Privacy Policy for NoteIn App

Effective Date: [22 September  2026]

 

Your privacy matters to us.

At Notein, we are committed to protecting your Personal Data and ensuring transparency in how it is collected, used, and safeguarded. This Privacy Policy explains our data practices, including those related to our AI features (AI Assistant and AI OCR).

 

This Privacy Policy applies to the Notein mobile application and related services.

 

1. Our Privacy Principles

No Sale or Rental of Data

We never sell or rent your Personal Data or notebook content.

Consent-Based Data Collection

We only access or collect data from your notebooks or documents with your explicit permission. Your notebook content leaves your device only when you use a feature that needs it (AI features, OCR, or a cloud backup or sync service you choose), and we tell you before it does.

Limited, Anonymized Data for Improvement

We may use limited, anonymized data to improve app functionality and meet legal obligations.

 

2. Data We Collect

2.1 Basic Personal Data

Name, email address, and country when you register an account.

 

2.2 Anonymous Statistical Data

Crash frequency, feature usage, anonymized analytics.

 

2.3 Device Information

Device ID, IP address, device model, operating system.

 

2.4 Payment Information

Processed securely by third-party processors such as Apple, Google, or other payment partners. Notein does not store full credit card numbers or payment credentials.

 

2.5 Diagnostic Data

Collected as necessary to resolve issues and improve app performance.

 

2.6 Automatically Collected Information

Approximate location, usage patterns, and device signals collected through Firebase Analytics, Firebase Crashlytics, and Firebase Remote Config (services of Google). These collect crash logs, device model and operating system version, an anonymous installation identifier, feature-usage events, and an approximate region derived from your IP address.

 

2.7 User Files and Notes Stored Locally

Files you create or import into Notein (e.g., handwritten notes, PDFs, images, documents) are stored locally on your device.

We do not upload, view, or retain your notebooks or imported files, except in these cases that you initiate: (a) you use an AI feature (Section 2.8), (b) you use OCR (Section 2.9), or (c) you back up or sync to a cloud service you choose (Section 5.4). In each case only the content needed for that request is transmitted, as described below.

 

2.8 AI Features (AI Assistant)

Notein's AI features (summaries, outlines, quizzes and flashcards, grading, "Circle to Ask", and follow-up questions) are available to eligible members and only run when you actively use them. Before you use an AI feature for the first time, the app shows a notice describing this processing and asks you to continue.

 

What is sent. Depending on the feature: the text of the note you are working on (including text recognized from your handwriting and text boxes); the PDF you imported, or the part of it needed for your request; a screenshot of the page area you circle; and, for grading, images of the pages being graded. The app's display language is included so results come back in your language. Your name, email address, and device identifiers are not sent with this content.

 

Who processes it. This content is processed by Google LLC using its Gemini models through Google's Firebase and Google Cloud services, acting as our processor under Google's data processing terms. Google does not use your content to train its models. Processing may take place outside your country, including in the United States (see Section 9).

 

How long it is kept. Note text and page images are used only to answer your request and are not stored by us afterwards. When a PDF file has to be sent, it is temporarily held in our Google Cloud storage so that repeated requests about the same document do not need to upload it again; it is automatically deleted no later than [7] days after upload.

 

What we keep. The results (summaries, outlines, quizzes, chat history, grading reports) are stored on your device inside your notebook, not on our servers. To manage your AI allowance we record, against your account, which feature you used, when, which model was used, and the amount of text processed (token counts) — never the content itself.

 

Your choices. You can stop this processing at any time by not using AI features. To have data already processed removed, contact support@notein.cn. If you believe an AI result is wrong or inappropriate, you can report it from inside the app.

 

2.9 User-Generated Content (OCR Processing)

When you use OCR ("Recognize this page", or "AI recognition" when importing a document), images of the selected pages are transmitted to our server and to our AI model provider (Google, as described in Section 2.8) only to produce the recognized text, which is then stored on your device. [We do not keep the page images after the request completes.]

 

2.10 Transaction Information

Purchase time, subscription history, renewal and expiration data.

 

2.11 Contact Information

Email or message content you provide during support or feedback, including reports you submit about AI results.

 

2.12 Third-Party Information

Information received from analytics, payment processors, and other partners solely for app functionality or user support.

 

3. Data Controller

Orion Studio Pte. Ltd.

196 Canberra Drive 03-54, Singapore 767960

Email: support@notein.cn

 

4. Data Protection Officer (DPO)

We have appointed a Data Protection Officer responsible for overseeing compliance with privacy regulations.

DPO Contact Email: support@notein.cn

 

5. Data Sharing Policy

We share your data only under specific, lawful circumstances:

 

5.1 With Your Consent

When you explicitly authorize sharing for a specific service or feature.

