Privacy Policy
This policy explains how Premsan Inc (“Premsan”, “we”, “us”) handles personal data in Filincal — this website, the web app, the API, and the Filincal apps for iPhone, iPad and Android. Premsan is the controller.
1. What we collect
- Your account. Your name, your email address, and a password, stored only as a hash. Each session records the IP address and the browser or device it was opened from, and when it expires. We also record the date on which you accepted the Terms, and which version, and the day you last used the account.
- Your notes. Each note’s title and text, the companies it is filed under, and when you created and last changed it.
- The filings you open. A filing is a public document. Filincal keeps one copy of each filing anyone opens, as the SEC published it, and that copy holds nothing about you; which filing you had open is kept only with your conversation about it.
- What you search for. The words you search companies and notes with are used to answer you and are not kept.
- Your conversation with the assistant. The messages you send it, the photos you attach, made smaller to the size the model reads, the filing or note you had open when you wrote, your time zone so it knows what today is, and its replies.
- What the assistant remembers. The facts you tell the assistant about yourself, your work and how you want it to work, kept as memories so every later conversation starts with their titles and descriptions: each one’s kind, title, description and details, whether you or the assistant wrote it last, and when. You see and delete them in Settings, and correct one by telling the assistant; their titles and descriptions go to the model with every message you send it, and a memory’s details when the assistant opens it.
- Your voice. When you turn on voice mode, what you say is recorded and sent to be written down as text; the text goes to the assistant as your message, and the recording is deleted once it is written down. The assistant’s replies are read aloud by your own device’s voice.
- The plan. When your free use began, how many messages you have sent the assistant since, and the state of your subscription. On the web, payment is taken by Stripe: it receives your email address and your account id, and your card details go to Stripe and never reach us. We keep the subscription’s id, your customer id at Stripe, when the current period ends and whether it renews. In the app, payment is taken by the App Store or Google Play; we receive the transaction’s id, confirm it with Apple or Google, and record it against your account.
- Help. When you write to us from Help, we keep your messages, the pictures you attach, and details that help us answer: whether you wrote from the web or the app, your browser or app version and operating system, your language, the screen you were on, the size of your window or screen, your time zone, and your most recent failed requests. They are kept with your account until you delete it. Our team reads them in our own support tool, where, if you have allowed the assistant, Filincal’s model may draft a reply that a team member reviews before sending.
- Usage. The number of requests you made to the assistant in the current hour, kept in your own account’s storage for the hourly limit. Server logs hold request metadata, including your IP address, error reports, and the size and cost of each of the assistant’s runs, for a short time, for security, debugging and our accounting.
- The bot check. Cloudflare Turnstile runs on our sign-in and sign-up pages, and in the app’s sign-in screen, to tell a person from a script.
- Nothing else. There is no advertising, no analytics service, no tracking across sites or apps, no advertising identifier, and no data broker.
How far you get is recorded as you go: the day you sign up and each day you come back, whether on the web or the phone app and in which language; when you allow the assistant; when each request to it ends, which of its agents answered and whether it worked; when you reach what is free; when you pay, and through which store; when you write a new note; and when you add text to a note. Each record carries a random number kept in your account’s storage, never your name, your address or anything you wrote or made, and we read the records only as counts, to see where people stop. Deleting your account deletes the number; the records stay, with nothing in them that leads back to you.
2. What we do with it
We use personal data to run Filincal: to find the companies and fetch the filings you ask for, keep your notes and show them to you, let the assistant read what you send it and answer you, sign you in, send you the emails the account needs — a verification link and a password reset — take payment and keep your subscription’s state, keep the service running and prevent abuse, answer you when you write to us, and meet legal obligations. We do not use your notes, memories or conversations to train models, we do not sell personal data, and we do not share it for advertising.
3. Why we are allowed to
Where the GDPR or a law like it applies, we rely on these bases:
- Performing our contract with you — your account, your notes, your memories, your conversations, and the subscription.
- Our legitimate interests — keeping Filincal running, finding failures, and stopping abuse and automated sign-ups. We limit this to the usage counts, the server logs and the bot check. Seeing where people stop, from the record of how far you get, rests on it too.
- A legal obligation — payment records and anything else the law requires us to keep.
If your notes or messages hold personal data about other people, you decide what you keep and why, and you answer to them for it.
4. Who else processes it
Filincal runs on Cloudflare: the servers, the storage that holds your account, your notes, your conversations, your photos and the copies of the filings, the resizing of photos, the email we send, and the bot check are all Cloudflare services on our own account. The model that reads your messages and the filings and writes the assistant’s replies runs at Anthropic, reached through Cloudflare, and the assistant sends it nothing until you allow that, on the web or in the app, when it asks before your first message or photo; you can turn it off in Settings (under Account in the phone app), and the assistant then asks again before your next message. Anthropic does not train a model on what it is sent and deletes it under its own retention policy; when Anthropic cannot answer, the same request goes to OpenRouter, which does not train a model on it and passes it only to a model host that keeps nothing once it has answered, or else to Cloudflare Workers AI, and nothing the assistant reads goes to any other AI provider. What it sends is your messages, the photos you attach, your memories as section 1 describes, the notes it reads or writes, and the filings and figures it reads to answer you. Some email may be sent through Resend instead.
