Privacy Policy

1. Controller

Foldy UG (Haftungsbeschränkt)

Hünefeldzeile 12a, 12247 Berlin, Germany

Email: [email protected]

Represented by: Mariia Tarbaieva

2. Data Processing

All data entered by users is stored locally on the device. Foldy does not operate servers that receive or store your documents, and the app does not include analytics or tracking SDKs as of today. If you enable and use AI features, relevant content may be transmitted to our external AI provider (Anthropic / Claude) for the purpose of generating the AI output you requested.

What We Process

• On-device content: documents you add to the app and the outputs the app generates (stored locally on your device)
• AI processing data: the content you submit for an AI feature (for example, text from a document) and necessary request metadata, transmitted only when AI features are enabled and used
• Support/feedback data (if you contact us): your email address and the information you include in your message

No Tracking / Analytics

The app does not use tracking technologies or third-party analytics SDKs as of today. We do not collect advertising identifiers (such as IDFA) or build profiles of your app usage.

Use of Anthropic (Claude)

We use Anthropic (Claude) to process and summarize the documents you upload when AI features are enabled and used.

• Your documents are protected during transfer and processing, and Anthropic applies privacy and security controls to protect data it processes.
• The information you send is used only to generate the summary or result produced by the AI feature.
• We do not use your documents to train our own models.
• We use appropriate contractual and technical safeguards to support GDPR-compliant processing, including safeguards for international transfers where applicable.
• Foldy does not store the documents you upload for AI processing on its own servers as part of providing the AI output. Anthropic’s retention (if any) depends on the provider’s service configuration and terms.

Data Minimization and Redaction

Where possible, we minimize the amount of data sent for AI processing and may attempt to redact sensitive information before transmission.

Redaction helps reduce exposure of sensitive data, but it may not catch everything. As a result, the transmitted content may still contain personal data.

No Disclosure

We do not share personal data with third parties, except when required to provide app functionality (e.g., Anthropic for AI processing) or by law.

Legal Basis

AI features: your consent (Art. 6(1)(a) GDPR). You may withdraw consent at any time (Art. 7 GDPR) by disabling AI features in the app and by not using AI features.

Support/feedback communications: depending on the context, processing may be based on your consent (Art. 6(1)(a) GDPR) and/or our legitimate interest in responding to your requests (Art. 6(1)(f) GDPR).

Rights of Testers

You have the right to access, rectify, delete, restrict, and port your data, and to withdraw consent at any time (Arts. 15–20 GDPR).

If processing is based on our legitimate interests, you also have the right to object (Art. 21 GDPR).

Liability

As this is a beta version, errors and interruptions may occur. We are not liable for damages, data loss, or malfunctions. Use of the beta is at your own risk.

3. International Transfers

If you use AI features, content may be processed by Anthropic in countries outside the European Economic Area (EEA), depending on the service configuration and infrastructure. Where required, we rely on appropriate safeguards (for example, Standard Contractual Clauses) and additional technical and organizational measures to protect data transfers.

4. TestFlight Data

Apple automatically collects device information, OS version, crash reports, and app version details. Apple acts as an independent controller for this data. For details, see Apple's Privacy Policy:

https://www.apple.com/legal/privacy/

5. Data Recipients

Data is shared only with service providers necessary to operate the app (e.g., Apple for TestFlight distribution and crash reporting, and Anthropic for AI processing when you use AI features) and under GDPR-compliant agreements where applicable.

• We do not sell or rent personal data.
• Disclosure to authorities occurs only when required by law.

6. Data Retention

On-device content: retained on your device until you delete it in the app or uninstall the app.

AI processing content: Foldy does not store the content you submit to AI features on its own servers as part of providing the AI output. Anthropic’s retention (if any) depends on the provider’s service configuration and terms.

Support/feedback communications: retained only as long as needed to respond to you and to document beta feedback, and then deleted or anonymized where feasible.

TestFlight crash reports: handled by Apple as an independent controller; retention is governed by Apple’s policies.

7. Your Rights Under GDPR and BDSG

You have the right to access, correct, delete, restrict, and port your data, and to lodge a complaint with a supervisory authority.

Supervisory authority:

The Federal Commissioner for Data Protection and Freedom of Information (BfDI)
Graurheindorfer Str. 153, 53117 Bonn
https://www.bfdi.bund.de

8. Data Security

We protect your data using encryption in transit where applicable, restricted access, and appropriate technical and organizational security measures.

For AI processing, we aim to minimize the data sent and avoid direct identifiers where possible. We may also attempt to redact sensitive content before transmission; however, redaction may not catch everything and the transmitted content may still contain personal data.

9. Changes to This Policy

We may update this Privacy Policy to reflect changes in the app or legal requirements.

The current version is always available at https://foldy.ai/app-info/ios/beta/privacy.html.