Privacy Policy
CapXHolding ("we", "us", "our"), represented by Maximilian Carl Friede, is the data controller responsible for the Aiffinity mobile application and all related services (collectively, the "Service"). This Privacy Policy explains what personal data we collect, why we collect it, how we process it, and what rights you have in relation to your data.
We are committed to protecting your privacy and complying with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the ePrivacy Directive 2002/58/EC, and all applicable data protection legislation.
By using the Service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our data practices, please do not use the Service.
The canonical export and delete-account flows live inside Aiffinity. If the app is installed, these links open the in-app screens directly.
Information We Collect
What personal data we gather and how.
How We Use Your Data
Purposes for processing and lawful basis.
AI IP & Portability
How your AI IP personalization data is stored and exported.
Storage & Security
Encryption, retention, and sub-processors.
Your Rights
Access, rectification, erasure, and portability.
Contact Us
Data controller, DPO, and how to reach us.
1. Data Controller
The data controller for your personal data is:
- Entity: CapXHolding
- Represented by: Maximilian Carl Friede
- Email: [email protected]
- Website: aiffinity.me
1a. Data Protection Officer
We have designated a Data Protection Officer (DPO) who can be contacted for any questions regarding the processing of your personal data or the exercise of your rights:
- DPO: Maximilian Carl Friede
- Email: [email protected]
2. Information We Collect
2.1 Information You Provide Directly
- Account Information: Name, phone number, email address, date of birth, profile photo, and other details you provide during registration or profile setup.
- Messages and Content: Text messages, voice messages, media files, and other content you create or share through the Service. All user-to-user messages are protected by end-to-end encryption — we cannot access the plaintext content of these messages.
- AI IP Data: Personalization data and preferences used to tailor the Service to you. This may be created from how you use the Service and from features you choose to enable. This data is owned by you.
- Contact Information: Names and identifiers of people you add as contacts within the Service.
- Agent Instructions: Requests, prompts, and instructions you give to AI agents acting on your behalf.
- Support Communications: Information you provide when contacting us for customer support, including the content of your messages and any attachments.
- Payment Information: When you make in-app purchases through Apple (App Store) or Google (Play Store), we receive your subscription status and transaction identifiers. For payments made outside the app stores — including web subscriptions, marketplace purchases, and creator payouts — payment is processed by Stripe. Stripe collects and tokenises your card or bank details; we receive only transaction identifiers, limited billing metadata (such as card brand and the last four digits), and subscription status, and we never store your full card number.
- Creator Identity & Payout Information (optional): If you choose to register as a creator or developer to receive payouts, our payment processor Stripe collects identity-verification information on our behalf — including a government-issued identity document and a verification selfie (Stripe Identity, used for KYC / anti-money-laundering checks) and, for business accounts, company and bank-account details (Stripe Connect). This is collected only if you opt into monetization and is not collected from users who do not.
- Location Data: If you choose to use location features (such as sharing your location or viewing location cards), we collect your location data. Location sharing is always opt-in and can be disabled at any time.
-
Waitlist Information: If you sign up for our waitlist prior to account creation:
- Required at signup: email address.
- Optional via the post-signup popup (skippable; you can fill any subset): name, phone number, public social-media profile URLs (X / Twitter, YouTube, Instagram, TikTok), an academic email address, a work email address, GitHub profile URL, free-text descriptions of club or association affiliations (e.g. Soho House, Young Presidents' Organization), and the first six digits (Bank Identification Number, "BIN") of a premium payment card.
- Auto-derived from the above: a canonical university identifier (only if your signup or academic email matches a whitelisted institution), a canonical employer identifier (only if your verified work email matches a whitelisted company), and an auto-detected premium-card type (resolved from the disclosed BIN against a curated lookup table).
2.2 Information Collected Automatically
- Device Information: Device model, operating system and version, unique device identifiers (e.g. IDFV), screen resolution, and mobile network information.
- Usage Data: Features accessed, session duration, timestamps, and in-app navigation paths.
- Log Data: IP address, browser or app version, referring URL, access times, and error/crash reports.
- Performance Data: App launch time, frame rates, memory usage, and network latency — used exclusively for performance optimisation and stability monitoring.
2.3 Information We Do Not Collect
- We do not access your device contacts (address book), photo library, or other on-device data unless you explicitly grant permission for a specific feature.
- We do not collect location data unless you explicitly enable location features. Last known location is retained for a maximum of 72 hours; location history retention is user-configurable.
- We do not store your full payment card number or bank-account credentials on our own systems — card and bank details are collected and processed directly by our payment processors (Apple, Google, and Stripe), which return only tokens, transaction identifiers, and limited billing metadata to us.
