Privacy

Version of 13 October 2026. This is the text for the private alpha.

This text says what happens to your data in four cases: you visit our website, you join the waitlist, you send the contact form, or you use the app frei. The app is a chat app for iPhone with AI models. In the private alpha you get it through TestFlight of Apple.

1. Who is responsible

Strana UG (haftungsbeschränkt)
Schackstr. 1, c/o Kleinhempel & Partner
80539 München, Germany
Email: hello@askfrei.com

Strana UG is the controller under the General Data Protection Regulation of the EU (GDPR). In this text, "we" is Strana UG. We have not named a data protection officer. For each question about your data, write to the address above.

2. The short form

• Your chats, your files, your memory and your settings are stored on your iPhone.
• Our server stores no chat, no file and no fact in a form that we can read.
• Our server stores no name and no email address for your account.
• When you send a message, our server reads it in its working memory and sends it to the AI partner that writes the answer. The server software writes none of it to a database, a file or a log.
• The partners that you select in the app get the parts of your content that they need for their work. Section 5 names each one.
• With the encrypted cloud backup on, our server stores a copy of your data that your iPhone encrypted. We do not have the key, so we cannot read the copy.
• We do not train an AI model on your content. We show no advertising, and we sell no data.
• The website sets no cookie, and it has no analytics tool and no tracker.
• The contact form of the website sends your message to our mailbox by email. The website stores no copy.

3. The website

3.1 A visit

The website sets no cookie and stores nothing in your browser. It has no analytics tool, no advertising and no tracker. It loads no font, no script and no image from a different company.

The server that sends you the website gets the data that each web server gets: your IP address, the time, the page that you ask for, and what your browser says about itself. Scaleway SAS, Paris, France, hosts the website for us, in its region Paris. Your connection ends at Scaleway, so Scaleway gets this data. We have not confirmed how long Scaleway keeps connection data.

The software of the website does not store your IP address and writes it to no log. For an event of the waitlist or of the contact form, it writes a log line with the kind of the event and the time. A line can also have counts, and for a failure the kind of the failure. For the requests that it refuses, it writes one line for the first request of a kind in an hour. When more such requests follow in that hour, it writes one line with their number. A line has no email address, no IP address, no link of the waitlist and no text of a message. The framework of the website also writes lines: at its start, and when a part of it fails. By the default of the host, Scaleway keeps the log lines for 7 days.

We use the data only to deliver the website and to keep it safe. The legal basis is our legitimate interest in a website that works (Article 6(1)(f) GDPR).

3.2 The waitlist

When you join the waitlist, we store your email address, the language of the page on which you joined, the time at which you joined, the time of our first email to the address, and the number of emails that we sent to the address. We send an email to the address, with a link to a page with a button. The button confirms the address. We use an address for an invitation only after you confirmed it with the button. We then store the time of the confirmation too.

We use the address for two things: to invite you to the private alpha, and to send you messages about the test, for example about its end. We send no advertising for other products.

