Terms, Privacy & DSA Policy
Version 3.2 · Compliant with GDPR, DSA (EU 2022/2065), AI Act (EU 2024/1689), Copyright Act (Art. 29 & 81), Telecommunications Act & Child Protection Standards · July 2026
🎯 1. Service mission, good faith & freedom of information
The TEƎN platform (te3n.life) is created to fulfill a public educational mission: protecting children and teenagers from digital threats (hate, emotional extortion, dangerous trends, AI scams), supporting parents and teachers, and fostering digital well-being.
🤝 Good Faith Operation (Bona Fides): All published materials, analyses, and warnings are prepared in good faith, based on expert evaluation, strictly for public interest and the safety and well-being of minors, youth, parents, and guardians.
📚 Right to Information & Education: Users have full right of access to knowledge, educational reports, and digital terminology analysis, supporting the right to information and education.
🎬 2. Educational fair use, external article summaries, video embedding & public persona
TEƎN respects intellectual property rights and public educational fair use principles:
- Fair Use & Article Synthesis (Art. 29 Copyright Act): Use of text snippets, screenshots, and creation of summaries/syntheses from external articles or research reports is conducted strictly under educational fair use (Art. 29 Copyright Act), always providing author attribution and direct source links.
- Video Embedding & Linking (CJEU C-348/13 BestWater): Embedding publicly accessible social media videos (YouTube, TikTok, Instagram, X/Twitter) and linking to external news/academic articles provides authentic context for digital safety. Under CJEU jurisprudence (Case C-348/13), embedding public content is not a new communication to the public and is fully lawful.
- Public Persona Images (Art. 81(2)(1) Copyright Act): Analyses referencing public figures or influencers are conducted strictly in relation to their public online activities and their impact on minors.
📊 3. Research reports creation, publication & sharing
The TEƎN team and collaborating experts reserve the right to compile, synthesize, and share public analytical reports:
Slang & AI Trend Reports: Reports regarding youth slang trends, dangerous online challenges, or AI voice scams may be freely quoted and shared by schools, universities, media, and public institutions with source attribution (TEƎN / te3n.life).
Data Anonymization in Reports: All analytical reports are based strictly on anonymous, aggregated metrics. No personal user data is ever exposed in published reports.
👤 4. No behavioral profiling & voluntary role selection (GDPR)
TEƎN respects user privacy and enforces strict non-invasive tracking rules:
Selecting a profile role is strictly used to adjust content safety levels and tone (LOW/MEDIUM/HIGH graduation). It is NOT commercial or behavioral tracking.
- No Commercial Profiling (Art. 28 DSA): In compliance with the Digital Services Act, we do not build behavioral user profiles, sell data to third parties, or serve targeted ads.
- Voluntary Consent (Art. 6(1)(a) GDPR): Optional newsletter subscriptions or saved settings rely on voluntary consent, which can be withdrawn anytime without affecting service access.
🍪 5. Cookies, local storage & Telecommunications Act
The service uses strictly necessary technical storage mechanisms:
- Local Storage (localStorage): Used strictly to store language preference (PL/UK/US), active profile choice, and login session token (Art. 173 Telecommunications Act).
- No Third-Party Tracking Cookies: The service does NOT place marketing pixels (e.g. Facebook Pixel, Google Ads) or third-party tracking cookies.
🛡️ 6. Illegal content notification & moderation (EU DSA 2022/2065)
- DSA Point of Contact: Reports regarding illegal content, hate speech, or copyright should be sent to: tomasz.mituta@te3n.pl [DSA]. Responses are provided promptly.
- Expert Moderation: All materials and dictionary entries are reviewed by specialists and experts for safety and compliance.
🤖 7. Artificial Intelligence (EU AI Act 2024/1689 & Privacy)
AI Transparency (Art. 50 EU AI Act): All AI-generated or AI-assisted content undergoes mandatory expert review prior to publication.
Query Privacy Protection: User inputs in educational games are NOT used to train public AI models.
🧑⚕️ 8. No medical advice & emergency helpline
1:1 consultations are provided directly by specialists and experts. TEƎN does not substitute medical diagnosis.
🏛️ 9. Data controller & your GDPR rights
Data controller is:
IT TOMASZ MITUTA
ul. Współczesna 6D lok. 74, 80-180 Borkowo Łostowickie, Poland
VAT/NIP: PL7292549876 · REGON: 221665369
E-mail: tomasz.mituta@te3n.pl
- Right to access, rectify, restrict and transfer data.
- Right to erasure ("right to be forgotten") — request to: tomasz.mituta@te3n.pl.
- Right to lodge a complaint with supervisory authority (UODO).
📱 10. TEƎN Mobile Applications (iOS & Android)
This section details the personal data processing rules for the TEƎN mobile applications available in Apple App Store and Google Play. In matters concerning the Data Controller and data subject rights, the provisions of section 9 apply. The legal basis for processing is Art. 6(1)(b) GDPR (user account) and Art. 6(1)(f) GDPR (safety report handling).
Browsing the knowledge base, youth slang lexicon, prevention materials, and sending safety reports in the mobile apps is fully functional without registration or sign-in (as a Guest).
- Account data: When signing up or logging in via Google or Apple: name, email address, and optionally profile image provided by the identity provider. When logging in via Apple, users may choose to hide their email address. Purpose: authentication and determining content access tiers.
- User-generated content (submissions): Report title and description, optional school code, and optional contact email (if user expects a response). Purpose: preventive support and incident safety triage.
Service providers (data processors): Supabase (database & authentication), Vercel (web hosting). Sign-in via Google or Apple is optional; these identity providers process data under their respective privacy policies. Supabase and Vercel are US-based companies; international data transfers are governed by EU Standard Contractual Clauses (SCC). Supabase database is hosted in the region: Central EU (Frankfurt) [eu-central-1]. All data transmission is secured via HTTPS encryption. Mobile applications contain no advertising SDKs and no commercial user behavior tracking.
Users may request permanent deletion of their account at any time: (1) directly in the mobile app: Login tab → option "Delete account and my data"; (2) on the website at: te3n.life/en/usun-konto; (3) via email: sending a request to tomasz.mituta@te3n.pl from the email address associated with the account (to verify identity).
Effects & retention: Account deletion results in immediate and permanent erasure of the auth account, email address, and profile. Previously submitted reports are retained for audit and safety compliance purposes for a period of 3 years from ticket submission, but the author email address is permanently erased (NULL). The report is no longer linked to your email address or account.