Privacy Policy
GDPR-based draft — to be reviewed. Last updated: [TO COMPLETE].
1. Controller
[TO COMPLETE: company, address]. Contact: [email protected]. DPO (if appointed): [TO COMPLETE].
2. Data, purposes, legal bases, retention
| Data | Purpose | Legal basis (GDPR art. 6) | Retention |
|---|---|---|---|
| Apple/Google/X identifier, name, handle, email (if provided), profile photo | Create and run your account | Contract | Life of the account |
| Age confirmation (18+) | Enforce the minimum age | Legal obligation / legitimate interest | Life of the account |
| Journal (picks, virtual-unit stakes), favourites, preferences | Provide the service | Contract | Life of the account |
| Messages, images, reports, moderation decisions, sanctions | Community, moderation, safety | Legitimate interest; DSA | 12 months after the decision |
| Subscription status (via RevenueCat / Apple / Google) | Manage Pro | Contract | Subscription + accounting obligations |
| Push token | Send the alerts you turned on | Consent | Until withdrawn |
| Voice (dictated questions) | Transcribe your question | Consent (microphone permission) | Speech recognition is done by the operating system's service (Apple or Google); audio is never sent to Edgium, only the transcribed text |
| Questions asked to Edge AI | Answer them | Consent (asked in the App) | Not kept beyond the answer (technical logs 30 days) |
| Technical data (truncated IP, device type, error logs) | Security, debugging | Legitimate interest | 30 days |
We do not sell your data. We do no targeted advertising and no cross-app tracking.
3. Automated decisions (GDPR art. 22)
Moderation is performed automatically by Edge AI. A post can be refused and a sanction applied without immediate human involvement. You can request a review (the "Appeal" button), give your point of view and contest the decision. Human review is available on request at [email protected].
4. Recipients and processors
- Hosting: [TO COMPLETE].
- AI analysis for Edge AI (moderation, explanations): an AI provider acting as a processor, [TO COMPLETE: name, country]. Questions asked to Edge AI are only sent to it after your explicit consent, requested in the App before your first question (without it, Edge AI answers with the on-device engine). No name, email or account ID is attached. Content is sent only to produce the answer. Under the contract, it is not used to train the provider's models.
- Subscriptions: RevenueCat Inc. (US), Apple, Google.
- Notifications: Expo (650 Industries, US), Apple Push Notification service.
- Sign-in: Apple, Google, X (your choice).
Transfers outside the EU rely on the EU–US Data Privacy Framework and/or the European Commission's Standard Contractual Clauses.
5. Your rights
You have the rights of access, rectification, erasure, restriction, objection and portability, and you can withdraw consent at any time.
- In the App: Settings → Account → Export my data / Delete my account.
- By email: [email protected]. We reply within one month.
- You can complain to your data-protection authority (in France: CNIL, www.cnil.fr).
- California residents: we do not sell or share personal information as defined by the CCPA/CPRA.
6. Security
Encrypted connections (HTTPS), session tokens stored hashed, service keys kept on our servers only, restricted access.
7. Minors
The App is not available to anyone under 18. If we learn that a minor has created an account, we delete it.
8. Changes
You will be told about material changes in the App.