• Where. The waitlist is in a database of its own at Scaleway in Paris, France. It is separate from the server and from the database of the app.
• The number of emails. If you join again before you confirmed, we send the email again: 3 emails at the most for one stored address, the second one at the earliest 10 minutes after the first one, and the third one at the earliest 20 minutes after the first one. An address with a different spelling is a different address: name+a@… and name+b@… each have their own count. An address that we deleted and that joins again has a new count too. For the software, two addresses are the same mailbox when they differ only in these four ways: in upper and lower case, in a "+" and the part after it in the name, for an address of Gmail in the dots of the name, and in gmail.com or googlemail.com after the "@". For all spellings of one mailbox together, the software takes 3 sign-ups at the most in one hour of the clock, for example from 10:00 to 11:00, and 6 sign-ups at the most in one day. A day is a day in UTC. Each sign-up that the software takes counts, also a sign-up that gets no email because its address is on the list. So one mailbox gets 3 emails at the most in one hour, and 6 at the most in one day. An email that waited counts for its mailbox a second time when it goes out. After these numbers, the software stores no new address of that mailbox and sends no email, and the page says that there were too many tries. A sign-up in the last moment of an hour or of a day counts for that hour or day. The software keeps the two counts in its working memory, so a new start of the software sets them to 0.
• A day with many emails. We have a limit for the number of emails of one day. A day is a day in UTC. When you join after we reached it, we store your address and send no email at that time. The page tells you that. A job of the website sends the email later, when a day has room. Your address waits in the same way when the email service cannot take our first email to you at the time at which you join. The page does not know this, and it tells you to check your email: the job sends that email later. When the email service refuses an email for its address, we send no second one by ourselves. Until you have the email, you can leave only with a message to hello@askfrei.com. An address that is on the list gets no new email on a day with no email left. We also have a limit for the number of addresses that wait for their email. On a day with no email left, the form takes no new address when that number of addresses wait, and the page tells you that.
• The links of the email. The two links of an email have a token with a random value. The database has a hash of each token, and not the token. A link opens a page with a button, and the link alone changes nothing.
• The email. Scaleway sends the email for us, with its service Transactional Email. For that, Scaleway gets your email address and the text of the email. Scaleway states that it hosts and processes all data of this service in the EU. We have not confirmed how long Scaleway keeps the record of an email.
• The limits. To limit the number of sign-ups and the use of the two buttons, the software of the website reads your IP address when you send the form or use a button of a link. It makes a hash of the address with a random value that changes each hour, and it keeps the hash in its working memory for a maximum of 2 hours. For an IPv6 address, it uses the first half of the address. To count the emails of one mailbox, it does the same with your email address: it makes the hash of the address in lower case, with no "+" and no part after it. For an address of Gmail, it also removes the dots of the name. For the count of one day, it keeps a second hash of that form, with a random value that changes each day, for a maximum of 25 hours. To limit the use of the two links of one email, it keeps a hash of their token in the same way, for a maximum of 2 hours. It writes no IP address and none of these hashes to a database, a file or a log. The database has your email address only as you wrote it, with no space around it.
• No link to the app. The app has no field for an email address, and the server of the app stores none. We do not link your email address to your account in the app.
• The invitation. The invitation comes through TestFlight. For that, we give your email address to Apple, and Apple sends the invitation. Section 6 says what Apple does.
• The legal basis. Your consent (Article 6(1)(a) GDPR). You give it when you join, and you confirm it with the button on the page of the first link of the email.
• How long. We delete an address that you did not confirm 7 days after our first email to it. When we sent no email to an address in the 7 days after it joined, we delete it then. So an address that you did not confirm stays for 14 days at the most. We delete a confirmed address 12 months after its confirmation, at the latest. A job of the website does these deletions each hour, so an address can stay for up to one hour longer.
• How to leave. Open the second link of the email, and use the button on its page. The button deletes your address at once. You can also write to hello@askfrei.com from the address that you gave us. You can do this at any time. We then delete the address. The software limits the number of uses of the two buttons in one hour: for one IP address, and for the two links of one email together, which have one token and one count. Over that limit, use the button in the next hour, or write to us.
• Backups. Scaleway makes a backup of the database of the waitlist each day and keeps each backup for 7 days. So a backup can keep a deleted address for a maximum of 7 days.

3.3 The contact form

When you send the contact form, the website sends your message as one email to our mailbox hello@askfrei.com. The email has your email address, your message and the language of the page on which you wrote. Your email address is also the address for our answer. We use this data only to read your message and to answer you. A message has 4,000 characters at the most.

