Privacy Policy
Effective date: [DATE] · [LEGAL ENTITY NAME]
Controller: [LEGAL ENTITY NAME], [ADDRESS], Switzerland. Contact / data requests: [CONTACT EMAIL].
1. Who we are
Repertoire is a private AI concierge for curated place recommendations. This policy explains what personal data we process, why, and your rights. It applies to visitors, applicants for invitations, and members. We process personal data under the Swiss Federal Act on Data Protection (revFADP) and, where you are in the EU/EEA, the EU GDPR.
2. Data we collect
- Invitation & referral data: name, email, and any note you submit when requesting an invitation or inviting someone. If you invite a friend, you provide their name and email — only invite people who agree to it.
- Account data (members): name, email, authentication identifiers (e.g. Google / email sign-in), and role.
- Concierge content: the messages and preferences you send to the concierge, and the recommendations returned. Aggregated, anonymous “gap” logs (a city/category we couldn’t answer) — without identifying you.
- Payment data: handled by Stripe; we receive limited billing/subscription status, not full card numbers.
- Technical data: IP address, device/browser info, and basic usage/security logs (e.g. rate-limiting), and any cookies described in §7.
3. Why we use it, and our legal bases (revFADP; GDPR Art. 6 for EU residents)
- Provide the Service, process your subscription, and respond to the concierge — performance of a contract.
- Handle invitation/referral requests and communicate with you — legitimate interests / your consent.
- Security, abuse prevention, and rate-limiting — legitimate interests.
- Improve coverage using anonymous gap logs — legitimate interests.
- Marketing emails (if any) — consent, which you can withdraw at any time.
- Comply with legal, tax, and accounting obligations — legal obligation.
4. AI processing & sub-processors
To run the Service we use trusted providers who process data on our behalf under contract:
- Anthropic — powers the AI concierge. Your concierge messages are sent to Anthropic to generate a response.
- Vercel — hosting / infrastructure.
- Upstash — stores invitation, referral, and gap records.
- Stripe — payment processing.
We do not sell your personal data. We share data only with these processors, and where required by law.
5. International transfers
Some providers (e.g. Anthropic) process data outside Switzerland and the EU/EEA, including the United States. For transfers from Switzerland to countries without adequate protection, we rely on safeguards recognized by the FDPIC (e.g. the Swiss Standard Contractual Clauses, and, where applicable, the Swiss–U.S. Data Privacy Framework); for EU residents, EU Standard Contractual Clauses.
6. Retention
We keep personal data only as long as needed: account data for the life of your membership plus 24 months; invitation/referral records for 24 months; concierge logs kept briefly and in aggregate; and accounting/billing records for 10 years as required by the Swiss Code of Obligations. We then delete or anonymize it.
7. Cookies & similar technologies
We use strictly necessary cookies for authentication and security. If we add analytics or non-essential cookies, we will describe them and obtain consent via a banner. You can control cookies in your browser.
8. Your rights
You have the right to: access, rectify, and delete your data, object to or restrict certain processing, receive your data (portability), and withdraw consent at any time. To exercise these, contact [CONTACT EMAIL]. You may lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) and, if you are in the EU/EEA, with your local data-protection authority.
9. Automated decision-making
The concierge uses AI to generate recommendations, but we do not make decisions producing legal or similarly significant effects about you solely by automated means.
10. Security
We use reasonable technical and organizational measures (access controls, encryption in transit, secret management, rate-limiting). No system is perfectly secure; we cannot guarantee absolute security.
11. Children
The Service is for adults (18+). We do not knowingly collect data from children.
12. Changes
We may update this policy; material changes will be notified by email or in-app. The “effective date” shows the latest version.
13. Contact
[LEGAL ENTITY NAME], [ADDRESS], Switzerland — [CONTACT EMAIL].