01 Who is the controller
The data controller is Adianny Ramírez Armenteros, sole trader (Spanish NIE Y0470333C), based in Madrid, Spain, reachable at hello@saelyx.app. Saelyx is the product's commercial brand. For special-category data (facial biometrics) you can use the same contact, which acts as our data protection point of reference.
02 What data we actually store
Saelyx is an agent with memory. So that it can remember what you ask, we do persist certain data tied to your account (identified by your email). Transparently:
- Account: email, name, plan and, if you pay, your customer identifier at the payment provider.
- Memories. Durable facts you choose for Saelyx to remember (routines, preferences, context). May include personal information.
- Faces. If you enable "remember faces" (available only on paid plans), we store the cropped face image and the derived features to recognize it later. This is special-category biometric data (see section 4).
- Scenes. Frames of objects/places you ask to recognize, with their description.
- Meetings. If you use Meeting Mode (a paid feature), we store the meeting transcript (including the voice and content of participants) for 30 days, and a distilled summary durably. It requires your recording consent (see section 4).
- Learned skills. Patterns of how you work that Saelyx automatically derives from your conversations (profiling) to help you better. They make no automated decisions with legal effect. You can delete them anytime.
- Documents. The files you upload to your knowledge bases and the ones Saelyx generates for you.
- Conversation panel. The feed of your most recent conversation (text), so you can resume it across devices.
- Scheduled reminders, personal dictionary and usage metrics.
- Technical data and logs from the app and website (version, OS, crashes, access) to diagnose and detect abuse. In logs, your email is stored pseudonymised (not in clear text).
03 What is processed on the fly (and the nuance)
Live audio, camera frames and screen capture are streamed in real time to the voice engine so Saelyx can reason about them. Saelyx does not store them in its own systems.
Important — depends on your plan. On paid plans, this stream is processed under enhanced privacy terms and is not used to train models. On the free plan, the voice engine provider (Google) may use your live audio, camera and screen to improve its models. We tell you this prominently and record your acknowledgement the first time you use voice on the free plan.
Faces are out of scope here. Face recognition is a paid-only feature, so no facial biometric data ever goes through the free plan nor, therefore, through that model-improvement processing. The warning above applies to live voice, camera and screen, not to faces.
In other words: the ephemerality of audio/screen in our systems is real, but how the voice engine provider treats it varies by plan and is not something we control technically. That is why we declare it rather than promising a universal "zero retention".
04 Faces, meetings and consents
The remember-faces feature processes biometric data, which the GDPR classifies as special category (Art. 9). Therefore:
- It is available only on paid plans and is enabled solely with your explicit consent, which you can withdraw at any time from the app.
- When you withdraw consent we immediately delete all remembered faces: the image, the derived features and its recognition index. (Deleting a single face does the same for that face.)
- Without that consent, our systems store no face at all, even with the camera active.
- You are responsible for presenting to the camera only faces for which you have a legitimate basis; remember to inform those people where appropriate.
Meeting Mode records and summarises your meetings, which involves processing the voice and content of the other participants. It therefore also requires your explicit recording consent before the first meeting. When you enable it:
- You act as the controller of the participants' data: it is your responsibility to inform them and, where applicable, obtain their permission; Saelyx acts as a processor handling the meeting on your behalf (Art. 14).
- The raw transcript is kept for 30 days; the summary, durably until you delete it or close your account.
We keep a record of your consents (what you consented to, when, and with which version of the text), which you can review in your data export. We carry out a data protection impact assessment (DPIA) for these processing activities given their sensitive nature.
