Privacy Policy
We respect your privacy. This policy explains what data we collect, why we collect it, and how you can control it.
Table of Contents
- 1. Data Controller
- 2. Data We Collect
- 3. Legal Basis for Processing (GDPR)
- 4. How We Use Your Data
- 5. Third-Party Processors
- 6. Data Retention
- 7. Cookies and Local Storage
- 8. Your Rights (GDPR)
- 9. Exercising Your Rights
- 10. International Data Transfers
- 11. Children's Privacy
- 12. Changes to This Policy
- 13. Contact
1. Data Controller
Reloadium is operated by a French company and acts as the data controller for personal data processed through our services.
Contact: contact@reloadium.com
2. Data We Collect
We collect the minimum data necessary to provide and improve the service.
- Account data
- Your email address and display name, obtained via Google Sign-In (Firebase Authentication). We do not store your Google password.
- Usage logs
- Metadata about AI requests: app identifier, model used, token counts, credit cost, and timestamp. We do not log the content of your prompts or AI responses.
- Credit balance
- Your current credit balance and transaction history (credits added, credits deducted), stored in Firebase Realtime Database.
- Payment data
- Payment transactions are processed by Stripe. We store only the Stripe customer ID and subscription status. Card numbers and full payment details are never stored by Reloadium.
- Analytics data
- Page views, app usage events, device type, browser type, and approximate location (country/region), collected via Google Analytics (Firebase). Data is aggregated and used to understand usage patterns. Google Analytics does not collect your name, email, or prompt content.
- Technical data
- Standard server logs including IP address, browser type, and request timestamps, collected automatically by Firebase Hosting and Google Cloud.
- App Check data
- Firebase App Check uses Google reCAPTCHA Enterprise (invisible, score-based) to verify that requests originate from a genuine app instance. reCAPTCHA collects hardware and software information (such as device and application data) and sends it to Google for analysis. No personal data is collected beyond what is described in Google's reCAPTCHA terms.
- Google Calendar access (optional)
- If you use a calendar feature in chat (adding an event, or checking what's on your calendar), you grant temporary permission to view and create events on your Google Calendar (calendar.events scope) — this does not include deleting or modifying calendars themselves, or events other than the ones you create. The access token is held only in your browser's memory for the current session and is never sent to or stored by our servers; it expires automatically and must be re-granted the next time you use a calendar feature.
- Forum content (Reloadium Forums)
- Posts, comments, your forum nickname, your optional display name (which can be your real name — it is never filled in from your Google account for you), your bio, and your tipping activity (each tip is recorded with the sender, recipient, amount, what was tipped, and the time), stored in Firebase and visible to other users of the Service where the feature makes them public.
- Direct messages (Reloadium Forums)
- The content of direct messages you send and receive through Reloadium Forums, stored in Firebase. Messages are visible to the sender and recipient only, and are also processed by our automated moderation system as described in our Terms of Service.
- Linked pages and moderation costs (Reloadium Forums)
- When a post, comment, or edit contains a link, our servers fetch that page (so the linked site sees a request from our servers, not from you) to have it reviewed by our automated moderation, up to three links per submission. We do not keep the page itself. We keep only a short AI-written summary of what the page was about, a cryptographic hash of the excerpt that was reviewed (which lets us detect later that the page changed, without holding a copy), the final address after any redirects, and the time of the check. We also record how many Credits the moderation check cost. The summary and the Credit cost are shown publicly next to your content.
- Images (Reloadium Forums)
- Images you attach to a forum post or comment, or send in a direct message (signed-in accounts only, up to four each). Each is re-encoded on our servers, which removes embedded metadata such as location, and is stored in Google Cloud Storage (Firebase Storage) in a private bucket. For a post or comment we also keep an AI-written description of what the image shows, which is displayed publicly as its alternative text, and the image itself is shown on the page. A direct message image has no such description and is delivered only to the two people in the conversation, through requests that require their sign-in. A profile picture (signed-in accounts with a nickname only) is stored the same way as a small square image, is shown publicly next to your name wherever you post, and is deleted when you remove it or delete your account.
- Note content (Reloadium Notes)
- The titles and content of notes you create in Reloadium Notes are encrypted on your device before being stored in Firebase, using a key derived from your device's passkey that never leaves your device. We cannot read your note content. To power AI features (such as generating connections between notes or transcribing audio), the unencrypted text of your notes is sent to the Google Gemini API, subject to the terms described under Google Gemini API below.
3. Legal Basis for Processing (GDPR)
We process your personal data on the following legal bases under EU GDPR Article 6:
- Contract performance (Art. 6(1)(b)) — processing your account data, credit balance, and usage logs is necessary to deliver the service you subscribed to.
- Legitimate interests (Art. 6(1)(f)) — retention of aggregated usage logs for fraud detection, abuse prevention, and service improvement, where these interests are not overridden by your rights. This also covers the automated moderation of forum content, including the pages it links to, which keeps the forums free of spam, phishing, and abuse.
- Legal obligation (Art. 6(1)(c)) — retaining payment records to comply with French accounting and tax regulations.
4. How We Use Your Data
- Authenticate you and maintain your session.
- Track and deduct credits for each AI request you make.
- Process subscription and credit pack payments via Stripe.
