Privacy Policy
Original Language: French. In the event of any discrepancy between this English translation and the original French version, the French version shall prevail.
Your Privacy in 30 Seconds (The Essentials)
Because transparency is the foundation of trust, here is how Ragalia actually works:
Local Storage & “Zero-Knowledge” Backup
Everything you say to our assistants stays on your phone, locked by your device’s security chips. New: You can now synchronize your devices or create Cloud backups. These are “End-to-End Encrypted” (E2EE) directly on your phone using a secret passphrase that only you know. Ragalia has no access to this key and can never read or recover your backups if you forget your password (“Zero-Knowledge”). ⚠️ Warning: Unless you enable these encrypted backups, your data will be permanently lost in the event of loss, theft, or breakage of your device.
Hybrid Processing (Secure & Ephemeral Transfer)
To make the Artificial Intelligence work, we query the Cloud, with maximum protection in 3 steps:
- Step 1 (Intelligent Scrubbing): Before leaving your phone, a high-reliability filter automatically removes detected sensitive data (Bank, SSN, Phone, Email), and your name is replaced by a pseudonym by default.
- Step 2 (The Isolated & Stateless Airlock): The “scrubbed” data is sent securely to an ultra-secure environment called an “Enclave” (a cryptographic airlock). It is decrypted there only in Random Access Memory (RAM) just long enough to generate the response. This enclave is hermetic: no one, not even Ragalia or the hosting provider, can see what happens inside.
- Step 3 (Egress Filter & Zero Retention): The enclave verifies the AI’s response to ensure no sensitive data was generated, then discards the data. We apply a strict Zero Retention policy: no conversational data is written to our servers.
Guaranteed Right to be Forgotten (Kill Switch)
If you decide to delete your account, our system triggers a “Kill Switch” that irreversibly destroys your local data vault and instantly cancels your subscription.
No Training & Zero Trackers
Your private conversations are never used to train our artificial intelligence models. Furthermore, our mobile application contains absolutely no advertising or behavioral analytics trackers. You are the client, not the product.
The detailed legal and contractual text begins below.
The purpose of this Privacy Policy (hereinafter the “Policy”) is to inform users (hereinafter “You”) of the commitments and measures taken by the company RAGALIA SASU (hereinafter “We” or “Ragalia”) to ensure the respect of your personal data.
Aware that confidentiality is the cornerstone of trust in a relationship with an Artificial Intelligence, we have designed our technology according to the principle of “Privacy by Design”.
Our “Local-First” Commitment (Data Sovereignty)
Ragalia’s specificity lies in its unique hybrid architecture which guarantees that you remain the sole master of your memory.
Encrypted Local Storage (At-Rest)
Your entire conversational history, consolidated “memories,” and emotional profile are stored in an encrypted database directly on your device. Decryption keys are mathematically bound to your operating system’s hardware security module (iOS Secure Enclave / Android Keystore) and never transit through our servers in clear text.
Absence of Default Cloud Copy & Risk of Loss
Ragalia does not retain any default copy of your memory on its servers. Warning: If you do not enable the encrypted backup feature described below, we have no means of restoring your conversations in the event of loss, theft, or breakage of your device.
”Zero-Knowledge” Cloud Sync and Backup (End-to-End Encryption)
Ragalia offers you the ability to synchronize your data between devices or create backups. We use a strictly transitive Cloud relay. Backup data is “end-to-end encrypted” on your device before any transmission, using high-security algorithms (AES-GCM and Argon2id) based on a unique passphrase you define. Zero-Knowledge Architecture: Ragalia neither stores nor knows this passphrase. It is technically impossible for us to decrypt your backups. Transfer files temporarily stored on our relay servers are automatically and permanently deleted after a short period (strict 1-hour lifecycle rule).
“No-Training” Guarantee
We formally commit that your personal conversations and memories will NEVER be used for the training of our artificial intelligence models or those of our partners.
The Data We Process
We collect and process data strictly necessary for the operation of the service, divided into two categories:
A. Administrative Data (Managed by Ragalia)
This data is stored on our secure servers for account management:
- Identity & Access: Email address, password (hashed and salted).
- Transactional: Subscription status managed via secure tokens (Webhooks). Your full banking data is processed exclusively by our secure payment provider (PCI-DSS) on our website or via native platforms. The mobile app has no direct access to it.
- Technical: Anonymized connection logs. The Ragalia mobile app is guaranteed “Zero Analytics”: it contains no behavioral tracking SDKs.
B. Conversational Data (Hybrid Architecture)
These data transit through our infrastructure to enable intelligence but are not retained.
- Local Filtering (Regex Scrubber): Before any transmission, a local algorithm removes ultra-sensitive data formats. Disclaimer: Although validated by intensive testing, this system acts as a safety aid. You agree not to voluntarily share critical secrets with the Assistant.