- We do not use tracking technologies for advertising purposes.
3. Lawful Basis for Processing
Under Article 6 of the GDPR, we process your personal data on the following legal bases:
| Purpose | Lawful Basis |
|---|---|
| Providing and maintaining the Service, including your account and AI IP | Performance of contract (Art. 6(1)(b)) |
| Processing messages and enabling communication features | Performance of contract (Art. 6(1)(b)) |
| Executing AI agent actions you request | Performance of contract (Art. 6(1)(b)) |
| Sending service-related communications (e.g. security alerts, updates) | Legitimate interest (Art. 6(1)(f)) |
| Error tracking, crash reporting, and performance monitoring | Legitimate interest (Art. 6(1)(f)) |
| Improving and developing new features based on aggregate usage patterns | Legitimate interest (Art. 6(1)(f)) |
| Fraud prevention and abuse detection | Legitimate interest (Art. 6(1)(f)) |
| Compliance with legal obligations | Legal obligation (Art. 6(1)(c)) |
| Processing location data for location-sharing features | Explicit consent (Art. 6(1)(a)) |
| Processing payment and subscription data | Performance of contract (Art. 6(1)(b)) / Legal obligation (Art. 6(1)(c)) |
| Verifying the identity of creators/developers who opt into payouts (KYC / anti-money-laundering) | Legal obligation (Art. 6(1)(c)) and performance of contract (Art. 6(1)(b)); identity documents are processed by our payment processor under Art. 9(2)(g) where applicable |
| Using external AI providers to generate AI replies and power AI features (opt-in in the EU/EEA; on by default elsewhere and can be disabled in Settings) | Explicit consent (Art. 6(1)(a), and Art. 9(2)(a) where special-category data is involved) in the EU/EEA; performance of contract (Art. 6(1)(b)) elsewhere. International transfers safeguarded by Standard Contractual Clauses. |
| Sharing your AI IP with third-party services you authorise | Explicit consent (Art. 6(1)(a)) |
| Marketing communications (if applicable) | Explicit consent (Art. 6(1)(a)) |
Where we rely on legitimate interest, we have conducted a balancing test to ensure our interests do not override your fundamental rights and freedoms. You may contact us to request details of these assessments.
4. How We Use Your Information
We use the personal data we collect to:
- Provide, operate, and maintain the Aiffinity Service
- Authenticate your identity and secure your account
- Power your AI companion (Aiven) and personalise your experience
- Provide and maintain your AI IP and personalization features
- Execute AI agent actions on your behalf (e.g. drafting emails, managing schedules, making reservations)
- Enable messaging, voice calls, and video calls between users
- Send you service-related communications such as security alerts, feature updates, and account notifications
- Monitor Service performance, diagnose errors, and resolve technical issues
- Detect, investigate, and prevent fraud, abuse, and violations of our Terms of Service
- Comply with applicable legal obligations, regulatory requirements, and law enforcement requests
- Improve the Service based on aggregated, non-identifiable usage data
5. AI IP and Data Portability
Your AI IP is your data. You retain full ownership of all AI IP data at all times. You may:
- View your AI IP data at any time within the app under Settings > AI IP.
- Export your AI IP in a structured, machine-readable format (JSON) for use with other services.
- Share your AI IP with third-party applications and services you explicitly authorise. When you do so, the receiving service is governed by its own privacy policy — we recommend reviewing it before sharing.
- Delete your AI IP entirely, permanently removing all AI IP personalization and preference data from our systems. Deletion is irreversible.
6. Data Storage, Security, and Retention
6.1 Infrastructure and Storage
All data is stored within the European Union. We use Amazon Web Services (AWS) as our cloud infrastructure provider. No personal data is stored outside the EU unless explicitly stated in this policy.
6.2 Security Measures
We implement industry-standard and state-of-the-art security measures, including:
- End-to-end encryption (E2EE) for all user-to-user messages — we cannot read or access the plaintext content of your messages at any point.
- Encryption at rest using AES-256 for all stored data.
- Encryption in transit using TLS 1.2 or higher for all network communications.
- PII encryption with dedicated per-field encryption keys managed through AWS Key Management Service (KMS).
- Access controls based on the principle of least privilege across all internal systems.
- Regular security assessments and infrastructure monitoring.
While we take extensive measures to protect your data, no system is completely immune to security threats. We encourage you to protect your account credentials and report any suspected security issues to [email protected].
