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Privacy Policy

Effective date: 28 April 2026 · Version 1.0

This Privacy Policy explains how AppFocus GmbH ("we", "us", "our") collects, uses, discloses, and protects personal data when you use Intellity (intellity.ai) and the related competitive intelligence service (the "Service"). This policy applies to all customers, prospects, and visitors to the Service.

1. Data Controller

The data controller for the purposes of the Swiss Federal Act on Data Protection (FADP) and, where applicable, the EU General Data Protection Regulation (GDPR), is:

AppFocus GmbH
Haselstrasse 19
5400 Baden, Switzerland
UID: CHE-139.464.954
Managing Director: Nikola Kitanovic
Email: nikola@appfocus.ch

2. Personal Data We Collect

We collect only the data required to deliver and improve the Service:

  • Account data: email address, name (if provided), company name, billing address (via Stripe).
  • Service data: the list of competitors and signals you ask us to monitor, your preferences, and brief delivery history.
  • Payment data: processed and stored by Stripe Payments Europe Ltd. We do not store card details on our systems.
  • Usage data: basic, aggregated information on email opens and link clicks within briefs (provided by Resend), and server logs from our hosting provider (Vercel) that record requests for security and operational monitoring. We do not run third-party advertising trackers or behavioural analytics.
  • Correspondence: emails and support messages you send to us.

We do not collect special categories of data (health, biometric, political opinions, religion, etc.). We do not knowingly collect data from children under 16.

3. How We Use Personal Data

  • To provide and operate the Service (preparing and delivering your weekly brief).
  • To bill, take payments, and provide receipts.
  • To respond to your support requests and feedback.
  • To improve the Service through aggregated, anonymised information about how briefs are read.
  • To meet legal and regulatory obligations.

We do not sell or rent personal data to third parties. We do not use personal data for advertising or behavioral profiling.

4. Legal Basis for Processing

Where the GDPR applies, we rely on the following legal bases:

  • Performance of a contract (Art. 6(1)(b)) for delivering the Service.
  • Legitimate interests (Art. 6(1)(f)) for analytics, security, fraud prevention, and product improvement.
  • Legal obligation (Art. 6(1)(c)) for tax, accounting, and regulatory compliance.
  • Consent (Art. 6(1)(a)) where specifically requested.

5. Subprocessors

We use the following carefully selected subprocessors to deliver the Service. Each is bound by data protection terms equivalent to or stricter than the standards we apply ourselves.

  • Stripe Payments Europe Ltd. (Ireland, with parent processing in the USA) for payment processing and subscription billing.
  • Resend (USA) for transactional and waitlist email delivery.
  • Vercel (USA) for website and application hosting.
  • Cloudflare (USA) for DNS, domain registrar, and inbound email routing.

We will update this list before adding any new subprocessor that processes personal data. If we later introduce analytics, a database provider, or a language-model provider, the list above will be updated and existing customers will be notified by email.

6. International Data Transfers

Several of our subprocessors are located in the United States. Where personal data is transferred outside Switzerland or the European Economic Area, we rely on adequate safeguards: the EU Standard Contractual Clauses (with the Swiss addendum recognised by the FDPIC), and, where the recipient is certified, the EU-US Data Privacy Framework and the corresponding Swiss-US Data Privacy Framework. Vercel, Resend, and Cloudflare are all DPF-certified at the time of writing.

7. Data Retention

We retain personal data only as long as necessary to provide the Service and meet legal obligations:

  • Account and Service data: for the duration of your subscription, plus 90 days after cancellation, after which it is deleted unless required by law.
  • Billing records: retained for 10 years to comply with Swiss accounting requirements (Art. 958f Swiss Code of Obligations).
  • Email correspondence: retained for up to 2 years.
  • Aggregated, anonymized analytics: retained indefinitely (no longer constitutes personal data).

8. Your Rights

Subject to applicable law, you have the right to:

  • Access the personal data we hold about you.
  • Request correction of inaccurate or incomplete data.
  • Request deletion of your data ("right to be forgotten").
  • Restrict or object to processing.
  • Receive your data in a portable format.
  • Withdraw consent at any time (where consent is the legal basis).
  • Lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) or, if you are in the EU, your local supervisory authority.

To exercise any of these rights, email nikola@appfocus.ch. We will respond within 30 days.

We do not make decisions with legal or similarly significant effects based solely on automated processing, including profiling.

9. Security

We protect personal data with measures appropriate to the size and stage of the Service: TLS encryption in transit, hosting on infrastructure (Stripe, Resend, Vercel, Cloudflare) that encrypts data at rest by default, and access strictly limited to the founder and any specifically authorised contractors under confidentiality. We will harden these controls (including formal role-based access, periodic security reviews, and audit logging) as the team and data footprint grow. No system can be guaranteed 100 percent secure; we will notify affected users and the relevant authorities of any data breach as required by Swiss and EU law.

10. Cookies

Intellity does not set tracking cookies and does not run advertising or behavioural analytics. The only cookies you may encounter are those set by Stripe during checkout, which are governed by Stripe's privacy policy. If we later introduce a privacy-respecting analytics provider, we will update this section before doing so.

11. Changes to This Policy

We may update this Privacy Policy to reflect changes to the Service or applicable law. Material changes will be communicated by email at least 30 days before they take effect. The version number and effective date at the top of this page reflect the current version.

12. Contact

Questions, requests, or complaints about this policy: nikola@appfocus.ch