05 Legal bases
| Processing | Legal basis (GDPR) |
|---|---|
| Account, access and service delivery | Performance of a contract (Art. 6(1)(b)) |
| Memory, documents, panel, skills | Performance of a contract (core product function) |
| Face recognition (biometrics) | Explicit consent (Art. 9(2)(a)) |
| Meeting recording and summary | Recording consent; you act as controller towards participants (Art. 6, 14) |
| Learned skills (profiling) | Legitimate interest (Art. 6(1)(f)); disclosed and switchable off (Art. 22) |
| Billing | Legal obligation (Art. 6(1)(c)) |
| Logs and security / anti-abuse | Legitimate interest (Art. 6(1)(f)) |
| Model improvement on the free plan (voice provider) | Disclosed to you prominently; handled by the provider |
06 Sub-processors (who is involved)
To operate Saelyx we rely on the following providers, each under a data processing agreement (DPA):
| Provider | For what | Note |
|---|---|---|
| Google (Gemini Live API) | Real-time voice engine: audio, camera and screen | Paid plan: no training. Free plan: live voice/camera/screen may be used to improve its models (faces are not, they are paid-only). |
| Amazon Web Services (incl. Bedrock) | Infrastructure (databases, storage, authentication) and memory-extraction & vision models | Processing in the EU region (eu-west-1, Ireland). |
| Stripe | Payment processing | Only if you subscribe to a paid plan. |
| Twilio / SendGrid | Transactional email delivery (reminders, sign-in links) | Only your email address and the reminder content. |
| ElevenLabs | Voice synthesis and streaming: the audio of the conversation | Involved when Saelyx speaks to you. Processed in the EU per its residency configuration; the audio is not used for training. |
| Anam | Real-time animated face (the “Face” feature) | Only if you turn the Face on. It receives the session audio to sync the expression; it does not receive your documents or your memory. |
| Microsoft (Graph) | Reading your calendar and mail when you connect your account | Only if you connect the account, and only the permissions you grant when connecting it. |
| Tavily and Brave Search | Web search when you ask for it | They receive the query being searched, not your identity or the rest of the conversation. |
| Apple (APNs) | Push notifications to your devices | For the reminders you schedule. |
We do not sell your data to anyone.
07 International transfers
Saelyx infrastructure is hosted in the European Union (AWS, Ireland region). Some providers (Google, Stripe, Apple, ElevenLabs, Anam, Microsoft, Tavily and Brave Search) may process data outside the EEA. In those cases, transfers rely on the mechanisms the GDPR provides —Standard Contractual Clauses (SCC) and/or the EU–US Data Privacy Framework where the provider is certified— together with the corresponding DPA.
08 How long we keep data
- Account, memories, faces, scenes, skills, documents: while your account is active. Deleted when you delete the account (cascade deletion).
- Meetings: the raw transcript is kept for 30 days; the summary, while your account is active.
- Conversation panel: up to 90 days from last update (renewed with use).
- Summarised sessions: 90 days. Linked devices: 180 days.
- Application logs: 90 days. Access/authentication logs: 30 days. Email in logs is pseudonymised.
- Billing: 5 years (Spanish legal obligation).
- Audio and screen: not stored in our systems (see the free-plan nuance in section 3).
09 Your rights and how to exercise them
You have the right to access, rectify, erase, object, restrict processing and data portability. The practical way:
- Export all your data (access + portability): from the app, the export option. It produces a file with all your data categories, including the consent record and —while it exists (30 days)— a link to the raw transcript of your meetings.
- Delete your account (erasure): from the app. It is irreversible and cascades through your data across our databases, files and associated indexes.
- Withdraw biometric consent: turn off "remember faces" in the app (deletes your faces immediately).
- Withdraw meeting consent: turn it off in Settings; we stop accepting new recordings.
- Delete learned skills or any specific memory, face or meeting: from the app, without deleting the whole account.
You can also write to hello@saelyx.app (we reply within 72 hours) and lodge a complaint with the Spanish DPA, the AEPD.
11 Minors
Saelyx is not directed at children under 18. If you believe a minor has created an account, write to us and we will delete it.
12 Changes
If we change this policy we will notify you by email before applying it, and we will review the document whenever the processing changes. The previous version is archived.