What we hold and why (lawful bases)
| Data | Why | Basis |
|---|---|---|
| Account (email, timezone, locale) | Run your account, weekly resets in your timezone | Contract |
| Your profile & answers (expertise, positioning, goals, voice, boundaries) | The entire product: proposing and writing in your voice | Contract |
| Pasted/imported LinkedIn text; your website's content | Building your voice profile — always at your initiation | Contract |
| Stories & (business) proof items | Story/Proof posts you approve | Contract |
| Business products & photos | Generating content that markets them | Contract |
| Usage events (approvals, skips, copies, edits) | Making next week's ideas better than this week's | Legitimate interest (stated plainly: this learning loop IS the product) |
| Generation cost logs | Running the service economically | Legitimate interest |
| Trial record (irreversible email hash) | One free week per person | Legitimate interest |
| Payment data | Handled by Stripe; we never see card numbers | Contract |
Export. You can download everything you have made and told us at any time: your profile, your stories and proof, your posts, and your image and clip files, as a single archive. Usage and cost logs are internal, anonymised on their own retention schedule, and not part of export — they record how the service ran, not what you made.
The promises (each backed by architecture, cite the mechanism)
- One model route. Every AI generation call runs through our EU/US-hosted model endpoint. The consumer API of our model vendor is not called from any code path — this is enforced by absence of code, not by policy. Sub-processors are listed below; none is in a jurisdiction we haven't named.
- Imports are read, not kept. LinkedIn archives and website scrapes are parsed in the moment; we keep the structured facts (roles, posts you wrote, what your business does), never the file. There is no table for the raw archive.
- Your content is yours. Posts, images, clips: your property, no licence back to us beyond operating the service, no training our systems on your content for other customers.
- We don't scrape anyone. Website reading happens only on a URL you give us for your own site; LinkedIn data arrives only by your paste or your official export.
- No faces, v1. We decline photos containing people and never generate identifiable faces — likeness consent done properly is coming for business accounts, not improvised.
- Trial fairness without surveillance. To prevent abuse of our free trial, we store a one-way hash of your email address for 12 months. This hash is retained even after account deletion to enforce the trial eligibility rule; it contains no readable personal data and is automatically deleted after 12 months (a scheduled job, not a promise). The hash is a one-way transformation that cannot be reversed to the original email address. No device fingerprinting. If abuse ever forces that conversation, it happens here in this policy first, with a consent mechanism, not silently.
- Where things live. Database: Supabase, London. Files & images: Bunny, UK region.
- UK GDPR rights — access, rectification, erasure, portability, objection — via legal@sayvios.com, answered within a month. Erasure: account deletion with a 30-day grace window (change your mind), then profile anonymised; financial records retained 6 years (UK law); the trial hash stays its 12 months (it cannot be reversed to your email address, and deleting it on request would defeat its purpose — stated honestly).
Sub-processors
We use the processors below. Each is bound by a written contract that limits them to acting on our instructions and nothing else.
| Who | What they do for us | Where | Transfer safeguard |
|---|---|---|---|
| Supabase | Database and sign-in | London | — |
| Bunny | Storing and delivering your images and clips | Stored in the UK; delivered from Europe only | — |
| Vercel | Hosting. Our server code runs in London | US company, London region | UK Addendum / SCCs |
| Stripe | Payments | UK / EU | UK Addendum / SCCs |
| Resend (Plus Five Five, Inc.) | Sending account emails | US company, sending from Ireland | UK Addendum, at their DPA §6.4 |
| OpenAI | Generating images, and checking reference photos for faces | US | Article 28 terms and SCCs |
| Together AI | Generating written drafts | US | EU SCCs, zero-retention configuration |
Three things we would rather say plainly than leave you to find out:
- Our emails carry account facts only — your name, dates, how much of your week's allowance is left, and links. They never contain anything you have written or made. That is enforced by how the code is built rather than by anyone remembering: there is nowhere in it to put such content.
- A reference photo you upload is sent to OpenAI to check for a face and to generate images. That is likeness data. OpenAI does not offer zero retention — they hold API data briefly for abuse monitoring. Together AI, which handles the words you write, is configured to retain nothing.
- Together AI and Resend are not certified under the EU–US Data Privacy Framework. For those transfers we rely on the UK Addendum and Standard Contractual Clauses, backed by a transfer risk assessment, rather than on an adequacy decision.
We give 30 days' notice before adding or changing a sub-processor, and you can object.
Cookies
Essential only (session auth). No analytics cookies in v1 — telemetry is first-party, server-side, tied to your account and covered above, not a tracking-consent matter. Banner: none required for essential-only; revisit if that ever changes.
Controller & contacts
The controller of your personal data is Archema Labs Ltd, a company incorporated in Scotland with company number SC879076, trading as Sayvios. Our registered office is in Glasgow, Scotland, and its full address is on the public register at Companies House under that company number. We are registered with the Information Commissioner's Office under registration ZC161034.
| To do this | Write to |
|---|---|
| Ask what we hold, correct it, export it, or have it deleted | legal@sayvios.com |
| Raise anything about data protection with our Data Protection Officer | dpo@archemalabs.com |
If you are not satisfied with how we have handled something, you can complain to us at ico@archemalabs.com, and you can complain to the Information Commissioner's Office at ico.org.uk at any time — you do not have to come to us first.