Privacy Policy — Jalyo

1. Data controller

EI OCTOCUBE, sole proprietorship of Olivier CAETANO, SIRET 451 182 596 00044, 1A rue des Chaneaux, 63200 Marsat, France. Contact regarding your data and your rights: contact@octocube.fr. No data protection officer has been appointed at this stage.

2. Our principles

• Collect as little as possible and keep the content of your documents for as short a time as possible.
• The image of a photographed document never leaves your phone, and no document image is sent to an artificial intelligence service: only text is sent for analysis.
• Separate what must last (your actions and reminders) from what must disappear (the text of the document and its excerpts).
• Never send the content of your documents to measurement or diagnostic tools.
• Never use your documents to train artificial intelligence models.

3. Data processed

• Account — email address, technical identifier, session, onboarding status, date the application was last opened, optional backup email.
• Preferences — time zone, reminder time and lead times, theme, notification permission and the phone’s notification token, calendar link token, choice regarding audience measurement.
• Documents — text read (on the phone for a photo and for the scanned pages of a PDF, on our servers for the other pages of a PDF), the PDF for the time it takes to read it, file fingerprint (to recognise a document already sent), number of pages, recognised document type, document date as read, sensitivity, status.
• Analysis — structured result, summary, excerpts supporting each suggestion, suggested actions, verification codes.
• Actions and reminders — label, issuer, due date, recurrence, status, reminder history.
• Feedback — type, message, optional screenshots, technical context (application and system version, screen, journey identifier, document concerned where applicable).
• Technical data — application and system version, phone model, technical identifiers and operating events, analysis counters, duration and cost of calls to the analysis model, without any document content.
• Legal records — versions of the terms of use and of the policy presented, acceptance date, application version and build number, platform (Android or iOS).

4. Purposes and legal bases

• Account, document analysis, actions, reminders, calendar, export, deletion — Purpose: Providing Jalyo — Legal basis: Performance of the contract (terms of use)
• Security, abuse prevention, error diagnostics — Purpose: Protecting and operating Jalyo — Legal basis: Legitimate interest
• Feedback (problems, suggestions, screenshots) — Purpose: Fixing and improving Jalyo — Legal basis: Legitimate interest; screenshots added by you
• Proof of acceptance of the terms of use and of the information provided — Purpose: Recording the contractual relationship — Legal basis: Performance of the contract and legitimate interest
• Record of a deletion request received by email — Purpose: Proving that your request was handled — Legal basis: Legal obligation (GDPR, Articles 12 and 17)
• Audience measurement — Purpose: Understanding how Jalyo is used in order to improve it — Legal basis: Consent: off by default, turned on only if you choose to, and can be withdrawn at any time in Jalyo

5. Processing of your documents

The path followed depends on the type of document.

• Photo — the picture is taken with Google’s document scanner, provided by your phone’s Google Play services, which runs on the device; the image is handed to Jalyo only if you approve the scan. The text is then read on your phone by Google’s ML Kit library, which runs on the device: the image and the text read are not sent to Google (see point 9 for the technical metrics Google receives). The image stays in a private area of the application, then is erased after approval, rejection or filing. Only the text read is sent to our servers, which apply the health filter (point 7) to it before any storage and before any transmission to Mistral AI.
• PDF containing text — the file is placed in a private storage area on our servers, its text is extracted there, then the file is deleted as soon as it has been read (or, in the event of an incident, during the next daily purge). The health filter is applied to the extracted text before any transmission to Mistral AI.
• Scanned or mixed PDF (one or more pages without text, produced by a scanner) — the file is placed in the private storage area on our servers, which identify the pages without text and extract the text of the other pages; the health filter (point 7) is applied to that text, then the file is deleted (or, in the event of an incident, during the next daily purge). The pages without text are converted into images on your phone and read by ML Kit, on the device: these images are sent neither to our servers nor to any third party, and are erased as soon as they have been read. The reconstructed text is then sent to our servers, which apply the health filter again before any storage and before any transmission to Mistral AI.
• Analysis — the text that has passed the health filter is sent to Mistral AI to extract the useful information. Our servers then check every date and every excerpt. The suggestions are presented to you: no action is created without your approval.

