← BrainCopy

Privacy Policy

Effective date: 15 November 2024

Last updated: 2 May 2026

This policy explains what data BrainCopy collects, why, where it's stored, who it's shared with, and what rights you have over it. BrainCopy is operated by Cnvert Sweden AB, a Swedish company registered at Gothenburg, Sweden (org. nr. 559158-5710). The quickest way to reach us about anything in this policy is the support chat at braincopy.ai; your message routes directly to the team and we respond within 30 days for formal GDPR requests (usually same-day for operational issues).

1. Summary

2. Data we collect

2.1 Account data

When you create an account, we collect your email address, display name, and an encrypted password hash (or a third-party identity token if you sign in with Apple or Google). We collect basic account metadata: creation date, last login, language preference, device identifier and push notification token for our mobile apps.

2.2 Content you give us

BrainCopy is a personal archive. You actively give us your content so that we can organize and preserve it. That includes:

2.3 Generated data

When you opt in to AI processing, our system creates derived data:

2.4 Technical data

When you use the website or mobile app, we and our hosting providers log standard technical data: IP address, browser/app version, approximate location (country level, inferred from IP), request timestamps, and crash reports. This data is retained for operational purposes — security monitoring, abuse prevention, debugging — and is not sold or used for advertising.

2.5 Payment data

If you subscribe or purchase AI processing, Stripe (our payment processor) handles your card details directly. We never see or store your card number. We retain the purchase record (what you bought, when, for how much) for seven years to meet Swedish accounting law requirements, even after account deletion.

3. Where your data lives

DataWhere it's storedLocation
Photos, videos, documents (originals)Your personal CloudMe account — our preferred partner for user-owned cloud storage. If CloudMe isn't the right fit, we can alternatively host your files on Hetzner hardware.Sweden 🇸🇪 (CloudMe) — or Germany 🇩🇪 (Hetzner alternative)
Account data, diary text, metadataMySQL database on our Oderland hosting accountSweden 🇸🇪
Thumbnails and processing artifactsHetzner Object Storage (S3-compatible)Germany 🇩🇪 (Nuremberg)
Temporary import files (social-media exports)Hetzner Object Storage, deleted after successful importGermany 🇩🇪
Email (newsletters, notifications)Our self-hosted Otto email platform on OderlandSweden 🇸🇪

All primary storage is inside the European Union, covered by EU data protection law. No personal data is transferred to the United States or other jurisdictions as part of normal operation.

4. Third parties we use (sub-processors)

We use the following companies to deliver specific parts of the service. Each receives the minimum data they need to perform their function; none are allowed to use your data for their own purposes beyond providing the contracted service.

ServicePurposeData transmittedLocation
Anthropic (Claude API)AI description of photos, diary narrative generation, voice transcription fallback, classification of capturesThe specific photo / text we're asking about, sent via encrypted HTTPS. Anthropic's terms prohibit training their models on API customer data.USA (unavoidable for Claude)
Amazon Web Services — RekognitionFace detection and clustering in photosPhoto bytes only, sent to the EU Frankfurt region. Faces are stored in our private collection; AWS's terms prohibit use for their own training.Germany (AWS Frankfurt)
StripePayment processing for subscriptions and one-off purchasesCard details (handled directly by Stripe — we never see them), customer name, email, billing countryIreland / USA
Hetzner Online GmbHObject storage for thumbnails; VPS hosting for worker and cloud storage; Storage Box for user filesAll data you uploadGermany 🇩🇪
Oderland Webbhotell ABWeb hosting, database, email deliveryAccount data, diary text, application codeSweden 🇸🇪
Apple / GooglePush notification delivery to mobile apps (APNs / FCM); optional Sign-in-with-Apple / Google identity tokensPush token + notification bodyGlobal
OpenStreetMap (Nominatim)Reverse geocoding — turning photo GPS coordinates into place namesGPS coordinates only, no user identifierEU
Otto (self-hosted)Transactional email (account notifications, digests)Email address, notification bodySweden 🇸🇪 (runs on our own server)
PostHog (EU cloud)Product analytics — anonymous and identified events to understand how features are used, where users get stuck, and which onboarding paths convert. Includes web analytics, click heatmaps, and uncaught error reporting. No advertising, no cross-site tracking, no profile sold or shared.Anonymous events (page views, button clicks) for visitors. Once you sign in, events are linked to a stable internal user ID so we can analyze your journey across sessions. Email is attached to your PostHog profile; raw diary content and photos are never sent.Germany 🇩🇪 (Frankfurt)

If you want the current list of sub-processors, reach us via the support chat at braincopy.ai.

