Privacy Policy

Responsible Entity

The entity responsible for data processing within the meaning of data protection law is:

Elwin Lovelace AG
Waffenplatzstrasse 54
8002 Zürich
Switzerland

Email: jaron@getelwin.ch
Website: www.getelwin.ch

Data we collect and how we collect it

We receive personal data directly from you and through your use of the app:

• Account and profile data: Information you enter during registration and profile management, including name, email address, date of birth, phone number, and address.
• Document and contract data: Files you select or scan, recognized full text, contract details extracted from them, and metadata such as file name and creation time.
• Assistant data: Your questions, chat history, answers, answer ratings, and the contract references used to answer your question.
• Technical data: For operations, security, and error diagnosis, we process information such as app version, platform, request timestamps, and scrubbed diagnostics. Elwin does not intentionally include contract content or directly identifying profile data in data sent to Sentry.

Data Storage in Switzerland (Data Residency)

We place a high value on data sovereignty. Contract data and uploaded documents are stored and processed on infrastructure in Switzerland.

• Hosting: Our applications run on Swiss infrastructure operated by Infomaniak Network SA. The database, authentication, and document storage are operated by our processor Supabase in its Swiss region (data center in Zurich).
• No Foreign Transfer: Your contract data and personal data are stored and processed exclusively in Switzerland. Only for technical error monitoring do we transmit scrubbed diagnostic data without any user-identifying information to the EU-hosted service Sentry.
• Processors: We use the following service providers: Supabase (database, authentication, document storage; Switzerland), Infomaniak Network SA (servers, AI models, backups, email delivery; Switzerland), and Sentry (error diagnostics; EU).

Use of Artificial Intelligence (Privacy-First Architecture)

For contract analysis and the Elwin Assistant, Elwin uses AI services provided by Infomaniak Network SA, Rue Eugène-Marziano 25, 1227 Geneva, Switzerland. Infomaniak processes the data described below on Elwin's behalf.

The technical process is as follows:

• OCR (Optical Character Recognition): Uploaded documents (e.g., PDF scans) are made machine-readable through text recognition on our infrastructure.
• Classification: The recognized contract text is sent to Infomaniak AI Services to identify the type of contract (e.g., "household insurance") and extract structured contract details. This text may include names, addresses, contract or policy numbers, premiums, insurance details, and sensitive personal data such as health information.
• Storage & Processing: The original document and extracted contract data are stored in Switzerland until they are deleted as described under Retention and deletion.
• RAG & LLM (Retrieval Augmented Generation): When you ask the Assistant a question, the question, relevant recent chat history, your first name and age, the names of policies in your account, relevant extracted contract data, and passages from related general insurance terms are sent to Infomaniak AI Services. This is used to perform retrieval and generate the answer.

Protection at Infomaniak:

• Processing in Switzerland: API requests are processed on Infomaniak's own infrastructure in Switzerland using open-source AI models. They are not forwarded to OpenAI, Google Gemini, or comparable providers.
• No permanent storage or model training: Under Infomaniak's terms, API request content is held temporarily only for the time required to process the request, is not permanently stored, and is not used to train Infomaniak models or for any other purpose. Infomaniak retains operational metadata such as the client identifier, number, processing time and timestamps of requests, and size and format information.
• Equivalent protection: Infomaniak is contractually required to process personal data only on Elwin's instructions and to provide the agreed services, maintain confidentiality, and apply appropriate technical and organizational security measures.

Purposes and personalization

We process your data only for the features and operational purposes described in this policy.

• Contract management: Documents are recognized, classified, and structured so that you can manage your contracts in Elwin.
• Personalized answers: The Assistant uses the profile and contract data listed above to tailor answers to your specific request. Elwin does not sell this data and does not currently use it to train its own or third-party AI models.
• Chat history: Your questions and the Assistant's answers are stored in your Elwin account to support a coherent conversation and later access to your history.

Processing of Particularly Sensitive Personal Data

As part of using the app, you upload documents (e.g., insurance policies) that may potentially contain particularly sensitive personal data (e.g., health data in health insurance documents).

• Consent: Before any data is first sent to Infomaniak AI Services for a document upload or the Assistant, the app displays a separate notice. Only by selecting "Allow and continue" do you give one explicit consent covering both AI features.
• Revocation: You can withdraw your consent at any time under "Profile > AI & data privacy." From that point onward, no further data for document uploads or Assistant requests will be sent to Infomaniak AI Services.
• Declining: If you do not consent, you may continue using the other areas of your account; document uploads and the Elwin Assistant remain disabled.

Disclosure to Third Parties (No-Selling Clause)

• No Data Sales: Elwin Lovelace AG does not sell user data to third parties (no address traders).
• Partners: In the current beta phase, no data is passed on to insurance partners or brokers. Should this become possible later for specific offers (Recommender), disclosure will only occur after an explicit, separate opt-in by you on a case-by-case basis.

Retention, deletion, and requests

Account data is retained until the account is deleted. Documents and extracted contract data remain until you delete the document or your account. Chat histories remain until account deletion or a substantiated deletion request. Statutory retention duties and time-limited backup copies remain reserved.

You can delete documents and your account in the app. For access, correction, or additional deletion requests, contact us at hello@getelwin.ch.