Politique de confidentialité

English translation for convenience. In case of discrepancies, the German version of this privacy policy is legally binding.

Last updated: 3 November 2026

1. Controller

Francesco D'Agosta
Uerdinger Str. 646
47800 Krefeld
Germany
Email: contact@chiusora.com

This website is a private, non-commercial information page about the free beta of the Chiusora app. Nothing is sold through this website.

2. Hosting by Shopify

This website is operated with Shopify. The provider is Shopify International Limited, Victoria Buildings, 2nd Floor, 1–2 Haddington Road, Dublin 4, D04 XN32, Ireland ("Shopify"). When you visit the website, Shopify processes technically necessary data such as your IP address, date and time of access, pages visited, browser type and operating system in order to deliver the website, ensure its security and prevent abuse. The legal basis is Art. 6(1)(f) GDPR (legitimate interest in secure and stable operation). Shopify may also transfer data to countries outside the EU, in particular the USA and Canada; this is based on adequacy decisions of the European Commission (including the EU-US Data Privacy Framework) or EU Standard Contractual Clauses. A data processing agreement is in place with Shopify. More information: Shopify privacy policy.

Shopify also records events when you visit the website (e.g. page views, loading times, technical errors). As long as you have not consented in the cookie banner, Shopify says this happens only in a limited way and without statistics cookies, for security and technical operation (Art. 6(1)(f) GDPR). If you consent to statistics, Shopify additionally uses statistics cookies so that we can see how the pages are used (Section 25(1) TDDDG, Art. 6(1)(a) GDPR). We do not use advertising pixels or ad trackers.

Downloading the test version: The test version is stored as a file with Shopify. When you download it, Shopify (Shopify International Ltd., Ireland) and the service providers Shopify uses to deliver files process your IP address, the date and time, the file name and technical information about your device (user agent). This is necessary to deliver the file to you and to keep the service secure. The legal basis is our legitimate interest in providing you with the test version (Art. 6(1)(f) GDPR). For transfers to countries outside the EU, the information on Shopify in this section applies. The download is currently paused.

3. Cookies

Shopify sets technically necessary cookies, e.g. for session management, security and storing your cookie preferences. The legal basis is Section 25(2) TDDDG in conjunction with Art. 6(1)(f) GDPR. Non-essential cookies (e.g. for statistics or marketing) are only set with your consent (Section 25(1) TDDDG, Art. 6(1)(a) GDPR), which you can give or withdraw at any time via the cookie banner. An overview of the cookies used by Shopify can be found in the Shopify cookie policy.

When you choose a language, your browser stores this choice locally (localStorage) so that the site appears in your language on your next visit. This information is not transmitted to us and can be deleted in your browser settings.

4. Premium waitlist (email)

If you join the Premium waitlist, we process your email address and – voluntarily – your first name in order to inform you as soon as Chiusora Premium is available and you can be invited. The data is stored in Shopify's customer management and tagged "premium-warteliste".

The legal basis is your consent under Art. 6(1)(a) GDPR, which you give by ticking the checkbox. You can withdraw your consent at any time with effect for the future – via the unsubscribe link in every email or by email to contact@chiusora.com. Your data will be deleted as soon as you unsubscribe or the waitlist is no longer needed.

We use the double opt-in procedure: after signing up, you will receive an email in which you confirm your registration. Only then will you be added to the list. Shopify stores the time of your sign-up and your confirmation as proof (Art. 6(1)(c) and (f) GDPR).

Signing up is free and non-binding. It creates no obligation to buy or pay anything.

5. Contact form and email contact

If you write to us by email or via the contact form, we process your details in order to answer your inquiry (Art. 6(1)(f) GDPR, or Art. 6(1)(b) GDPR for pre-contractual inquiries). The data will be deleted once the inquiry has been dealt with and no statutory retention obligations apply.

For emails to contact@chiusora.com we use the iCloud+ email service (Custom Email Domain) of Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland ("Apple"). Your emails and the data they contain are stored and processed on Apple's servers; a transfer to the USA is possible (basis: EU-US Data Privacy Framework or EU Standard Contractual Clauses). The legal basis is Art. 6(1)(f) GDPR (legitimate interest in reliable email communication). More information: Apple privacy policy.

5a. Signing up as a beta tester

If you sign up as a tester using the form on our beta page, we process your email address and – voluntarily – your Mac's chip (e.g. M1, M2). We use this information to send you access to the beta, new test versions and information about the beta. The legal basis is Art. 6(1)(b) GDPR (your request to take part in the beta).

The form sends your details via Shopify as an email to contact@chiusora.com; no customer account is created. The email is stored in our iCloud+ mailbox provided by Apple (see section 5). When you submit the form, hCaptcha checks whether a human is using it (see section 6a). We do not send you advertising this way.

