Privacy Policy

1. Data Controller

SARL Spottmedia, 1354 Chemin Du Pioch De Baillos, Montferrier-sur-Lez, 34980, France.

2. Contact

For any data-related request, write to info@spottmedia.com.

3. What we collect

Waitlist visitors:

Email address, first name, last name, the date and time you accepted this policy, and the version of the policy you accepted.

Authenticated users:

• The decision text you type and the council responses generated for you. This content is transmitted to Anthropic's API to generate your council's perspectives — see §7 for details.
• Product analytics events (pageviews, page-leave, autocaptured clicks) via PostHog.
• Session-replay frames, with text masked by default (only fields explicitly marked data-capture="true" are recorded verbatim).
• Feedback comments, category, rating, the page URL where the feedback was submitted, your locale preference, and the technical context you opt in to share (page state, console logs, network activity).
• Locale preference (BCP-47 — currently en-GB or fr-FR).
• Council session content (your decision description and the AI-generated council responses) may be accessed by a limited number of Spottmedia staff for operational monitoring, quality assurance, and aggregate pattern analysis. Access is restricted to Spottmedia employees and is not shared with third parties for this purpose.

Operator/staff visits (anonymous, IP-allowlisted only):

Your IP address is read by our backend to evaluate the admin allowlist that gates the feedback widget on public pages. The IP itself is not stored in our database beyond the lifetime of the request; PostHog records its standard $ip property as part of any feedback event you submit.

4. Legal basis

Waitlist:

Your consent, under Article 6(1)(a) of the General Data Protection Regulation (GDPR). You may withdraw your consent at any time.

Authenticated users:

Performance of the service contract under Article 6(1)(b) GDPR for account + session operation, and our legitimate interest under Article 6(1)(f) for product analytics + session replay (debugging, UX improvement, reliability). You may object to legitimate-interest processing at any time — see §10.

Operator/staff visits:

Our legitimate interest under Article 6(1)(f) GDPR for internal debugging and product improvement of the public surface. Limited to an explicit IP allowlist set by Spottmedia operations.

5. Purposes and what we do not do

We use your data solely to operate and improve Invisico. Specifically:

• To operate your account and deliver the council service.
• To contact you about your waitlist place or account (if applicable).
• To send product updates or our newsletter, only if you have explicitly opted in.
• To improve the product through analytics and session replay.
• To monitor session quality and identify aggregate usage patterns during the closed beta period.

We do not sell your personal data to any third party, ever. We do not share your data with advertisers or data brokers. We do not use your data for marketing unrelated to Invisico. If you have opted in to email communications, those emails will only ever be about Invisico — its features, updates, and content. You can opt out at any time from your account settings or by emailing info@spottmedia.com.

6. Retention

Waitlist entries:

Kept until you ask us to delete your entry, or until the waitlist closes — whichever comes first.

Accounts and council sessions:

Account data and the council sessions you create are retained for as long as your account is active. If you request deletion of your account, we delete your personal data within 30 days, except where we are required by law to retain it longer.

Analytics and session replay:

PostHog event data is retained on a rolling basis per our PostHog plan tier. Session replays are retained for 30 days by default.

7. Third parties and data location

• Anthropic (United States, under Standard Contractual Clauses) — AI model provider. When you use the council feature, the decision text you type is transmitted to Anthropic's Claude API to generate your council's perspectives. Anthropic does not use API content to train its models (per their Privacy Policy). Only the content of your decision description and the structured prompts we send are shared — your email address, name, and account details are never transmitted to Anthropic.
• Brevo (European Union) — email delivery and contact list management. If you have opted in to our newsletter or product updates, your email address and opt-in preferences are stored in Brevo. Brevo is our data processor; a Data Processing Agreement is in place under Article 28 GDPR. Brevo does not use your data for any purpose other than delivering the emails we instruct it to send.
• DigitalOcean (EU region) — database and server hosting.
• Doppler (United States, under the EU-US Data Privacy Framework) — secrets management. Doppler does not receive any user data.
• GitLab SaaS (United States, under the EU-US Data Privacy Framework) — continuous-integration build logs only. GitLab does not receive any user data.
• OpenAI (United States, under the EU-US Data Privacy Framework) — feedback-triage translation only. When you submit feedback in French, the comment is sent through OpenAI's API to generate an English gloss for our triage queue. OpenAI does not use API content to train its models (per their API Data Usage Policy). Email addresses and URLs are stripped before the request.
• PostHog (European Union region — eu.i.posthog.com) — product analytics, session replay, and feedback collection for authenticated users + allowlisted operator visits. PostHog is our data processor; a Data Processing Agreement is in place under Article 28 GDPR. Session replay text content is masked client-side before transmission — only fields explicitly marked data-capture="true" are recorded verbatim.

8. Your rights

Under the GDPR you have the right to access (Art. 15), rectification (Art. 16), erasure (Art. 17), portability (Art. 20), restriction (Art. 18), objection (Art. 21), and to withdraw your consent at any time (Art. 7(3)).

9. Complaints

You have the right to lodge a complaint with the French data protection authority, the CNIL: cnil.fr/en/plaintes.

10. Exercising your rights

To exercise any of these rights or ask a question about your data, email info@spottmedia.com.

11. AI and automated processing

Invisico is an AI-powered service. Every council session is processed automatically: your decision description is sent to an AI language model API, which generates the counselor perspectives and synthesis you receive (see §7 for data-location details). No human reads or writes your council output in real time.

In accordance with Article 50 of the EU AI Act (Regulation (EU) 2024/1689), applicable from 2 August 2026, we inform you that you are interacting with an AI system. The counselors that appear in your sessions are AI-generated personas — not real people providing advice in real time.

Council output is a thinking tool to help you examine a decision from different angles. It does not constitute professional advice — legal, medical, financial, psychological, or otherwise. Seek qualified professional advice where appropriate.

12. Counselor imagery

The portraits shown for each counselor are AI-generated stylised illustrations — interpretations informed by a reference photograph, not photographs of the person and not likenesses endorsed by them. We use reference imagery only from openly-licensed sources (such as Wikimedia Commons, Creative Commons–licensed photography, and public-domain collections) or from photographs a person has made available for press use. Where no suitable image exists, we show a faceless silhouette rather than depict a real person's face. Each counselor page credits the image source and licence where one applies.

If you are a person represented in our counselor library (or their authorised representative), or the rights-holder of a reference photograph we have used, and you would like the associated imagery changed or removed, email info@spottmedia.com. We will remove it promptly on request, no questions asked.

13. Cached council responses

To reduce cost and latency, the council's response to a given question may be cached and reused: if another signed-in person later asks a question that is word-for-word identical, they may be shown the same previously-generated council output rather than a freshly-generated one. A cached entry stores only the generated council content and a one-way hash of the question text — it does not store your name, email, account, or any identifier linking the entry back to you, and it is not retrievable by anyone who has not typed the same question themselves.

Because a cache entry is de-identified derived content, exercising your right to erasure removes your own sessions but does not require us to purge the shared cache entry, which is no longer personal data once decoupled. Cached entries expire automatically and are cleared whenever the underlying model or council configuration changes.