Privacy Policy

Last updated: 26 April 2026 · Etornie AG (Switzerland)

1. Who we are

This Privacy Policy describes how Etornie AG ("Etornie", "we", "us") collects and processes personal data when you use the Etornie platform, including etornie.com, etornie.xyz, the client and attorney portals at app.etornie.com, and any related APIs and SDKs (the "Services").

Controller: Etornie AG, Ruessenstrasse 5, 6340 Baar, Switzerland. Contact: info@etornie.com.

2. Data we collect

Account & identity

• Name, email, phone number, role (admin / lawyer / client)
• Authentication credentials (hashed) and JWT tokens
• Solana wallet public keys and signed nonces (when wallet sign-in is used)

Case & document data

• IP case metadata (auto-numbered references, status, jurisdiction, deadlines)
• Documents you upload, including derived embeddings stored in pgvector
• Notes, comments, and activity timestamps

Usage & technical

• Server logs (IP address, user agent, request paths, response codes)
• Performance and error telemetry
• Aggregate AI-usage metrics (token counts, no prompt content unless required to debug)

3. How we use your data

• Operate the Services (case management, deadline tracking, AI assistance, notifications)
• Authenticate you and protect against abuse
• Send transactional emails and WhatsApp messages you opted into
• Improve the product and diagnose issues
• Comply with legal obligations (Swiss FADP, EU GDPR, applicable IP-law confidentiality rules)

4. Legal bases (GDPR)

• Contract — to deliver the Services you signed up for
• Legitimate interest — to secure and improve the platform
• Legal obligation — record-keeping under accounting and IP regulations
• Consent — for optional WhatsApp marketing or non-essential analytics, where applicable

5. AI processing & sub-processors

Etornie uses third-party AI providers to power EtornieGPT and the IP Agent. When you submit content to AI features, that content is sent to the relevant provider for inference, subject to their data-processing terms.

• Groq — LLM inference (Llama 3.3 70B Versatile)
• Together AI — embedding generation
• Meta WhatsApp Business Cloud API — outbound notifications
• EmailJS — transactional email (OTP, case alerts)
• Solana RPC providers — on-chain attestations, public-key transactions

The full sub-processor list with contact details is maintained in the Data Processing Addendum.

6. On-chain data

When you opt to attest case events on Solana, transaction metadata (wallet addresses, attestation hashes, timestamps) becomes part of the public Solana ledger. This data is immutable and cannot be deleted. We never publish raw documents on-chain — only ZK-friendly hashes and references.

7. Retention

We retain account and case data for as long as your subscription is active and for up to 7 years after termination, in line with Swiss accounting and IP-record obligations. Aggregated, de-identified analytics may be kept indefinitely. You can request deletion of personal data subject to overriding legal obligations.

8. Your rights

Under GDPR and Swiss FADP, you may request access, rectification, erasure, restriction, portability, and objection. To exercise any right, email info@etornie.com. You may also lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) or your local EU supervisory authority.

9. International transfers

Data may be transferred to providers in the United States and the European Union. Where required, transfers are protected by Standard Contractual Clauses or Swiss equivalents.

10. Security

We use bcrypt password hashing, TLS in transit, encryption at rest, role-based access control (RBAC), and audit logging. No system is perfectly secure — report any vulnerability to info@etornie.com.

11. Changes

We will post material changes to this policy on this page and update the “Last updated” date. Continued use of the Services constitutes acceptance.

Questions? Email info@etornie.com or write to Etornie AG, Ruessenstrasse 5, 6340 Baar, Switzerland.