Filings come from the SEC’s EDGAR system. When you or the assistant look up a company, list its filings, read the figures it reported or open a filing, our server asks EDGAR for it; the SEC sees the company’s or the filing’s number in a request from our server, which identifies itself as Filincal with our support address and keeps to the SEC’s request limits, and nothing about you or your account. The SEC’s list of companies and their tickers is fetched for every account at once and kept for a day.
In voice mode, each recording of what you say goes to Cloudflare Workers AI to be written down as text, and to no other provider; we do not keep the recording.
Stripe takes payment on the web and keeps the card; Apple and Google take payment in the app, and each tells us when a subscription you bought there renews, is cancelled or is refunded. When the app opens, it asks Expo’s update service whether a newer version of our code is available; that request carries the operating system, our project id and a random identifier the app created for itself — no account and no device identifier — and Expo sees the IP address it came from. These providers process data only on our instruction and are each bound to protect it at least as well as this policy does; we give notice here before a new one starts.
The App Store and Google Play are the sellers of what you buy inside the app, and their handling of your payment is governed by their own privacy policies.
5. Where it is
Your data is processed on Cloudflare’s network, which spans the world, and stored on it under Cloudflare’s own commitments for international transfers. A request that goes to Anthropic leaves that network for Anthropic’s servers, and one that goes to OpenRouter for OpenRouter’s servers and its model host’s, each under that company’s own commitments for international transfers. Premsan is in Japan, a country the European Commission recognises as protecting personal data adequately.
6. On the phone
The app keeps on your device a sign-in token, the language and appearance you chose, and the random identifier its update check uses; your notes stay in your account and are fetched when you open them. It asks for the camera only when you choose to photograph a page or a chart for the assistant; you can turn it off in the operating system’s settings. It reads a photo only when you pick one, to send the assistant or to attach to a Help message, through the system’s photo picker, which needs no permission, and it makes a photo smaller before sending it. It uses the microphone only while voice mode is on, and the operating system asks your permission the first time you turn it on. It asks for no other permission, carries no advertising or analytics library, and purchases go through the store’s own sheet.
7. Cookies
On the web we set the cookies the product cannot work without: the one that keeps you signed in, and the ones Cloudflare Turnstile sets to tell a person from a bot on the sign-in and sign-up pages. This website and the web app keep your theme and language in your browser’s own storage. That is the whole list: no advertising cookies, no cross-site trackers, and no analytics that follows you between sites. Clearing them signs you out.
8. How long we keep it, and deleting it
We keep your account and your notes for as long as the account exists. Deleting a note deletes it, and clearing a conversation with the assistant deletes its messages and the photos you attached to them. The copy of a filing is the SEC’s public document, not yours, and stays for every account.
If your account goes unused for a month and has never had a subscription, we delete it and everything in it, as if you had deleted it yourself. One that has had a subscription becomes dormant instead: nothing it does on a schedule runs, and using it again restores it as it was; if it is still unused twelve months after it was last used, we delete it the same way. An account with an active subscription is never made dormant or deleted for going unused.
You can delete your account at any time: on the web under Account in Settings, or in the app under Account. We then erase everything we hold for you — your notes, your memories, your conversations and their photos, Help messages, usage counts and the subscription’s state — and then the account itself, and a subscription bought on the web ends. This cannot be undone.
These records remain after the account is deleted:
- A purchase made in the app. We keep the store’s transaction id, the date and the id of the account it was bought for, so that a store sending the same receipt again cannot credit it to another account, and because the law requires payment records to be kept. The account it names no longer exists.
- Payment providers’ records. Stripe, Apple and Google keep their own records of a payment under their own legal obligations.
- Backups. Cloudflare keeps restorable copies of our databases for up to 30 days so that they can be restored after a failure; they then expire.
- Server logs. They are deleted automatically after a short time.
9. Your rights
You can edit or delete any note, read and delete your memories, clear any conversation and delete your account in the web app or the phone app, without asking us. Depending on where you live, you may also have the right to a copy of the rest of what we hold about you, to restrict how we process it, to object to processing we base on legitimate interests, and to move your data elsewhere. Write to support@filincal.com and we will answer within one month.
If you live in California or another U.S. state with a similar law, you have the right to know what personal data we hold about you, to delete it, and to correct it; the controls above do that. We do not sell or share personal data as those laws define the words, so there is no opt-out to offer, and exercising a right gets you the same service on the same terms.
If you think we have handled your personal data wrongly, you can complain to a data protection authority — in the EEA or the United Kingdom, the one where you live or work or where the problem happened; in Japan, the Personal Information Protection Commission. You may contact us first, but you do not have to.
10. Security
Every connection is encrypted in transit. Passwords are stored as hashes. Each account’s notes, memories, conversations and photos are kept in their own isolated storage and are deleted with the account, apart from the records listed in section 8. The app keeps its sign-in token in the operating system’s secure store. Credentials never enter our server logs. If you find a security weakness, write to security@filincal.com and allow us time to fix it before you disclose it to anyone else.
11. Children
Filincal is not for anyone under 16, and we do not knowingly hold a child’s account. If you think a child has an account, tell us and we will delete it.
12. Changes
We may update this policy. When a change matters we will say so in the web app or the phone app, or by email. The date at the top is the version that stands.
13. Contact
Premsan Inc — 530-0001, 12-12, Osaka Ekimae Dai-2 Bldg., 1-2-2 Umeda, Kita-ku, Osaka-shi, Osaka, Japan. support@filincal.com.