6. Artificial intelligence — Mistral AI

Mistral AI (France) analyses the text of your documents. Only the necessary text is sent, to an endpoint located in the European Union; the analysis is carried out in the European Economic Area. Mistral AI’s text recognition (OCR) service is not used: no file and no document image is sent to it (point 5).

Zero data retention is enabled for Jalyo’s account: according to Mistral AI’s commitments for this setting, the texts sent and the results are not kept after the request has been processed. The use of Jalyo’s calls to train Mistral AI’s models is disabled.

The summary of a document and the label suggested for each action are generated automatically; you can correct them before approving.

7. Health documents

Jalyo is not intended for medical documents or documents containing health data (medical reports, test results, prescriptions or any other document directly revealing a person’s state of health): do not submit them. Jalyo is not a service for storing or processing medical records. To limit their processing:

• for a photo or a PDF, our servers first search the text read for terms characteristic of medical documents; a detected document is rejected immediately, without being sent to Mistral AI or kept;
• a health document that was not detected at this stage is recognised during the analysis and rejected; everything relating to it is then erased from our servers. Its text will, however, have been sent to Mistral AI, under the conditions of point 6;
• the scanned pages of a PDF are read on your phone: no image is sent to Mistral AI or to any other text recognition service, and the filter is applied to the text of these pages before any transmission to Mistral AI.

8. Retention periods

• Image of a photo — On your phone only; erased after approval, rejection or filing
• PDF (with or without scanned pages) — Deleted from our servers as soon as it has been read or, in the event of an incident, during the next daily purge
• Images of the scanned pages of a PDF — On your phone only; erased as soon as they have been read
• Text read, analysis result, summary, excerpts (including those shown on an action) — 7 days after the document is approved, rejected or filed
• Same data for a tax, banking or social security document — Erased upon approval, rejection or filing
• Same data for an identity document — Text read and analysis result erased as soon as the analysis ends; suggestions erased upon approval, rejection or filing; only the expiry date and the renewal action remain
• Document never approved — Content erased 30 days after it was created
• Health document — Nothing is kept
• Screenshots attached to feedback — 90 days
• Account, preferences, actions, reminders, feedback without screenshots, proofs of acceptance — Until the account is deleted
• Record of a deletion request received by email (internal identifier, dates, verification method, outcome; neither email address nor content) — 12 months after the request is closed
• Diagnostic logs (Sentry) — 30 days
• Hosting platform logs (Supabase) — API and database logs: 1 day; authentication audit logs: 1 hour
• Audience measurement (PostHog) — 1 year; when the account is deleted, erasure is requested from PostHog, which processes it on a deferred basis (point 12)
• Erasure request sent to PostHog when the account is deleted: pseudonymised fingerprint of the account identifier — Until PostHog confirms the erasure, then deleted; a record without identifier (dates, number of attempts, outcome) is kept for 12 months

9. Recipients

Your data is neither sold nor used for advertising purposes. Processors: the following providers process data on behalf of Octocube, in accordance with its instructions:

• Supabase — Role: Database, authentication, servers, private storage — Location: Paris region; account, support and operations possibly outside the EU (Singapore, United States)
• Mistral AI — Role: Text analysis — Location: Analysis in the European Economic Area; account management and some sub-processors outside the EU
• Resend — Role: Sending sign-in codes and reminder emails — Location: Sent from Ireland; account data and sending logs in the United States
• Expo — Role: Routing notifications — Location: United States
• Google (Firebase Cloud Messaging) — Role: Delivering Android notifications — Location: Worldwide
• Apple (APNs) — Role: iOS notifications, once the iOS version is released — Location: Worldwide
• Sentry — Role: Error diagnostics — Location: Storage in the European Union; account data and support in the United States
• PostHog — Role: Audience measurement, if you turn it on — Location: Storage in the European Union; support and some sub-processors outside the EU
• RevenueCat — Role: Subscription management, only once a paid plan exists — Location: United States

