Privacy Policy

Version 1.2 — last updated: 27 August 2026

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Controller

Sevy-Créations
Kappelenacker 14
3234 Vinelz, Switzerland
Email: infos@sevy-creations.net

Sevy-Créations is the controller within the meaning of Art. 5 lit. j FADP (Swiss Federal Act on Data Protection) and Art. 4(7) GDPR.

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The principle: analysis takes place on your device

DocPacta identifies passages in a document and prepares questions to ask. This analysis is entirely local: the text of your document does not leave your phone, and the publisher never has access to it. The last five documents analysed are kept on your device only; you may delete them at any time from Settings.

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What is processed, and what is not collected

DocPacta requires no account, registration or email address. Documents, preferences and the five most recent items are processed locally. For unlock, credits and recovery, the app creates a random pseudonymous technical identifier. RevenueCat processes that identifier, limited technical information and Apple purchase history. The publisher's server stores only an HMAC fingerprint of the identifier with the credit balance, never document text.

DocPacta uses no advertising identifier, no ads and no cross-app advertising tracking.

Apple App Store declaration: Other User Content, Purchase History and User ID are declared for app functionality; purchase history is also used for aggregated RevenueCat analytics. None is used for advertising tracking.

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Device permissions

DocPacta may request access to the camera (to scan a document) and to the photo library (to import an image). The image is processed locally and is never sent. These permissions are optional: the application works by pasting text, without granting any of them.

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Cookies and trackers

DocPacta uses no cookies, no trackers, no audience-analytics tool and no advertising pixel. The application contains no advertising.

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The optional artificial-intelligence feature

An optional feature generates three to five additional questions. It is activated only with your express consent, on each use. The selected text, capped at 6,000 characters, is then transmitted to Infomaniak Network SA, Rue Eugène-Marziano 25, 1227 Genève (CHE-103.167.648), which hosts the relay server and the language model, exclusively in data centres located in Switzerland. No transfer outside Switzerland takes place; for persons located in the European Union, Switzerland benefits from an adequacy decision of the European Commission confirmed on 15 January 2024, so that no standard contractual clauses are required.

Infomaniak acts as processor within the meaning of Art. 9 FADP and Art. 28 GDPR, under its Data Processing Agreement, which forms an integral part of its general terms and conditions. Infomaniak's Data Protection Officer: Yoann Lopez (dpo@infomaniak.com).

Do not send unnecessary data or sensitive data within the meaning of Art. 5 lit. c FADP or Art. 9 GDPR. The purpose is single: to produce questions to ask. No advertising, no profiling, no resale.

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Retention period

Infomaniak contractually undertakes not to retain submitted text durably or use it for training (LLM API Specific Terms, Art. 6, 7 October 2025). The relay does not log content; it retains the balance, processed purchases and a pseudonymous fingerprint as long as needed to provide purchases and credits.

RevenueCat, Inc. (United States) acts as processor for purchases and recovery. Its Data Processing Agreement provides Standard Contractual Clauses where required, including restricted Swiss transfers, and permits listed subprocessors. Transaction data is retained while the service is provided and under applicable obligations, backup and archival rules.

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Your rights

You have the rights of access, rectification, erasure, restriction, objection and portability (Art. 25 to 28 FADP; Art. 15 to 22 GDPR). The recovery code shown in the app lets the publisher locate the corresponding pseudonymous record without knowing your civil identity. Keep it confidential and include it with your request.

Write to infos@sevy-creations.net; a reply will be sent within 30 days. Complaints may be made to the FDPIC in Switzerland or your EU supervisory authority.

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Security

Network communications are encrypted in transit with TLS. The language-model access token remains server-side. The credit ledger stores an HMAC fingerprint of the pseudonymous identifier, uses atomic writes and idempotency controls, with rate and daily limits on the relay.

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Children

DocPacta is not intended for persons under the age of sixteen and does not knowingly collect their data.

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Legal basis

Local analysis and processing of the pseudonymous identifier, purchases and credits are necessary to perform the service and purchase contract (Art. 31 FADP; Art. 6(1)(b) GDPR). The optional AI feature relies on your consent (Art. 6 para. 6 and Art. 31 para. 1 FADP; Art. 6(1)(a) GDPR), which you may withdraw at any time for the future in Settings.

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Changes

This policy may be amended. The version in force is always the one published at this address, with its date. A substantial change will be indicated in the application.

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Governing law

This policy is governed by Swiss law. The place of jurisdiction is that of the publisher's registered office, in Vinelz, canton of Bern.

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