• No copy on the website. The software of the website stores no message and no email address of the contact form: not in a database, not in a file and not in a log. When the email does not go out, the page tells you that, and it names our email address. The website does not try again, because it has no copy of your message.
• The email. Scaleway sends the email for us, with its service Transactional Email. For that, Scaleway gets your email address and your message. Scaleway states that it hosts and processes all data of this service in the EU. We have not confirmed how long Scaleway keeps the record of an email.
• The mailbox. The email arrives in our mailbox. The email provider of our company stores it there for us.
• The limits. To limit the number of messages, the software of the website reads your IP address when you send the form. It makes a hash of the address in the way that section 3.2 says, and it keeps the hash in its working memory for a maximum of 2 hours. It also counts the messages of all visitors together: for one hour in its working memory, and for one day in the database of the waitlist. The count of a day is one number, with no data of a person. Over a limit, the page tells you that there are too many messages at that time, and it names our email address.
• The legal basis. Our legitimate interest in an answer to each person who writes to us (Article 6(1)(f) GDPR). When your message is about a contract with us, or about a step before one, the legal basis is Article 6(1)(b) GDPR.
• How long. We delete your message from our mailbox 6 months after our last email about its subject, at the latest. We keep a message for a longer time only when a law requires that, for example for a business letter under German commercial and tax law. A person of our company deletes a message. No software does it.
• Without the form. You do not have to use the form. You can write to hello@askfrei.com with your own email program. The website gets no data then.

4. The app

For a new user, the tap on "Get started" makes your account key on your iPhone, and it sends nothing to our server. The tap on "Start using your frei" makes the account. For that, the app sends two things to our server: a sign-in secret and your time zone. Before that tap, our server has no account for you. No chat text and no fact leaves your iPhone before you agree. You agree with the button "Start using your frei". When you bring an account back, you agree with "Restore" or with "Restore my intelligence".

4.1 What is on your iPhone

The app stores these things on your iPhone:

• your chats, with each message and each answer;
• the files and photos that you send;
• the documents that the AI model writes for you (the artifacts);
• the facts of your memory, with a list of numbers for each fact that the memory search uses;
• your custom instructions and your settings;
• your account key.

The account key is a random number that the app makes. It is in the Keychain of your iPhone. The recovery code is the account key as text: 28 letters and digits. If iCloud Keychain is on, Apple syncs the account key to the other devices of your Apple Account, from the moment at which you agree. Apple states that only your devices can read what iCloud Keychain syncs.

The app shows the keyboard of iOS only. It does not let a keyboard app of a different company open in it, so such an app does not get what you type in frei.

The app keeps the files with your content out of the iPhone backup of Apple. Apple states that this setting is guidance and not a guarantee. The preferences of the app are in the iPhone backup. They hold settings and the time of your agreement, and no chat, no file and no fact.

When you dictate a message, your iPhone turns the speech into text. The sound does not go to our server.

"Download my data" makes a ZIP file on your iPhone. The app sends no request to our server for it.

Before an update changes the form of the stored data, the app makes a safety copy of it on your iPhone. The app removes a safety copy when it starts and the copy is 14 days old or older.

4.2 What our server stores

Our server runs at Scaleway in Paris, France. It stores the following data.

• The app derives the sign-in secret from the account key. Our server gets the sign-in secret and never the account key.
• A log line has no message text, no title, no file, no search words and no fact.
• The server software does not read and does not store your IP address. Scaleway gets the IP address of each request, because your connection ends at Scaleway. We have not confirmed how long Scaleway keeps connection data.

4.3 What our server does with a message

When you send a message, the app sends one request to our server. The request has:

• the messages of the chat;
• the files and photos of the chat;
• your core facts, or each fact when your memory is small;
• your custom instructions and your settings;
• your time zone;
• the artifacts of the chat.

Our server reads the request in its working memory. It builds the request for the AI model and sends it to the AI partner that you selected. It gets from your iPhone the facts of your memory that fit your message. It runs a web search or opens a web page when the AI model asks for that. It sends the answer to your iPhone while the AI model writes it.

The server software writes no message, no file, no fact, no search and no answer to a database, a file or a log.

The content of a request stays in the working memory of the server while the answer is written. That is a maximum of 10 minutes, and some seconds for the end of the answer. After that, the server holds the answer until your iPhone confirms that it has it, for a maximum of 10 minutes. Then the server removes the answer from its buffers and writes zeros over them. Pieces of text can stay in the working memory of the program until the program uses that memory again. No request can read them.