Separate recipient: Google’s ML Kit library, which reads the text of your photos and of the scanned pages of your PDFs on the phone, and Google’s document scanner (Google Play services) send Google technical usage and performance metrics (device and application information, technical identifiers, configuration, durations, error codes), without the image or the text read. Google processes these metrics for its own purposes (measurement, debugging, improving its services, abuse detection), as a separate controller and not on behalf of Octocube. Google does not state where or for how long these metrics are kept, and offers no way to turn off their sending.

10. Transfers outside the European Union

Some providers process data outside the European Union, in particular in the United States and Singapore:

• Supabase, Mistral AI: standard contractual clauses of the European Commission, provided for in their contracts;
• Resend, Expo, Sentry, PostHog: Data Privacy Framework certification and standard contractual clauses provided for in their contracts;
• Google (Firebase Cloud Messaging): Data Privacy Framework certification of Google LLC, with standard contractual clauses as a fallback.

For ML Kit metrics, Google acts as a separate controller (point 9); any transfers fall under its own commitments.

11. Reminders, emails and calendar

The label of your actions and their due date pass through the notification and email services so that you are reminded of them. Avoid writing information in them that you would not want to see on a locked screen or in an inbox.

The calendar link is personal: anyone who has it can see your dated actions. Do not share it; you can regenerate it at any time in Settings, which disables the old one.

12. Diagnostics and audience measurement

Jalyo’s logs contain only codes, counters, statuses and technical identifiers: never any document text, excerpt, amount, label or email address. The hosting platform’s logs (Supabase) contain the IP address and may contain the email address at sign-in; they are kept for 1 day, and 1 hour for authentication.

Sentry receives the application’s errors. Your message is attached to a report only if you tick the box provided; screenshots are never sent to Sentry. The IP address is not kept.

PostHog (audience measurement) is turned off by default: no event is collected before you turn it on, and nothing from before it was turned on is sent afterwards. If you turn it on in Settings, “Legal information”, Jalyo sends PostHog pseudonymised usage data in order to improve the application: a limited number of coded events, linked to an identifier derived from your account, without any content from your documents. No screen recording, no automatic collection, no IP address. Events are kept for 1 year. You can withdraw your consent at any time in the same place: no further events are then sent. When the account is deleted, Jalyo records an erasure request before deleting your data, then sends it to PostHog, normally within the hour. PostHog then erases this data on a deferred basis, according to its own schedule, which may take several days; Jalyo tracks this erasure until it is confirmed and, until then, keeps only the pseudonymised fingerprint needed for that tracking (point 8). Refusing or withdrawing this consent has no effect on your use of Jalyo.

13. Security

Access restricted to your account, isolation in the database, writes performed only by our servers, private storage, secrets kept server-side, encrypted communications, minimised logs, automated tests of isolation between accounts. In the event of a data breach, Octocube records it, assesses the risk, notifies the CNIL within 72 hours where the law requires it and informs you if it poses a high risk to your rights and freedoms.

14. Your rights

You have the rights of access, rectification, erasure, restriction, objection and portability, as well as the right to set instructions regarding what happens to your data after your death.

You may lodge a complaint with the CNIL, the French data protection authority, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, or at cnil.fr (opens in a new tab).

15. Mandatory data

The email address and the data needed for the features you use are essential. The message and screenshots of feedback, the backup email and audience measurement are optional.

16. Automated decision-making

Jalyo suggests; you decide. No action is created without your approval, and Jalyo makes no decision producing legal effects concerning you based solely on automated processing.

17. Minors

Jalyo is restricted to adults. Octocube does not knowingly collect data concerning minors.