- Name Pseudonymization: An option (enabled by default) replaces your real name with a neutral identifier or pseudonym in data sent to the Cloud. You can disable this option in the app settings. In this case, your name will be transmitted to the cloud to improve personalization but will remain subject to strict non-retention policies.
- Ephemeral Processing in Enclave (Cloud): The “scrubbed” context is transmitted encrypted to an isolated cryptographic enclave (AWS Nitro Enclaves). The cloud retains no state between messages.
- Egress Filtering: The enclave includes a security mechanism verifying the AI’s response in real-time. If forbidden data is detected during generation, the stream is immediately blocked to protect your privacy.
Legal Bases and Purposes
In accordance with Article 6 of the GDPR:
- Provision of AI Service: Performance of Contract (Art. 6.1.b).
- Subscription Management: Performance of Contract (Art. 6.1.b) and Legal Obligation (Art. 6.1.c).
- Security & Fraud: Legitimate Interest (Art. 6.1.f).
Data Sharing and Sub-processors
We do not sell any personal data. Sharing is strictly limited to necessary technical providers.
Cookies and Trackers
- On the Mobile App: Zero trackers. The application is free of any analytics tools.
- On the Website (Vitrine): We use Plausible Analytics (UE), a privacy-friendly solution that does not set cookies and collects no personal data, only aggregated trends to evaluate our marketing efforts. Cloudflare Turnstile protects our forms against spam without profiling.
Main Sub-processors:
- Infrastructure & Secure Airlock: [Amazon Web Services (AWS)] (EU/France) - Hosting isolated environments (Nitro Enclaves) and the end-to-end encrypted sync relay (S3).
- Artificial Intelligence: [Google Cloud / Vertex AI / OpenRouter] - Configurations with strict training opt-out.
- Web Hosting: [Cloudflare] / [Vercel] - Security and static delivery.
- Payment: [Stripe] (Direct) and [Apple / Google] (In-App) - Secure transactions.
- Communication: [Brevo] (France/EU) - Transactional emails, newsletters, and waitlist management.
- Dispute Resolution: [CM2C] (France) - Consumer Mediator.
Transfers Outside the EU
Transfers to the USA are framed by the Data Privacy Framework or Standard Contractual Clauses (SCCs) with a Transfer Impact Assessment (TIA).
Retention Period
- Account Data: Deleted 3 years after the last activity.
- Billing Data: Retained for 10 years (Legal obligation).
- E2EE Transfer Files (Cloud Relay): Automatically destroyed after a maximum of 1 hour.
- Conversational Data (Enclave): Zero Retention. RAM purged instantly after each message.
- Technical Logs: 12 rolling months (anonymized).
Security and Vulnerability Reporting
- Encryption at rest: Native APIs (Secure Enclave / Keystore / DPAPI).
- Transport and End-to-End Encryption (E2EE): Strict TLS 1.3 and cryptographic exchanges via pinned certificates.
- Confidential Computing: Use of hardware cryptographic enclaves (Nitro Enclaves) guaranteeing physical and memory isolation.
Data Breach Notification
In accordance with Articles 33 and 34 of the GDPR, in the event of a data breach likely to result in a high risk to your rights and freedoms, we commit to informing you as well as the competent supervisory authority (CNIL) as soon as possible.
Coordinated Vulnerability Disclosure
If you are a security researcher and discover a potential vulnerability, we invite you to report it to us ethically before any public disclosure. Security Contact: security@ragalia.ai
Your Rights (The GDPR “Kill Switch”)
You have all the rights provided by the GDPR (Access, Rectification, Portability, Objection).
- Right to Portability: You can request the export of your conversational data. This export is provided in a structured, commonly used, and machine-readable format (JSON), allowing you to reuse it elsewhere.
- Right to Erasure (“Right to be Forgotten”) and Kill Switch: Ragalia integrates a strict deletion mechanism. If you request account deletion via the app, a “Kill Switch” is triggered. It immediately cancels your subscription with our payment provider, erases your administrative data, and triggers the immediate and irreversible truncation of your encrypted local databases on your device.
- Right to Lodge a Complaint: If you believe that your rights are not being respected, you can address a complaint to the CNIL (Commission Nationale de l’Informatique et des Libertés) at www.cnil.fr.
To exercise your rights, contact our Data Protection Officer (DPO) at: privacy@ragalia.ai.
Protection of Minors
The Ragalia Service is not intended for minors. You must be at least 18 years old to create an account.
Changes to the Policy
We may update this policy to reflect legal or technical changes. In the event of a substantial modification, we will inform you by email or via a notification within the application before it comes into effect. This policy is complementary to our Terms of Service.
Data Controller and Contact Details
- Company Name: RAGALIA SASU
- Address: 61 rue de Lyon, 75012 Paris, France
- SIRET: 99376727600013
- Email: legal@ragalia.ai