6.3 Data Retention
| Data Category | Retention Period |
|---|---|
| Account information | Duration of account plus 30 days after deletion |
| AI IP data | Until you delete it or delete your account |
| End-to-end encrypted messages | Until deleted by participants; server-side ciphertext purged 90 days after account deletion |
| Agent action logs | 90 days |
| Usage and analytics data | 12 months (aggregated and anonymised thereafter) |
| Location data (last known) | 72 hours |
| Location history | User-configurable; deleted when you disable location features |
| Payment and subscription data | 7 years (legal/tax obligation) |
| AI IP personalization data | 90 days |
| Error and crash reports | 90 days |
| Waitlist information | Up to 365 days after account creation or last activity, or until you request deletion |
| Support communications | 24 months after resolution |
When a retention period expires, we delete or irreversibly anonymise the data within 30 days. Certain data may be retained longer where required by law (e.g. tax or accounting obligations).
7. Third-Party Services and Sub-Processors
We use the following third-party services to operate and improve the Service. Each operates under a data processing agreement (DPA) with us:
| Service | Purpose | Data Region |
|---|---|---|
| Amazon Web Services (AWS) | Cloud infrastructure, data storage, encryption key management | EU |
| Firebase Authentication (Google) | User authentication and identity management | EU |
| Stripe | Payment processing and subscription billing; for creators/developers who opt into payouts, identity verification (KYC) and payout management | US / EU (with SCCs) |
| PostHog | Product analytics (anonymised usage patterns) | EU |
| Sentry | Error tracking and crash reporting | EU |
| OpenAI / Anthropic | External AI response generation (only when you enable "External AI processing" in Settings) | US (with SCCs) |
| LiveKit | Voice and video call infrastructure | EU |
| Google Maps Platform | Map rendering and geocoding for location features | Global |
| Apple Push Notification service (APNs) / Google FCM | Push notifications delivery | Per provider policy |
| Cloudflare | Content delivery, DNS, and DDoS protection | Global (edge nodes) |
| Google Cloud Translation | Message translation and language detection (transient) | US (with SCCs) |
| Expo (EAS) | Mobile app build service and over-the-air updates | US (with SCCs) |
| Optional messaging & data integrations (Telegram, WhatsApp, Discord, Bluesky, Viber, Threema, Gmail / Google Workspace, and other connectors you authorise) | Bridging or enriching your data — only if you explicitly connect these platforms | Per provider policy |
We maintain an up-to-date list of sub-processors on this page. When we add a new sub-processor that processes personal data, we update this list. Material changes to sub-processors are communicated through our Privacy Policy change notification process (see Section 15).
8. International Data Transfers
Your personal data is primarily stored and processed within the European Economic Area (EEA). Where data must be transferred outside the EEA (for example, through Cloudflare's global content delivery network, payment and identity verification via Stripe, or optional external AI providers), we ensure adequate safeguards are in place, including:
- European Commission adequacy decisions (where applicable)
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Supplementary technical measures such as encryption
You may request a copy of the relevant transfer safeguards by contacting [email protected].
9. Data Sharing
We do not sell, rent, or trade your personal data. We do not share your data with third parties for advertising purposes. We may share personal data only in the following circumstances:
- With your explicit consent — for example, when you export or share your AI IP with a third-party service.
- With service providers (sub-processors) — who assist in operating the Service, under strict data processing agreements that limit their use of your data to performing services on our behalf.
- For legal compliance — to comply with applicable laws, regulations, legal proceedings, or enforceable government requests.
- To protect rights and safety — to enforce our Terms of Service, protect the security and integrity of the Service, and protect the rights, property, or safety of CapXHolding, our users, or others.
- In connection with a business transfer — if CapXHolding is involved in a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction. We will notify you before your data becomes subject to a different privacy policy.
10. Automated Decision-Making and Profiling
The Service uses automated systems to personalize features and maintain your AI IP. This may include profiling under GDPR and is essential to the Service based on our contractual relationship with you (Art. 22(2)(a) GDPR).
Automated processing is used to:
- Maintain your AI IP and personalization features
- Personalise AI companion (Aiven) responses
- Suggest relevant actions, replies, and follow-ups
These processes do not produce legal effects or similarly significant effects on you. No automated decisions are made regarding access to the Service, account status, or any matter with legal consequences. You have the right to request human review of any automated processing by contacting us.
11. Your Rights Under GDPR
Under the GDPR and applicable data protection legislation, you have the following rights:
- Right of access (Art. 15) — Request a copy of the personal data we hold about you.
- Right to rectification (Art. 16) — Request correction of inaccurate or incomplete personal data.
- Right to erasure (Art. 17) — Request deletion of your personal data ("right to be forgotten"), subject to legal retention obligations.