5. Why we process your data (legal basis under GDPR)

6. Retention

We retain your data for as long as you have an account with us, plus short grace periods for account recovery. Specific retention rules:

7. Your rights under GDPR

You have the right to:

  1. Access your data — we provide a full export in machine-readable format.
  2. Correct inaccuracies — you can edit most data directly in the app; for anything you can't, contact us via the support chat at braincopy.ai.
  3. Delete your data — initiate from Settings, or contact us via the support chat; we process within seven days (plus the grace period).
  4. Restrict processing — pause AI processing or specific features at any time.
  5. Data portability — receive your data in JSON / standard file formats to move to another service.
  6. Object to processing based on legitimate interest.
  7. Withdraw consent for AI processing at any time (future processing stops; already-generated results can be deleted on request).
  8. Lodge a complaint with the Swedish Data Protection Authority (Integritetsskyddsmyndigheten, IMY — imy.se) or your local supervisory authority.

To exercise any of these rights, open the support chat at braincopy.ai and tell us what you need. Your message routes directly to the team responsible for privacy requests; we respond within 30 days.

8. Security

9. Children's data

BrainCopy is not intended for users under the age of 16. We don't knowingly collect data from children. If you believe a child has created an account, contact us via the support chat at braincopy.ai and we'll remove it promptly.

Parents who import a child's content into their own BrainCopy account (e.g. photos of their children in the family archive) are responsible for that content. The child's content in that case is not the child's data — it's the parent's — and is processed under the parent's consent.

10. Cookies and analytics

Login cookie: the application (app.braincopy.ai) uses a single session cookie to keep you logged in. There are no advertising cookies. No data is sold to third parties.

Product analytics (PostHog): we use PostHog to understand how the product is used so we can fix what's confusing and improve what works. PostHog stores a small first-party identifier (cookie or local storage entry, depending on your browser) so it can recognize you across pages of the same visit. The data is hosted in the EU (Frankfurt, Germany) and is processed under our Data Processing Agreement with PostHog. We don't enable session replay, advertising integrations, or cross-site tracking. We track events like "page viewed", "button clicked", and "onboarding step completed" — never the content of your diary, photos, or messages.

Your control: you can opt out of analytics at any time by enabling the "Do Not Track" setting in your browser, or by blocking eu.i.posthog.com in any privacy extension. PostHog respects DNT signals where present. We rely on Article 6(1)(f) (legitimate interest in product improvement) as the legal basis; if you object, contact us via the support chat and we'll exclude your account from collection.

11. Marketing communications

We send you operational email (account notifications, daily digests if you've enabled them, lifecycle reminders) under the legitimate interest basis. You can unsubscribe from any non-critical email via the footer link; account-critical notifications (e.g. security, payment) cannot be disabled while you have an account.

12. Changes to this policy

If we change this policy in a way that materially affects your rights, we'll notify you by email at least 30 days before the change takes effect. Minor clarifications and formatting updates are applied directly and tracked by the "Last updated" date at the top.

13. Related documents

The legal terms governing your use of BrainCopy live in our Terms of Service, including liability limits, refund rules, the Legacy-feature carve-outs, and choice of law.

14. Contact

Data Controller: Cnvert Sweden AB, Gothenburg, Sweden (org. nr. 559158-5710).

Contact: support chat at braincopy.ai. Messages reach the team responsible for privacy directly, with escalation to the company's responsible person when needed.

We don't have a formally appointed Data Protection Officer (not required under GDPR at our current size), but privacy requests are tracked and answered within the 30-day SLA.