You can unsubscribe at any time by emailing contact@chiusora.com; we will then delete your details immediately. As soon as the beta ends, we delete the details of all testers, including the sign-up emails in our mailbox and our tester list.

6. Three.js via the jsDelivr CDN

For the 3D animation on the home page, the Three.js library is loaded from the jsDelivr content delivery network (operated by Prospect One, Poland, among others, with infrastructure from Cloudflare and Fastly). When it loads, your IP address is transmitted to the CDN's servers; this may include servers outside the EU. The legal basis is Art. 6(1)(f) GDPR (legitimate interest in fast and reliable display of the website). If you have enabled "Reduce motion" on your system, the animation is not loaded. More information: jsDelivr privacy policy.

6a. Spam protection with hCaptcha

Shopify protects our forms (contact, beta sign-up) against spam and abuse with hCaptcha, provided by Intuition Machines, Inc., USA. When you submit a form, hCaptcha checks whether a human is using it and processes, among other things, your IP address, browser and device information and your behaviour on the page (e.g. mouse movements). A transfer to the USA is possible. The legal basis is Art. 6(1)(f) GDPR (legitimate interest in protection against spam and abuse). More information: hCaptcha privacy policy.

7. The Chiusora app

This website itself does not transmit any data to AI providers. The Chiusora app works on your device (Mac, iPhone or iPad). Your chats, your memory, your files, photos and voice recordings stay on your device and are never sent to us or to third parties; we have no access to them. If you back up your device yourself (e.g. with Time Machine or as an iPhone backup), this app data may be included. You manage these backups yourself; we receive nothing from them. Apple's privacy policy applies to backups via iCloud. Answers are generated on your device. The app uses your device language; nothing is sent for this. The app does not check for updates itself; you download new test versions yourself from our website.

Photos, files and voice: Photos, images, scanned documents and files you give Chiusora are processed only on your device. Speech recognition runs on the device; audio is neither stored nor sent. The text recognised from your speech is treated like a typed message. Missing language packs may be downloaded by the operating system itself from Apple; Apple's privacy policy applies.

Account

There is no user account and no sign-in for the Chiusora app. Only the former beta version 0.10 ("Da Vinci Code AI") had a sign-in; details are in the paragraph "Sign-in (Beta 0.10 only)".

Online mode of Beta 0.10 ("Da Vinci Code AI")

This paragraph applies only to beta version 0.10, which was previously distributed as a ZIP file under the name "Da Vinci Code AI". Newer versions of Chiusora have no web search in the free version.

• In Beta 0.10, online mode is switched off by default. You can switch it on yourself, in the main window as well as in the floating window; the "Local | Online" setting applies to both. No account is needed for this. In local mode, web search is technically blocked.
• When online mode is switched on, the app decides by itself whether a question needs a web search; there is no further switch. It answers small talk and personal questions without searching. If a question needs a search, the app sends the wording of your question as the search term directly from your device, not via us, to DuckDuckGo (Duck Duck Go, Inc., USA) and to the Wikipedia search of the Wikimedia Foundation, Inc. (USA).
• Both receive the search term, your IP address, the time and technical connection data (e.g. user agent). Stored memories are not included in the search term. The app does not send your chat history, memory, files, photos or audio recordings.
• Purpose: the web search the app carries out for your question in the online mode you switched on, so that it can answer with current information. Legal basis: Art. 6(1)(b) GDPR.
• Transfer to the USA: To our knowledge, DuckDuckGo and the Wikimedia Foundation are not certified under the EU-US Data Privacy Framework, and we have no contract with them. The transfer takes place because it is necessary for this search in the online mode you switched on (Art. 49(1)(b) GDPR). The level of data protection in the USA may be lower than in the EU; in particular, US authorities may access data without you having the same legal remedies as in the EU.
• DuckDuckGo and the Wikimedia Foundation process this data as independent controllers under their own privacy policies. We do not receive the search queries.
• Please use local mode for health questions.

Automatic updating of knowledge packs (Beta 0.10 on the Mac only)

In Beta 0.10 on the Mac, the check for new knowledge packs is switched on by default. If a knowledge pack is installed, the app retrieves the file list at download.kiwix.org without any click, at most every 7 days and only over Wi-Fi without a metered plan (Kiwix Association, Switzerland; adequacy decision 2000/518/EC). If it finds a newer file, the app downloads it by itself; the information on downloads applies, including mirror servers. Only your IP address and the usual technical connection data are sent. The legal basis is Art. 6(1)(f) GDPR, our legitimate interest in keeping your installed knowledge packs up to date. You can object to this at any time (Art. 21 GDPR), most simply by switching off the toggle in the settings.