A person with access to the server while it runs could read a message that passes through it. So we do not say that we cannot read your chats. We say that we store none of them.

More facts about a message:

• A PDF or a text file. The app sends the file to our server one time. The server reads the text out of it in its working memory and sends the text back. It stores nothing.
• The title of a chat. A small AI model at the same AI partner writes the title from your first message.
• The memory. The AI model can save a fact about you, change it or delete it. The fact is stored on your iPhone. You see, change and delete each fact on the memory screen. With the memory off, no fact leaves your iPhone.
• The memory search. Your iPhone searches your memory. For that, it needs a list of numbers for your message, which the memory search partner makes. So when your memory is not small, our server sends text to the memory search partner for each message: your newest message, and the first 300 characters of your message before it. Of a message with more than 1,000 characters, it sends the first 500 and the last 500 characters. The partner also gets the text of each saved fact, the search words that the AI model writes when it searches your memory, and what you type in the search field of the memory screen.
• The web search. The AI model decides when to search. Our server removes email addresses, phone numbers, bank account numbers and payment card numbers from the search words. It cannot remove all personal data: a name can stay in a search.
• A web page. When the AI model opens a web page, the website gets a request from our server and not from your iPhone. The request has a fixed program name and no cookie. The AI model writes the address of the page, so an address can have words from your chat.

4.4 The encrypted cloud backup

The backup is on when you start, and you can turn it off. With the backup on, your iPhone encrypts each chat, each message, each file, each artifact, each fact, your custom instructions and your settings. Then it sends them to our server. The key for this comes from your account key and never leaves your devices. Our server stores the encrypted data in its database and in its file storage at Scaleway in Paris.

We cannot read the backup. We can see these things about it:

• that your account has a backup, if it is on, and the time of the last write;
• the number of the items and of the files;
• the size of each item in steps of 256 bytes, and the exact size of each file;
• the time at which a file came;
• which items change, how often, and which items come together.

The limits of the backup:

• A backup has a maximum of 1 GB.
• A file over 20 MB is not in the backup.
• A change that still waits for its upload is not in the backup.

Without your account key and without your recovery code, nobody can read the backup. We cannot bring it back for you.

5. The partners

A partner is a company that does a part of the work of the app. You select the partners in the app, in the settings under "Partners". Each option has a page with its facts.

The partners of sections 5.1 to 5.3 do not get your account id, your IP address or your device from us. So such a partner cannot identify you directly. It can learn about you from what you write, and from your photos and files.

What a partner states about its own work is a statement of that partner. We cannot check it.

5.1 The AI model

Today the app has one option.

• Company. Lyceum Technology Germany GmbH, Berlin, Germany. Lyceum also names an office in Zurich, Switzerland.
• The models. Kimi K3 writes the answers. GLM-5.3 writes the titles of the chats. Moonshot AI and Z.ai, two companies in China, made these models and published them. They do not run the models for us, and they do not get your chats.
• What Lyceum gets. Each request of section 4.3: your messages, your files and photos, the facts that fit, your custom instructions and the artifacts of the chat. It also gets your time zone with the date and the time, and the texts that a web search or a web page gave.
• Where. Lyceum states that its models run in Paris and in Finland. Its data processing agreement says that it processes personal data primarily in the EU or the European Economic Area. So Lyceum does not promise that each part of the processing is there.
• What it keeps. The terms of Lyceum state that it does not store your text and the answers longer than is technically necessary to write the answer. Lyceum gives no number of days. Its data processing agreement permits it to keep content when a law requires it, against fraud and abuse, for security, and to keep its service stable. Lyceum states that it keeps a record of each request with the model, the number of tokens and the time. Lyceum states that it keeps the start of recent requests in the memory of its machines until newer requests replace it.
• Training. The terms of Lyceum state that it does not use your text and the answers to train or to improve AI models.
• The contract. The standard terms of Lyceum of August 2026, with its data processing agreement.

