1. Introduction

LowKey is a digital productivity ecosystem offering Second Brain (a Notion template for life management) and UniversityGPT (an AI mentor chatbot). This Privacy Policy explains how your personal data is collected, processed, and protected when using LowKey’s services, in line with major privacy laws (GDPR, CCPA).

By using LowKey, you agree to this Policy. If there is any discrepancy between English and other translated versions, the English version prevails. Please also see related policies (Terms of Service, Cookie Policy) on our website.

2. Information We Collect

• Personal data: name, email, contact forms.
• Account info: registration data, login credentials (where required).
• Usage data: site interactions, logs, analytics, activity and audit logs.
• Technical data: device info, IP, browser, OS, approximate location.
• UniversityGPT inputs: prompts/questions you submit (no sensitive info should be entered).
• Payment data: All financial transactions are managed by third-party processors (e.g., Gumroad); LowKey never stores or directly handles card or bank information.

Sensitive data disclaimer: We do not seek to collect sensitive personal data (e.g., health, political opinion). Please do not submit such data via UniversityGPT or other LowKey products.

3. Legal Bases for Processing

We process your data based on one or more of the following: (a) your explicit consent, (b) performance of a contract (e.g., to deliver purchased products), (c) compliance with legal obligations, (d) legitimate interests (e.g., service improvement, security, analytics), (e) protection of vital interests or the public interest as required.

You may withdraw consent at any time via site controls or by contacting contact@lowkey.com. Withdrawal does not affect lawful processing prior to withdrawal.

4. How We Use Your Information

We use your data to operate, improve, and secure LowKey’s services; personalize user experience; respond to queries; monitor usage; and comply with legal and business needs. Aggregated/anonymized data may be used for analytics and business enhancements.

We never sell your personal data. Payment data is handled only by trusted third-party processors.

5. How We Share & Transfer Your Information

Data may be shared with third parties for hosting, analytics, support, legal compliance, payment processing (e.g., Gumroad), or if required by law.

Business transfers: If LowKey is involved in a merger, acquisition, or sale, your data may be transferred as part of the business assets, subject to this Policy.

International transfers: When data is stored or processed outside your country, contractual safeguards (such as Standard Contractual Clauses) are implemented. See our Cookie Policy for separate analytics/cookie details.

6. Data Storage & Retention

Data is stored with reputable cloud providers protected by technical and organizational safeguards (encryption, access controls, audits). We keep your data only as long as necessary, determined by business and legal requirements.

When no longer needed, data is securely deleted or anonymized according to GDPR/CCPA and best practices.

7. Your Rights—GDPR/CCPA

You have the right to:
• Access, correct, update, or request deletion of your data
• Restrict or object to processing
• Data portability
• Withdraw consent (where applicable)
• Not be discriminated against for exercising privacy rights
• Submit privacy-related complaints to a supervisory authority
To exercise these rights, please contact: contact@lowkey.com. We may require identity verification.

Complaints: If you believe your rights are violated, you can file a complaint with your data protection authority or contact us first for resolution.

8. Security Measures & Liability

We implement appropriate security (encryption, access control, service audits) to protect your data from unauthorized access, loss, or misuse. However, no internet transmission is entirely secure. LowKey’s liability is limited as permitted by law.

If any breach occurs, affected users will be notified promptly and authorities informed as required by law.

9. Cookies, Tracking, & Consent

We use cookies and similar tools (including Google Analytics) for analytics, personalization, and site performance. You can manage or withdraw cookie consent at any time via our cookie banner/tool or browser settings. See our Cookie Policy for details.

10. Children’s Privacy

LowKey does not knowingly collect data from children under 13 (or applicable local age). If such data is discovered, it will be deleted promptly. Parents can request deletion by contacting us.

Our services are not intended for minors. If you are under the applicable age, do not use LowKey services.

11. Business Transfer Clause

In the event of a business transfer (merger, acquisition, asset sale), user data may be transferred to the new entity and become subject to their policies, but safeguards and notification will be provided as required by law.

You will be notified before your data becomes subject to any new privacy policy.

12. Data Anonymization & Aggregation

LowKey may anonymize or aggregate your data for analytics, improvements, or reporting. Such data does not identify individuals and is not reversible.

These practices help us understand trends and improve the platform without affecting your privacy.

13. Consent Management & Withdrawal

Consent for processing (where applicable) is obtained via banners, forms, or explicit actions. You may withdraw consent or change preferences anytime via site controls or by contacting us.

Withdrawing consent does not affect data processing completed before withdrawal.

14. References & Related Policies

This Privacy Policy is to be read alongside our Terms of Service, Cookie Policy, and other relevant agreements. The English language Privacy Policy governs in case of legal ambiguity.

For more policy details, visit the LowKey website or contact us.

15. Language Priority

If this Policy is translated into other languages, the English version will govern in case of any conflict or ambiguity.

16. Changes & Notifications

We may update this Policy over time. Changes will be posted with revised effective dates, and significant updates will also be notified via email or banners.

Please review this Policy periodically. Your continued use after updates signifies acceptance.

17. Contact & Complaints

For any questions, rights requests, or complaints regarding this Policy or your data, contact: contact@lowkey.com. Complaint procedures and supervisory authority contact details will be provided upon request.

We strive to respond quickly and transparently to all privacy inquiries.

18. Effective Date & Copyright

Effective date: July 22, 2025. Copyright © 2025 LowKey. All rights reserved.

© 2025 Relume. All rights reserved.

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