Sign-in (Beta 0.10 only)

• What data: your email address and, depending on the method, a one-time sign-in code, a password you choose, or the data from "Sign in with Apple" (which may include your name). Sign-in is also possible in the browser via auth.davincicodeai.com. For the waiting list, only your email address. Our sign-in server also sees your IP address and the time. On your device, the app stores a user ID, email address, name, an access token, the sign-in method, role and tier in the Keychain.
• Purpose: access to the beta via an account. Signing in is not required for online mode or search. Legal basis: Art. 6(1)(b) GDPR.
• Service providers: Vercel Inc. (USA, operation of the sign-in server), ChiselStrike Inc. ("Turso", USA, storage of accounts) and Plus Five Five, Inc. ("Resend", USA, sending sign-in codes). There are currently no reviewed data processing agreements with these service providers; we are looking into this.
• Storage location and transfer: It cannot be ruled out that the data is processed in the USA. Vercel Inc. and Plus Five Five, Inc. are listed under the EU-US Data Privacy Framework (Art. 45 GDPR); for Plus Five Five, Inc., re-certification is currently under way. We found no listing for ChiselStrike Inc.; here the transfer takes place because it is necessary for the sign-in you requested (Art. 49(1)(b) GDPR). The level of data protection in the USA may be lower than in the EU; in particular, US authorities may access data without you having the same legal remedies as in the EU.
• Sign in with Apple: this sign-in is processed by Apple Distribution International Ltd., Ireland, under its own privacy policy.
• Retention: The retention period has not yet been set. Until then, we will delete your account on request to contact@chiusora.com.
• Signing out: When you sign out in the app, the session on your device is deleted. Your sign-in remains stored on the server, however. For complete deletion, please email contact@chiusora.com.
• You can also exercise your rights under Art. 15–21 GDPR via contact@chiusora.com.

Downloads (models and knowledge packs)

The app downloads AI models and knowledge packs only when you start the download yourself, for example by clicking the download button. The download goes directly from your device to the provider, not via us. We receive no data.

• AI models are downloaded as public files, without an account or sign-in, from Hugging Face, Inc., USA (huggingface.co). Its EU establishment is Hugging Face SAS, Paris, France. Hugging Face receives your IP address, the file name, the requested part of the file (byte range), the time and a general identifier of the program (user agent). The file may be delivered via Hugging Face's content delivery network, which runs on Amazon CloudFront (Amazon Web Services, USA); Amazon Web Services then also receives this information.
• Knowledge packs (for example offline Wikipedia) are downloaded from the Kiwix Association, Switzerland. For the list of available packs (opds.library.kiwix.org) Kiwix receives your IP address and the chosen language and category. When a file is downloaded (download.kiwix.org) Kiwix receives your IP address and the file name, each with the time and user agent. Kiwix redirects the download to a mirror server, usually near you. If none is available there, a mirror server in another country may be used, including outside the EU, for example in the United Kingdom or the USA. The mirror operator then receives the same information.
• Chiusora only connects to Kiwix when you download a knowledge pack yourself.
• Purpose: providing the content you requested. Legal basis: Art. 6(1)(b) GDPR.
• Switzerland and United Kingdom: The European Commission has found that both countries ensure an adequate level of data protection (Art. 45 GDPR): for Switzerland by Decision 2000/518/EC, for the United Kingdom by Implementing Decision (EU) 2021/1772, last amended and extended by Implementing Decision (EU) 2025/2574.
• USA: To our knowledge, Hugging Face, Inc. is not certified under the EU-US Data Privacy Framework. We have no contract with Hugging Face, Amazon Web Services or the mirror operators, so there are no standard contractual clauses either. The transfer to the USA takes place because it is necessary for the download you requested (Art. 49(1)(b) GDPR). The level of data protection in the USA may be lower than in the EU; in particular, US authorities may access data without you having the same legal remedies as in the EU.
• Hugging Face, Amazon Web Services, Kiwix and the mirror operators process this data as independent controllers. How long they keep it depends on their own privacy policies.

After the download, the model and knowledge pack work on your device.

The full description is in this privacy policy; the app links to it.

8. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on legitimate interests (Art. 21 GDPR). You can withdraw any consent you have given at any time with effect for the future (Art. 7(3) GDPR). To do so, contact contact@chiusora.com.

You also have the right to lodge a complaint with a data protection supervisory authority, e.g. the authority responsible for your place of residence or the state data protection authority responsible for the controller.

9. Storage period

We store personal data only for as long as is necessary for the respective purpose or as required by statutory retention obligations.