5.2 The web search

You select Staan or Exa, or you turn web search off. Staan is the option of an account that selected nothing. With web search off, the AI model can still open a web page, for example a link that you give it.

The search partner gets the search words after the filter of section 4.3. Staan also gets a market code for the language of the search, for example "de-de".

Staan

• Company. European Search Perspective, a joint company of Qwant and Ecosia, in Paris, France. The legal notice of Staan names it European Perspective SAS.
• Where. Staan states that all its servers are in Europe, at OVHcloud. Staan states that an American backup adds results when necessary, and that this backup then gets the search words. Staan does not name the company of the backup.
• What it keeps. The privacy policy of Staan lists logs of searches at OVHcloud in France. Staan gives no time for them. Staan states that the backup does not keep searches.
• Training. Staan states that it never uses searches to train a language model. Staan states that it uses searches to understand usage and to improve its service.
• The contract. The standard terms of Staan. A data processing agreement is available from Staan on request.
• A transfer to the United States. We do not know if the American backup is on for our account. Staan does not name the legal safeguard for it. If you do not want this, turn web search off.

Exa, only if you select it

• Company. Exa Labs Inc., San Francisco, United States.
• Where. In the United States. Exa states that it operates its services there.
• What it keeps. Exa gives no time. Exa offers a service that keeps no data only on its Enterprise plans. Our account has no such plan, so Exa can keep your searches.
• Training. Exa states that it uses search data to train and to fine-tune its models.
• The contract. The standard terms of Exa, with its data processing addendum.
• A transfer to the United States. With Exa, your search words go to a company in the United States. This follows from your own choice in the app. The data processing addendum of Exa has the standard contractual clauses of the EU (Article 46(2)(c) GDPR). No search goes to Exa while you do not select it.

5.3 The memory search

You select Scaleway or Lyceum, or "By words only". Scaleway is the option of an account that selected nothing. The model is Qwen3-Embedding-8B, of the Qwen team of Alibaba Cloud. The maker does not run the model for the memory search.

The memory search partner gets the texts that section 4.3 names. With "By words only", no company gets a text for the memory search.

Scaleway

• Company. Scaleway SAS, Paris, France.
• Where. Scaleway states that these models run in a data center in Paris, France.
• What it keeps. Scaleway states that it keeps no request by default. Scaleway states that after misuse or an error that harms its service, it can store the full content of requests for up to two weeks, to find and fix the cause. Scaleway states that it keeps usage numbers for up to 6 months.
• Training. Scaleway states that it does not use your data to train or to improve the models, and that the makers of a model cannot access your data.
• The contract. The standard terms of Scaleway. We have not confirmed which data processing agreement applies to these requests.

Lyceum, only if you select it

• Company and place. As in section 5.1.
• What it keeps, and training. Lyceum states on its page for this model that it does not store your text and never uses it for training. The terms of Lyceum promise this for its product "Inference", and they do not name requests for a search index. So we have not confirmed that the contract covers the memory search.

5.4 The host

• Company. Scaleway SAS, Paris, France.
• What it does. Scaleway runs our server, our database, our file storage and our log store, in its region Paris.
• What it gets. All data of section 4.2, your IP address, and each request while it passes through the server. The disk of the database is encrypted. With the backup on, the database and the file storage hold your content only in the encrypted form of section 4.4.
• Backups of the database. Scaleway makes a backup of our database each day and keeps each backup for 30 days. These backups are in data centers of Scaleway in the EU.
• The contract. The standard terms of Scaleway. We have not confirmed which data processing agreement applies.

6. Apple

Apple Distribution International Limited, Ireland, runs TestFlight and the App Store. Apple is responsible for its own processing. Its privacy policy applies to it.

• The invitation. To invite you, we give your email address to Apple.
• What Apple sends to us. Apple states that it collects crash logs, your name and email address, usage information and the feedback that you submit, and that it sends them to the developer. We are the developer. We use this data only to find faults and to make the app better.
• Your feedback. A feedback with a screenshot can show a chat. You decide what you send.
• iCloud Keychain. Section 4.1.

