Exomem Hosted privacy

This policy covers the Exomem Hosted service and its public product, account, OAuth, and support pages. The data controller is Substrate Systems OÜ (Estonian registry code 17394552), Siidisaba tn 13/2-14, 11311 Tallinn, Estonia. Privacy questions and rights requests can be sent to founder@substratesystems.io.

Data we process

• Account and authorization data: email address, invitation and consent state, client registration metadata, session and OAuth token digests, and account status. Raw passwords are not used for the Hosted OAuth flow.
• Your knowledge store: Markdown, media, links, metadata, searches, and changes you send through an authorized Exomem client. Search indexes and caches are derived from this content.
• Operations and security data: timestamps, coarse counts and sizes, client/protocol version, opaque request and resource identifiers, rate-limit records, service health, and security events. Operational logging is designed to exclude note content, queries, filenames, email addresses, tokens, and private endpoints.
• Billing data, when a paid plan is enabled: Paddle customer, transaction, subscription, product, and status identifiers. Paddle handles payment-card details; Exomem does not receive them.
• Support data: messages and content-free diagnostics you choose to send us. Please do not send knowledge content, tokens, invite links, or screenshots containing them.

Purposes and legal bases

We process account and knowledge-store data to provide the service you request and perform our agreement with you. We process limited security, reliability, support, and abuse data for our legitimate interests in operating and protecting Exomem and its users. We process billing and business records where necessary for our agreement and legal obligations. If we ask for optional consent, you can withdraw it without affecting earlier lawful processing.

The security boundary

Hosted Exomem is encrypted in transit and at rest, with tenant-isolated cells. It is not zero-knowledge or end-to-end encrypted: the isolated cell processes plaintext to search and serve your knowledge store. A tightly controlled operator could access a running cell only where necessary to operate, support, or secure the service. Access is restricted, and the operational design minimizes content-bearing logs and shared infrastructure.

AI clients and service providers

When you connect Claude, ChatGPT, Codex, or another MCP client, that client sends authorized tool requests to Exomem and receives the requested results. The client provider processes those prompts and results under its own terms and privacy policy; disconnecting the client revokes its future Exomem access but does not delete data already handled by that provider.

We use service providers only as needed to operate Exomem: Vercel for the public web and control plane, Neon for PostgreSQL, Cloudflare for protected networking and transfer ingress, contracted compute and object-storage providers for tenant cells and encrypted exports, Brevo for transactional email, and Paddle as merchant of record when billing is enabled. The public site may use privacy-filtered Vercel/PostHog analytics; Exomem account identifiers, email, knowledge content, tokens, and private routes are filtered from those events. Providers may process data outside the EEA under the safeguards required by applicable data-protection law.

Retention, export, and deletion

Your canonical knowledge content remains yours and is kept while your Hosted account is active. You can create a portable export and start verified account deletion from the product. Exports and access credentials expire on their stated schedule. On deletion we revoke sessions and client access, close routing, and destroy the tenant's compute, storage, and keys through the verified deletion workflow rather than merely hiding the account. Minimal billing, security, deletion-proof, and legal records may be retained for the period required to resolve disputes, prevent abuse, demonstrate deletion, or meet accounting and legal duties; they do not contain the deleted knowledge store.

Your choices and rights

Depending on applicable law, you can ask to access, correct, delete, restrict, or receive a portable copy of your personal data, and object to processing based on legitimate interests. You can withdraw consent where processing relies on it. We do not use Exomem data for solely automated decisions with legal or similarly significant effects. You may also complain to the Estonian Data Protection Inspectorate or your local supervisory authority.

Changes and contact

We will update the revision date when this policy changes and give appropriate notice of a material change. Contact founder@substratesystems.io or see the support page for help with privacy, export, or deletion.