Privacy Policy

1. Data Controller

CGID Project Management LLC, registered in Dubai (SHAMS Free Zone), operates the APSOLU Pro platform (“apsolu.app”). For any questions regarding your personal data, contact us at: privacy@apsolu.app.

2. Data We Collect

We collect and process the following personal data:

• Account data: name, email address, profile picture (provided via Clerk authentication).
• Profile data: display name, profession, company, LinkedIn URL, bio, specialities (voluntarily provided).
• Usage data: pages visited, features used, timestamps (for product improvement).
• Project data: documents, contacts, companies, and other project-related information you upload or create.

3. Legal Basis (GDPR Art. 6)

We process your data based on:

• Contract performance (Art. 6(1)(b)): providing you with the APSOLU Pro service.
• Legitimate interest (Art. 6(1)(f)): improving our platform, preventing fraud, ensuring security.
• Consent (Art. 6(1)(a)): for optional AI-powered features that analyze your documents.

4. Sub-processors

We use the following third-party services to operate APSOLU Pro:

• Clerk (clerk.com) — authentication and user management. USA, SOC 2 compliant.
• Supabase (supabase.com) — database hosting (PostgreSQL). EU region (Frankfurt).
• Cloudflare R2 (cloudflare.com) — document storage. EU region.
• Vercel (vercel.com) — application hosting. Edge network, EU routing.
• OpenRouter / AI providers — optional AI features (document analysis, translation). Data sent only with explicit user action.
• Resend (resend.com) — transactional email delivery.

5. Your Rights (GDPR Art. 15–22)

As a data subject, you have the right to:

• Access your personal data (Art. 15) — export all your data from Settings.
• Rectification (Art. 16) — update your profile at any time.
• Erasure (Art. 17) — delete your account and all associated data from Settings.
• Data portability (Art. 20) — download your data in machine-readable JSON format.
• Object to processing (Art. 21) — contact privacy@apsolu.app.
• Withdraw consent for AI features at any time in Settings.

6. Data Retention

Your data is retained for the duration of your account. Upon account deletion, all personal data is permanently erased within 30 days. Project data shared with an organization may be retained by the organization owner per their own data retention policy.

7. Security

We implement industry-standard security measures including: encrypted data in transit (TLS 1.3), encrypted data at rest, role-based access control, rate limiting, and regular security audits. Authentication is handled by Clerk with SOC 2 compliance and optional two-factor authentication.

8. Cookies

APSOLU Pro uses only essential cookies required for authentication (Clerk session cookies). We do not use advertising or analytics cookies. No cookie consent banner is needed as we only use strictly necessary cookies (ePrivacy Directive Art. 5(3) exemption).

9. International Transfers

Some sub-processors are located in the USA. Transfers are protected by Standard Contractual Clauses (SCCs) as approved by the European Commission. Clerk and Vercel maintain SOC 2 compliance. Our primary database is hosted in the EU (Frankfurt).

10. Contact & Supervisory Authority

For any privacy-related questions: privacy@apsolu.app

If you believe your rights have been violated, you may lodge a complaint with your local data protection authority. For Romania: ANSPDCP (dataprotection.ro). For France: CNIL (cnil.fr).