof of age, and we do not pretend it is; it is what the platform makes available, and it is used only to apply the two rules above.

We write this policy to be readable by the students who use Elio. If anything here is unclear, write to support@eliostudy.com and we will explain it.

8. Your rights

You have the right to:

• access the personal data we hold about you and receive a copy (you can download it yourself from the Account screen, under "A copy of your data");
• correct data that is wrong;
• delete your data (you can delete your whole account yourself from the Account screen);
• restrict how we use your data in certain cases;
• receive your data in a portable format (the same download, as a JSON file);
• object to processing based on our legitimate interests;
• withdraw consent at any time: from Cookie settings for cookies, and from the Account screen for the AI features.

To exercise a right, write to support@eliostudy.com. We answer within one month, extendable by two further months for complex requests, in which case we tell you why.

You also have the right to lodge a complaint with the Italian data protection authority, the Garante per la protezione dei dati personali (www.garanteprivacy.it), or with the authority in the EU country where you live or work.

9. Security

Your data is encrypted in transit. Every read of your study data is limited to your own account by the database itself, not by application code, and the records Elio writes on your behalf go through a separate, restricted path that your browser cannot use. Passwords are never stored in readable form.

10. Changes to this policy

If we change this policy in a way that matters, we will tell you by email or in the app before the change takes effect. The date at the top shows when it last changed.

[LAWYER: an Italian-language version is required if Elio is offered to consumers in Italy (Consumer Code, art. 9). State which version prevails.]

Device study reminders

If you connect a device in Account, we store its push subscription address and public encryption material, your quiet hours, a requested snooze time and the last recovery-reminder time while that subscription exists. We use your agreed study routine, local time zone and recent study activity to decide when a reminder is useful. Connecting a new device replaces the previous device. Your browser's push provider (for example Apple, Google or Mozilla) transports the notification. Notification text contains no grades, answers or profile name.

You can turn reminders off in Account or block notifications in your device settings. Turning them off in Account removes the subscription. Delivery bookkeeping is removed after 30 days by the reminder worker; it records provider acceptance, not proof that you saw a notification. Deleting your account removes its subscription and delivery bookkeeping. We do not send study reminders to a parent or guardian as part of this feature.