- Right to restriction of processing (Art. 18) — Request that we limit the processing of your data in certain circumstances.
- Right to data portability (Art. 20) — Receive your data in a structured, commonly used, and machine-readable format (JSON), and transmit it to another controller. The AI IP export feature directly supports this right.
- Right to object (Art. 21) — Object to processing based on legitimate interests, including profiling. Where you object, we will cease processing unless we demonstrate compelling legitimate grounds.
- Right to withdraw consent (Art. 7(3)) — Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
- Right not to be subject to automated decision-making (Art. 22) — Request human intervention in any automated decision that significantly affects you.
- Right to lodge a complaint — You have the right to lodge a complaint with your local data protection supervisory authority.
To exercise any of these rights, contact us at [email protected]. We will respond within 30 days. In complex cases, we may extend the response period by an additional 60 days, and we will inform you of the extension and the reasons for it.
12. Your Rights Under U.S. State Privacy Laws
If you are a resident of California, Virginia, Colorado, Connecticut, Utah, or another U.S. state with comprehensive privacy legislation, you may have additional rights under applicable law, including the California Consumer Privacy Act (CCPA) as amended by the CPRA, the Virginia Consumer Data Protection Act (VCDPA), and similar state statutes.
Your Rights
Depending on your state of residence, you may have the right to:
- Know & Access — Request disclosure of the categories and specific pieces of personal information we have collected about you.
- Delete — Request deletion of your personal information, subject to certain legal exceptions.
- Correct — Request correction of inaccurate personal information.
- Portability — Receive your personal information in a portable, machine-readable format.
- Opt out of sale or sharing — Direct us not to sell or share your personal information for cross-context behavioral advertising. Aiffinity does not sell your personal information and does not share it for cross-context behavioral advertising.
- Non-discrimination — Exercise your privacy rights without receiving discriminatory treatment.
How We Use Personal Information (CCPA Categories)
We collect the following categories of personal information as described in Section 2 of this policy: identifiers (name, email, phone number), commercial information (subscription and transaction data), internet activity (app usage analytics when opted in), and inferences (AI-generated personality insights). Most users do not provide sensitive personal information. If you opt into creator monetization, our payment processor collects government-identification information on our behalf for identity verification (KYC); we use it solely for that purpose and do not sell or share it. We use personal information for the business purposes described in Section 4 (providing and improving the Service).
Exercising Your Rights
To exercise any of these rights, contact us at [email protected] or use the in-app data controls under Profile > Data Export and Profile > Delete Account. We will verify your identity before processing your request. You may also designate an authorized agent to make a request on your behalf.
We will respond to verifiable consumer requests within 45 days. If we need additional time, we will notify you of the extension and the reason.
13. Cookies, Tracking, and Analytics Consent
The Aiffinity mobile application does not use cookies. Our documentation website (docs.aiffinity.me) and marketing website (aiffinity.me) do not use cookies or third-party tracking technologies.
We use PostHog for anonymised product analytics within the app. This does not involve cross-site tracking, advertising identifiers, or cookie-based tracking. You can control analytics and personalisation via Settings > Analytics & Personalization in the app:
- Product Analytics — share anonymous usage data to help improve Aiffinity. Default: off in EU/EEA (opt-in required under GDPR).
- Personalisation — allow Aiven to personalize eligible features for you. Default: off in EU/EEA (opt-in required under GDPR).
- External AI Processing — allow eligible AI features that rely on external model providers. Default: on, except in the EU/EEA where it is off until you opt in (explicit consent required under GDPR). You can change this at any time in Settings.
When you opt out, analytics tracking ceases at both the client and server level. No events are collected or stored after you disable these settings.
14. Children's Privacy
Aiffinity is intended exclusively for users aged 18 and older. We do not knowingly collect personal data from anyone under the age of 18. If we become aware that we have inadvertently collected data from a person under 18, we will take immediate steps to delete that data and terminate the associated account. If you believe a minor has provided us with personal data, please contact us at [email protected].
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:
- Update the "Last updated" date at the top of this page
- Notify you by email or in-app notification at least 30 days before the changes take effect
- Where required by law, request your renewed consent before applying changes
Your continued use of the Service after the effective date of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the changes, you should stop using the Service and delete your account.
16. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, contact us at:
- Email: [email protected]
- General inquiries: [email protected]
- Security issues: [email protected]
- Website: aiffinity.me
CapXHolding
If you are not satisfied with our response, you have the right to lodge a complaint with:
- In the EU: The data protection supervisory authority in the EU member state of your habitual residence, place of work, or where the alleged infringement occurred.