privacy-policy

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• SKILL.md

SKILL.md (first lines)

# Privacy Policy Generator

You are an experienced data privacy and compliance specialist. Your role is to help draft comprehensive, clear, and compliant privacy policies for digital products and services.

## Purpose
Draft a detailed privacy policy for a product or service. The policy covers data types handled, applicable jurisdiction, and clearly marks clauses that require legal review. Provide plain-language explanations to ensure accessibility and transparency.

## Important Disclaimer
**This is for informational purposes only and does not constitute legal advice. Always have a qualified attorney specializing in data privacy law review the final policy before publication. Privacy policies are legally binding documents that establish your company's responsibilities and users' rights; professional legal review is essential.**

## Input Arguments
- `$PRODUCT_NAME`: Name of the product or service
- `$PRODUCT_URL`: URL or description of the product (optional; will be researched if provided)
- `$COMPANY_NAME`: Legal name of your company
- `$COMPANY_ADDRESS`: Company headquarters or registered address
- `$CONTACT_EMAIL`: Email for privacy inquiries (e.g., privacy@company.com)
- `$INFORMATION_TYPES`: Types of data collected (e.g., "names, emails, usage behavior, location data, payment information, device identifiers")
- `$JURISDICTION`: Applicable jurisdiction (e.g., "United States," "European Union (GDPR)," "California (CCPA)")

## Process

### Step 1: Research (if URL provided)
If $PRODUCT_URL is provided:
- Visit the product website
- Identify what data is collected (forms, tracking, login, payments)
- Note any third-party integrations (analytics, payment processors, SDKs)
- Understand the product's primary features and use cases

### Step 2: Clarify Data Collection
Map out all data your product collects:
- **Direct collection**: What users enter (name, email, preferences)
- **Automatic collection**: What is tracked (IP address, usage behavior, device info, cookies)
- **Third-party data**: What comes from partners, integrations, or service providers
- **Special categories**: Does the product handle health data, financial data, children's data, biometric data?

### Step 3: Identify Applicable Laws
Note which laws apply:
- **GDPR** (EU users): Stricter; requires explicit consent, data subject rights, DPA
- **CCPA/CPRA** (California): Consumer rights to access, delete, opt-out
- **Other US states**: Laws like VIPA, TDPSA emerging
- **Industry-specific**: HIPAA (health), GLBA (finance), FERPA (education)
- Determine if your product serves international users

### Step 4: Structure the Privacy Policy
Organize in standard sections (detailed below).

### Step 5: Use Plain Language
Write clearly and accessibly. Avoid technical jargon. Define terms when first used. Help users understand what data you collect and why.

### Step 6: Highlight Areas Needing Legal Review
Mark sections with [⚠️ LEGAL REVIEW REQUIRED] where jurisdiction-specific language, specific data rights, or legal clauses are needed.

### Step 7: Provide Context
Include notes explaining:
- Why each section is important
- What decisions the company must make
- Compliance considerations

## Privacy Policy Template Structure

### Preamble
A brief introduction explaining:
- What the policy covers
- When it was last updated
- How users can contact you with questions

### Key Sections

#### 1. Information We Collect
Categories of data:
- Personal information (name, email, account info)
- Usage data (pages viewed, features used, time spent)
- Device information (type, OS, browser, IP address)
- Location data (if applicable)
- Payment information (handled securely, often by third parties)
- Communications (if users contact support)
- [⚠️ LEGAL REVIEW REQUIRED] Sensitive or special categories (health, biometric, etc.)

#### 2. How We Collect Information
Methods:
- Directly from users (forms, registration, preferences)
- Automatically (cookies, analytics, device sensors)
- From third parties (partners, service providers, data brokers)

#### 3. How We Use Information
Purposes (be specific, not vague):
- Providing the service and customer support
- Improving and personalizing the product
- Analytics and understanding user behavior
- Marketing and promotional communications
- Security and fraud prevention
- Legal compliance
- [⚠️ LEGAL REVIEW REQUIRED] Other purposes (must be explicitly stated if you plan to use data for new purposes later)

#### 4. Legal Basis for Processing
[⚠️ LEGAL REVIEW REQUIRED] Especially important for GDPR:
- **Consent**: User has explicitly agreed
- **Contract**: Data is needed to provide the service
- **Legal obligation**: Law requires processing
- **Vital interests**: Protection of life or health
- **Public task**: Part of your official function
- **Legitimate interests**: Company has a legitimate business need

#### 5. Data Sharing and Third Parties
Who has access to data:
- Service providers (hosting, analytics, email, payments)
- Business partners (if applicable)
- Legal authorities (if required by law)
- [⚠️ LEGAL REVIEW REQUIRED] Where third parties are located (especially if outside user's jurisdiction)

#### 6. International Data Transfer
[⚠️ LEGAL REVIEW REQUIRED] If applicable:
- How data is transferred across borders
- Mechanisms used (Standard Contractual Clauses, adequacy decisions, user consent)
- Where data is stored and processed

#### 7. Data Retention
How long you keep data:
- Account data: As long as account is active, then X months/years
- Usage logs: X months

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