- Detect and prevent fraudulent or abusive usage.
- Send transactional emails (payment receipts, subscription confirmations) via Stripe.
- Improve the service by analysing aggregated, anonymised usage patterns.
- Comply with legal obligations (tax records, law enforcement requests where legally required).
- Automatically screen forum posts, comments, and direct messages for violations of our Acceptable Use rules before they are published or delivered.
- Fetch and review the pages linked from forum posts and comments as part of that screening, and publish a short AI-written summary of each next to the content.
5. Third-Party Processors
We share data with the following sub-processors, each bound by data processing agreements:
- Google Firebase (Auth, Realtime Database, Hosting, Cloud Functions)
- Stores account data and credit balances, runs server-side functions, and hosts the web applications. Data is stored in the EU (europe-west1). Privacy policy: https://firebase.google.com/support/privacy
- Google Gemini API
- Processes AI prompts to generate responses. We use the paid tier, which means Google does not use your data to train AI models. For forum moderation, this includes the text of the post or comment being checked and excerpts of any pages it links to. Privacy policy: https://ai.google.dev/gemini-api/terms Images attached to a forum post or comment, and to the first message of a direct message conversation, are sent to it together with the text so that they can be checked before publication or delivery.
- Stripe
- Processes payments and manages subscriptions. Stripe is the merchant of record for billing. Privacy policy: https://stripe.com/privacy
- Google Analytics
- Collects aggregated usage analytics (page views, app events, device info) to help us understand how the service is used and improve it. Data is processed in Google's infrastructure. Privacy policy: https://policies.google.com/privacy
- Google reCAPTCHA Enterprise
- Used via Firebase App Check to protect our API from abuse and ensure requests come from genuine app instances. reCAPTCHA Enterprise is invisible (no user interaction required) and score-based. Terms: https://cloud.google.com/terms/service-terms
- Google Calendar API (optional)
- Used only if you explicitly use a calendar feature in chat, to view your upcoming events or create an event you requested. We request the calendar.events scope. Privacy policy: https://policies.google.com/privacy
6. Data Retention
- Account data: retained for as long as your account is active, plus 30 days after deletion to allow for recovery.
- Usage logs (AI request metadata): retained for 12 months for fraud detection and service improvement, then automatically deleted.
- Payment records: retained for 10 years to comply with French accounting regulations (Code de commerce, Art. L123-22).
- Credit balance: deleted when your account is deleted.
- Technical server logs: retained for 90 days by Google Cloud infrastructure, then automatically deleted.
- Google Calendar access token: not retained at all — held in your browser's memory only for the current session and never transmitted to or stored by our servers.
- Forum posts and comments: retained until you delete them or your account is deleted.
- Link summaries and moderation costs (Reloadium Forums): kept with the post or comment they belong to and deleted with it. The content of a linked page is not retained beyond the moment it is reviewed; only the summary and a hash of the reviewed excerpt are kept.
- Images (Reloadium Forums): a profile picture is kept until you remove or replace it; other images are kept for as long as the post, comment or message they belong to, and deleted from storage when you delete it or your account is deleted (an image in a direct message is retained as long as the message itself, see below). An image that fails moderation is never stored.
- Tip records (sender, recipient, amount, time): retained for as long as either the sender's or the recipient's account remains active, for fraud prevention and refund review.
- Direct messages: since a conversation is shared between two accounts, a message is retained for as long as either the sender's or the recipient's account remains active, even if the other party deletes their account.
- Note content (Reloadium Notes): encrypted note data is retained until you delete individual notes or your account is deleted.
8. Your Rights (GDPR)
If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the following rights under GDPR:
- Right of access — request a copy of the personal data we hold about you.
- Right to rectification — request correction of inaccurate data.
- Right to erasure ("right to be forgotten") — request deletion of your account and associated personal data.
- Right to data portability — request your data in a machine-readable format.
- Right to restriction of processing — request that we limit how we use your data in certain circumstances.
- Right to object — object to processing based on legitimate interests.
- Right to withdraw consent — where processing is based on consent, withdraw it at any time without affecting prior processing.
9. Exercising Your Rights
To exercise any of the rights listed above, contact us at contact@reloadium.com. We will respond within 30 days. We may ask you to verify your identity before processing your request.
You also have the right to lodge a complaint with the French data protection authority (CNIL) at https://www.cnil.fr if you believe we have not handled your data lawfully.
10. International Data Transfers
Our primary infrastructure (Firebase) stores data in the EU (europe-west1, Belgium). Some Google Cloud services and Stripe may process data in the United States.
Where data is transferred outside the EEA, it is protected by Standard Contractual Clauses (SCCs) approved by the European Commission, ensuring an equivalent level of protection to that within the EEA.
11. Children's Privacy
The Service is not directed to children under the age of 18. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with personal data, contact us at contact@reloadium.com and we will delete it promptly.
12. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by posting a notice on the Service and updating the "Last updated" date at the top of this page.
Your continued use of the Service after the effective date of any updated policy constitutes your acceptance of the changes.
13. Contact
For any privacy-related questions, data requests, or complaints, contact us at:
- contact@reloadium.com
- Data Protection Authority (France)
- CNIL — https://www.cnil.fr