 

5.2 For Legal Reasons

To comply with legal obligations, regulatory requirements, or lawful requests.

 

5.3 With Affiliates

Shared within our corporate group for legitimate, clearly defined purposes.

 

5.4 With Third-Party Service Providers

We share limited information with trusted partners that help us operate Notein—for example:

Payment services (e.g., Apple Pay, Google Pay)

Cloud or storage services (if chosen by you)

AI model provider: Google LLC (Gemini models via Firebase and Google Cloud) — processes note text, PDFs and page images only when you use an AI feature (Section 2.8); bound by data processing terms; does not train on your content

Cloud storage for AI requests: Google Cloud Storage (Firebase) — temporary storage of PDF files sent for AI processing (Section 2.8)

Analytics and crash reporting: Firebase Analytics and Firebase Crashlytics (Google)

 

We may also share aggregated, non-identifying analytics information with partners to help us improve app performance.

We do not share Personal Data for advertising purposes.

All third parties are bound by strict confidentiality and data processing agreements.

 

6. Opt-Out Rights

You may request to opt out of:

Targeted advertising

Sale of Personal Data

Profiling

(submitted via support@notein.cn)

Notein does not sell Personal Data.

You can withdraw your consent to AI processing at any time by not using AI features (see Section 2.8).

 

7. Data Retention

We retain your Personal Data only for as long as necessary to:

Operate the service

Meet legal requirements

Maintain accounting and reporting records

Content sent for AI processing is not retained after your request, except PDF files held for up to [7] days as described in Section 2.8. AI usage records (feature, time, model, token counts) are kept for as long as your account exists.

You may request deletion at any time.

 

8. User Rights

8.1 Under CCPA (California)

Right to know

Right to delete

Right to opt out

 

8.2 Under VCDPA (Virginia)

Right to access, correct, delete

Right to opt out of targeted advertising or profiling

 

8.3 General Rights

You may request information about whether your data is shared with third parties.

 

9. International Transfers of Personal Data

As a global business, Notein may process and transfer your Personal Data to countries outside of your country of residence, including locations outside the UK and the European Economic Area ("EEA"). Content you send to AI features (Section 2.8) may be processed by Google in the United States or other countries where Google operates.

 

When we transfer Personal Data internationally, we take steps to ensure that it remains protected in accordance with applicable data protection laws. These safeguards may include:

Adequacy decisions issued by data protection authorities;

The use of Standard Contractual Clauses (SCCs) approved by the European Commission;

Binding Corporate Rules (BCRs); or

Other lawful mechanisms permitted under GDPR and UK GDPR.

 

We implement appropriate contractual, technical, and organizational measures to ensure that your Personal Data continues to receive a level of protection that is essentially equivalent to that required under applicable laws.

 

10. Data Security

We prioritize the security of your Personal Data and have implemented technical and organizational measures to protect it from unauthorized access, loss, misuse, alteration, or destruction. These safeguards include:

 

10.1 Technical Measures

Encryption of Personal Data where appropriate

Secure server storage

Access control through unique credentials

Breach detection and monitoring systems

 

10.2 Organizational Measures

Confidentiality obligations for authorized staff

Access restricted to personnel with a legitimate business need

Regular review and updates of our security protocols

 

10.3 Security Principles

We take steps to prevent cyber-attacks, unauthorized access, and service disruptions.

Our processing of Personal Data adheres to the following principles:

Lawfulness, fairness, and transparency

Accuracy and timely updates

Secure and appropriate processing methods

 

10.4 Security Incidents

We maintain procedures to address data security incidents.

Where legally required, we will notify affected users and relevant data protection authorities of a data breach.

 

11. How We Use Your Personal Data

At Notein, we value your trust and are committed to using your Personal Data responsibly. We use the data collected in the following ways and for the following purposes:

 

11.1 Access and Use of Services

Your Personal Data is used to allow you to use and access the features and functionality provided by the Notein app.

 

11.2 Account Administration

We use your data to set up and administer your account, ensuring a seamless user experience.

 

11.3 Communication

We may send communications to you regarding changes to our terms or policies, modifications to our products, important notices, or other relevant updates.

 

11.4 User Feedback

Your feedback on the services is essential to us. We use this information to understand user needs and quickly provide more information about using our services.

 

11.5 Service Communication

We communicate with you to provide support, deliver information about our services, and address your inquiries.

 

11.6 Personalization

Your data allows us to tailor the information you see, ensuring that you receive content and materials most relevant to your interests.

 

11.7 Service Optimization

We use data for optimizing the Notein app and enhancing your user experience. Continuous review and improvement are vital to ensure user-friendliness.

