Imported from moonzff/Codex_up (skills/sensitive-or-specialized/privacy-policy/SKILL.md). Install upstream with npx skills add moonzff/Codex_up --skill privacy-policy. Copyright stays with the author.

--- name: privacy-policy description: "Draft a detailed privacy policy covering data types, jurisdiction, GDPR and compliance considerations, and clauses needing legal review. Use when creating a privacy policy, updating data protection documentation, or preparing for compliance."

Codex Adaptation Notes

Use the user's current request, attached files, and repository context as inputs.
Do not assume Qoder-style positional arguments; ask only if a missing input materially changes the result.
Prefer concise, high-signal outputs. Save files only when the user asks or when the project workflow clearly requires a documentation artifact.
If external or current-market information is required, use web/research tooling and cite sources.
Keep sensitive, legal, privacy, and SQL outputs bounded with explicit risk notes.

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

the provided product or system_NAME: Name of the product or service
the provided product or system_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 the provided product or system_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 [鈿狅笍 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)
[鈿狅笍 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
[鈿狅笍 LEGAL REVIEW REQUIRED] Other purposes (must be explicitly stated if you plan to use data for new purposes later)

4. Legal Basis for Processing

[鈿狅笍 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)
[鈿狅笍 LEGAL REVIEW REQUIRED] Where third parties are located (especially if outside user's jurisdiction)

6. International Data Transfer

[鈿狅笍 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
Deleted content: Y days before permanent deletion
[鈿狅笍 LEGAL REVIEW REQUIRED] Be specific, not vague; many regulations require this

8. User Rights

[鈿狅笍 LEGAL REVIEW REQUIRED] Varies by jurisdiction:

Right to access: Users can request copy of their data
Right to deletion: Users can request data be deleted ("right to be forgotten")
Right to correct: Users can update inaccurate data
Right to restrict processing: Users can limit how data is used
Right to data portability: Users can download their data
Right to opt-out: Users can unsubscribe from marketing
Right to lodge complaints: Users can contact data protection authorities
How users exercise these rights (contact info, process)

9. Cookies and Tracking

[鈿狅笍 LEGAL REVIEW REQUIRED] Detailed info:

What cookies and tracking tools are used
Why each is used (functionality, analytics, marketing)
How to manage/disable cookies
Whether explicit consent is required (GDPR requires it for non-essential cookies)

10. Security

Measures taken to protect data:

Encryption in transit and at rest
Access controls and authentication
Regular security audits
Incident response procedures
Limitations (no system is 100% secure)

11. Children's Privacy

[鈿狅笍 LEGAL REVIEW REQUIRED] If product serves users under 13:

Parental consent mechanisms
Age gates or verification
Compliance with COPPA (US), UK Children's Code, similar laws

12. Contact and Rights

How users contact you:

Privacy contact email
Mailing address
Response timeframe for requests
Data Protection Officer (if required)

13. Policy Changes

How you'll communicate changes:

Notice period (e.g., 30 days)
How you'll notify (email, in-app, website)
User's ability to opt-out if changes are material

14. Additional Provisions

No sale of data: Whether you sell/share data (if not, explicitly state)
Third-party links: You're not responsible for external sites
Governing law: Which jurisdiction's laws govern
Effective date: When policy became active

Content Guidelines

Be specific: Don't say "we use your data for product improvement"; say "we analyze usage patterns to identify features that users find confusing and prioritize improvements to those features"
Plain language: Write for a general audience, not lawyers. Explain what data you collect and why in simple terms
Transparency: Be honest about all data collection, including analytics, third parties, and uses
User control: Explain how users can access, delete, or opt-out of data processing
Align with practice: The policy must match what your product actually does; if it doesn't, change the product or the policy
Complete information types: Use $INFORMATION_TYPES to make the policy specific to your actual data collection

Output Format

Present the privacy policy in three parts:

Part 1: Summary

Quick reference:

Product name and purpose
Data types collected
Jurisdiction(s) covered
Key user rights
Retention periods
Contact information

Part 2: Full Privacy Policy Document

A complete, ready-to-publish privacy policy.

Part 3: Customization and Compliance Notes

Guidance on:

Sections marked for legal review
Jurisdiction-specific considerations (GDPR, CCPA, etc.)
Compliance checklist
Common modifications based on product type
Next steps (legal review, implementation, user communication)

Key Compliance Reminders

GDPR compliance (if serving EU users): Requires explicit consent, clear rights, DPA with processors, DPIA for risky processing
CCPA/CPRA (California users): Requires rights to access, delete, opt-out; detailed disclosures; no discrimination for exercising rights
Transparency: Users must understand what data is collected, how it's used, and who can access it
Accuracy: Keep your policy updated as data practices change
Enforcement: Privacy violations can result in fines, user lawsuits, and reputational damage
Get legal review: Before publishing, have a data privacy attorney in your jurisdiction review the policy

Before You Publish

Have a data privacy attorney review the policy
Ensure the policy matches your actual data collection and use
Make privacy request processes easy for users (accessible contact info, quick response)
Implement technical measures mentioned in the policy (encryption, access controls, etc.)
Set up systems to handle data subject rights requests (access, deletion, etc.)
Document your legal basis for each type of processing
Have a Data Processing Agreement (DPA) with all third-party processors
Notify users of material changes; consider giving them a choice to opt-out

About

﻿--- name: privacy-policy description: "Draft a detailed privacy policy covering data types, jurisdiction, GDPR and compliance considerations, and clauses needing legal review. Use when creating a privacy policy, updating data protection documentation, or preparing for compliance."