The app itself has no analytics tool and no advertising tool.

7. The legal bases

You can take your agreement back at any time, for the future. To do that in the app, delete your account. The app has no control that takes back only the agreement.

You do not have to give us data. Without an account, the app cannot send a message. Without an email address, you cannot join the waitlist, and we cannot answer a message of the contact form.

We make no decision about you that has a legal effect and that only a machine makes (Article 22 GDPR). The server applies the limits of use by itself. We make no profile of you.

8. How long data stays, and how you delete it

In the app.

• A chat. You delete one chat, or all chats. The app deletes them from your iPhone, with their files and their artifacts. Your memory stays.
• A fact. You delete one fact, or all facts.
• The backup. With the backup on, a deletion on your iPhone also goes to the backup, at the next sync. You can also delete the full backup.
• The account. "Delete account" deletes these things from our server in one step: the account, each session, the use of the account and the encrypted cloud backup. Then the app removes the account key and all data of the app from your iPhone. "Delete account" needs a connection to our server. With no connection, it deletes nothing.

What can stay for some time.

• Backups of the database. A backup of our database keeps a deleted row for a maximum of 30 days. A row of your encrypted cloud backup stays encrypted there.
• A file of the backup. Our file storage has no backup and no versions. If the storage fails at the moment of a deletion, the encrypted file stays until a later try works. The server tries again until the file is gone.
• The cost. After "Delete account", the cost of your account is a part of one sum for each month, for all deleted accounts together. The sum has no link to you.
• The log. Log lines with your account id stay for 7 days. They have no content.
• Safety copies on your iPhone. After you delete one chat or one fact, a safety copy on your iPhone can still have it. The app removes a safety copy when it starts and the copy is 14 days old or older. "Delete all chats" also removes each safety copy that has a chat.
• Your other devices. Data on a second device stays there until you delete it there.
• The working memory of the server. Section 4.3: a maximum of 10 minutes after the end of an answer.
• The partners. What a partner got stays there as section 5 says. We cannot delete it there.

An account that nobody uses. We keep an account until you delete it. We have no rule that deletes an account after a time with no use.

9. People in your chats and on web pages

You can write about other people in a chat, and a file or a web page can name people. Our server processes this data as section 4.3 says, and it stores none of it. The partners of section 5 get it as a part of your content. We cannot identify these people, and we cannot inform them. If you put data of a different person into a chat, you are responsible for your right to do that.

10. Your rights

You have these rights under the GDPR:

• access to your data (Article 15);
• correction (Article 16);
• deletion (Article 17);
• restriction of the processing (Article 18);
• your data in a format that a machine can read (Article 20);
• objection to a processing that rests on our legitimate interest (Article 21).

You can take a consent back at any time, for the future (Article 7(3)).

In the app. Your content is on your iPhone, so you use most rights there, with no request to us:

• You see your chats. You see, change and delete your facts, your custom instructions and your settings.
• "Download my data" gives you all data of the app on this iPhone as one ZIP file.
• You delete as section 8 says.
• You turn the memory, the web search or the backup off, and you select a different partner.

A request to us. Write to hello@askfrei.com. For the waitlist, write from the address that is on the waitlist.

For the data of section 4.2, we must know which account is yours. Our server has no name and no email address for an account. So a name or an email address does not find your account. Your account key is the proof that an account is yours: only a device with the key can sign in. Never send us your recovery code. We will tell you how you prove that the account is yours in a different way.

A complaint. You can complain to a data protection authority, for example the authority of the place where you live. The authority for our company is:

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
Promenade 18, 91522 Ansbach, Germany
www.lda.bayern.de

11. Age

The private alpha is for adults. You must be 18 years old or older to join the waitlist and to use the app. If you think that a younger person uses the app, write to hello@askfrei.com.

12. Changes of this text

We publish each new version on this page, with its date. When a change gives your content to a new company by default, or when we use your data for a new purpose, we publish the new version 14 days before the change applies. We also send the change to each address on the waitlist.