 

11.8 Security Measures

We may process certain technical data as necessary to support the security measures described in Section 10. This includes using system and device information to help maintain service integrity, prevent misuse, and ensure the reliability and stability of our services.

 

11.9 Marketing Communications (with your consent)

If you've provided consent, we may send you marketing communications about our services, promotions, and relevant updates.

 

11.10 Technical and Support

Your data helps us provide technical and other support to ensure a smooth experience with our services.

 

11.11 Business Administration

Data is used for the management and administration of our business, including activities related to sales, reorganization, financing, or other corporate transactions.

 

11.12 Compliance

We use data to comply with applicable laws, rules, regulations, subpoenas, legal processes, governmental requests, and internal policies and procedures.

 

11.13 Database Maintenance

Your data is used for the administration and maintenance of our databases storing Personal Data.

 

11.14 Fraud and Security

We may use certain information to identify abnormal or harmful activities, to prevent fraud, and to ensure that our services function safely and as intended. This includes processing data required to detect misuse, enforce our policies, and maintain overall service integrity.

 

11.15 AI Features

To generate the summaries, outlines, quizzes, answers and grading you request, and to manage your AI allowance (Section 2.8).

 

Our usage of your Personal Data is in compliance with applicable data protection laws. We may use your data when necessary to perform contractual obligations, with your consent, to fulfill legal and regulatory obligations, to protect our legal rights, or for legitimate business interests.

 

Protecting Your Rights and Safety is Our Priority.

 

12. Information About Other Individuals

If you provide us with information on behalf of another person, you confirm that you have their consent and authority to:

 

Give consent for the processing and transfer of their Personal Data.

Receive data protection-related notices on their behalf.

 

13. Third-Party Websites

Our services may include links to third-party websites and social media features (e.g., Facebook, Twitter, YouTube, Instagram). These third-party websites may collect information about you when you interact with them. Your interactions with third-party websites and social media features are governed by their respective privacy policies, not by this privacy policy.

 

14. EU/UK Data Protection Representative (GDPR Article 27)

Orion Studio Pte. Ltd. (trading as Notein) has appointed DataRep as its Data Protection Representative for the purposes of GDPR in the EU/EEA and the UK.

If you are located in the EU/EEA or the United Kingdom and wish to contact us specifically regarding your GDPR/UK GDPR data-subject rights, you may contact our representative using the details below. Please include "Notein" in the subject line so your request can be correctly routed.

 

EU Representative

DataRep

The Cube, Monahan Road

Cork, T12 H1XY, Republic of Ireland

Email: datarequest@datarep.com

Webform: https://www.datarep.com/data-request

 

UK Representative

DataRep

107–111 Fleet Street

London, EC4A 2AB, United Kingdom

Email: datarequest@datarep.com

Webform: https://www.datarep.com/data-request

 

For all general enquiries—including product feedback, technical issues, account questions, or non-GDPR privacy matters—please contact Notein directly at:

Email: support@notein.cn

Such enquiries will not be handled by our EU/UK representative. DataRep cannot assist with product issues, refunds, account questions, or technical support.

 

15. Children's Privacy

In the United States, Notein complies with COPPA and does not knowingly collect Personal Data from children under the age of 13.

In the EU/EEA and the UK, we do not knowingly offer services directly to children under the age of 16, in accordance with GDPR requirements.

AI features, including AI chat, are not directed at children and are intended only for users who meet the age requirements above.

If you believe we have collected Personal Data from a child without proper consent, please contact us at support@notein.cn and we will promptly delete the information.

 

16. Cookies

Our website may use Cookies to improve functionality and analyze usage.

These Cookies do not collect Personal Data unless you explicitly provide it (for example, by submitting a form).

 

17. How to Delete Your Account

You can delete your Notein account from inside the app: Settings → Account → Delete account. This removes your account, your membership records and your AI usage records; notebooks stored only on your device are not affected. You can also email support@notein.cn and we will confirm the deletion for you.

 

18. Changes to this Policy

We regularly review and update our privacy policy to reflect changes in our practices and legal requirements. The last update was on [DATE OF PUBLICATION, 2026]. Significant changes will be communicated to you through notices or, when legally required, we will seek your consent. Always check the "last updated" date at the top of this policy for the most current version. We may notify you of changes by updating the date at the top of the Privacy Policy on Notein or by providing more direct notifications, such as in-app alerts.

 

19. Contact Us

If you have any privacy-related questions, concerns, or wish to exercise your data rights under applicable law, please contact us at:

📩 support@notein.cn

We will respond as promptly as possible in accordance with applicable data protection requirements.