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PRIVACY_POLICY.md
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Privacy Policy
# Privacy Policy
Last updated: 06.01.2026
Effective and last updated: 23 September 2026
1. Controller / Contact
This policy explains what personal data Elsewhere handles, why it is needed, where it goes and the choices available to you.
Application: DeepFake
## 1. Who is responsible
Owner/Controller: Kristian Cerni
Kristian Cerni is the controller responsible for Elsewhere. This policy applies to the Elsewhere website, account area, chats, persona market and related features.
Contact: https://github.com/KrisHD1337
- Service: Elsewhere
- Privacy contact: [kriscerni@gmail.com](mailto:kriscerni@gmail.com)
- Project contact: [github.com/KrisHD1337](https://github.com/KrisHD1337)
This policy applies to all users within Switzerland, the EU, and other jurisdictions.
## 2. Personal data we handle
2. What We Collect
We collect data you provide and technical data generated while you use the service:
We collect only what’s needed to provide our service:
- **Account data:** username, password hash and session records. Elsewhere does not ask for an email address during registration.
- **Workspace content:** chats, AI responses, conversation titles, personas, prompt templates, settings, memories, model choices, retry history and roleplay state.
- **Uploaded images:** image files plus filename, type, size, dimensions, ownership, storage key, timestamps and cached analysis associated with your question.
- **Persona market activity:** published personas and creator username, collections, favourites, ratings, reports and moderation records.
- **Web-search data:** the search query derived from your current message, selected result links and snippets when you turn on web search.
- **Technical and security data:** session identifiers, request identifiers, routes, response status and timing, account username for signed-in requests, and IP-based rate-limit information held temporarily in memory.
Account Data: Username, email (optional), hashed password
Please avoid putting sensitive personal data into chats or images unless it is genuinely necessary for your use of the service.
Chat Data: Messages you send and the AI responses
All data is processed to provide your chat history and account functionality.
## 3. How and why we use data
3. Legal Basis (GDPR)
We use personal data to:
For EU/EEA users, we process data based on:
- create and secure your account, based on performance of our contract and legitimate interests in security;
- provide chats, personas, uploads, exports and settings, based on performance of our contract;
- run optional AI, image and search features at your request, based on performance of our contract;
- operate and moderate the persona market, based on performance of our contract and legitimate interests in a safe public space;
- prevent abuse, diagnose faults and maintain reliability, based on legitimate interests in security and service operation; and
- meet legal obligations and establish, exercise or defend legal claims where necessary.
Contract performance (to provide your account and chat history)
We do not use your data for targeted advertising and do not sell it. Elsewhere does not make decisions about you that produce legal or similarly significant effects solely by automated means.
Legitimate interests (system security, fraud prevention)
Your data will not be processed for marketing without explicit consent.
## 4. AI models, image analysis and web search
4. How We Use Data
To generate a reply, Elsewhere sends your current message and relevant conversation context to the configured model backend. Depending on your settings, this may also include persona instructions, conversation summaries, stored memories, selected web results and analysis derived from images. The final chat model does not receive image files directly; a separate configured vision model receives the image and your question to produce an analysis.
Your data is used to:
If you enable web search, Elsewhere sends a query based on your current message to the configured SearXNG service. The service may pass that query to search engines enabled by its operator. It does not receive your full conversation, account password or persona profile from Elsewhere.
Authenticate and manage your account
The deployment operator chooses and hosts or configures these services. Their location and sub-processors can therefore vary by deployment. Contact us if you need current information about the providers used by this instance.
Store and retrieve chat history
## 5. Public persona features
Improve and maintain the app
Your chats, uploads and private personas are not public by default. If you publish a persona, its profile fields and your username become visible in the public market along with aggregate usage, favourite and rating information. Reports are available to administrators for moderation.
We do not sell your data.
You can unpublish a persona. A private copy previously collected by another user is separate and is not automatically removed when the original is unpublished or your account is deleted.
5. Data Retention
## 6. When data is shared
We retain data as long as your account is active. If you request deletion, your data will be deleted unless we must retain it for legal reasons.
We disclose personal data only as needed:
6. Data Transfers
- to the configured model and search services when you use those features;
- to infrastructure providers that host or support the application under appropriate safeguards;
- to other users when you intentionally publish a persona;
- when required by law, a valid legal process or to protect rights, safety and service security; or
- as part of a service reorganisation, with notice and appropriate protection where required.
Your data may be stored or processed where our servers reside. Switzerland has an adequacy decision with the EU, meaning transfers can occur without additional safeguards.
## 7. Cookies and local storage
7. Your Rights (GDPR + Swiss rights)
Elsewhere uses an essential, HTTP-only session cookie to keep you signed in. It expires after the configured session period or when invalidated. The browser also stores appearance and interface preferences locally on your device. These technologies are used for service functionality, not advertising or cross-site tracking.
Depending on jurisdiction, you may have the right to:
## 8. How long data is kept
Access your data
- **Account and workspace data** remain until you delete individual items or your account.
- **Temporary, unattached uploads** are scheduled for deletion after 24 hours. Images attached to a message remain with that conversation.
- **Session records** expire according to the configured session lifetime and can be invalidated from Settings.
- **Operational logs and in-memory rate-limit records** are kept only as long as reasonably needed for security, diagnosis and operation.
Correct inaccuracies
Deleting your account removes its workspace, attached files and published market entries from the active service. Deletion from backups or queued file cleanup may take additional time. We may keep limited records longer where required by law or necessary to establish, exercise or defend legal claims.
Request deletion
## 9. International transfers
Restrict or object to processing
Data may be processed outside your country when infrastructure, model or search providers are located elsewhere. Where required, we rely on a legally recognised transfer mechanism, such as an adequacy decision or appropriate contractual safeguards. Contact us for details relevant to the current deployment.
Request data portability (GDPR)
## 10. Security
To exercise these rights, contact us at: kriscerni@gmail.com
We use reasonable technical and organisational measures designed to protect personal data, including hashed passwords, HTTP-only same-site session cookies, same-origin request protection, access checks for chats and attachments, upload validation and rate limiting. No system is completely secure, so please use a unique password and do not share it.
8. Data Security
## 11. Your choices and rights
We implement reasonable technical and organisational measures to protect your data — encryption for passwords and secure database access.
Depending on the law that applies to you, you may have the right to request access, correction, deletion, restriction, portability or an objection to certain processing. You may also withdraw consent where processing relies on consent, without affecting earlier lawful processing.
9. Changes to this Policy
You can export your workspace and delete your account directly in Settings. For other requests, email [kriscerni@gmail.com](mailto:kriscerni@gmail.com). We may need to verify your identity before completing a request.
We may update this document. Changes will be posted with a “Last updated” date.
You may lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) or, where the GDPR applies, your local data protection authority. We encourage you to contact us first so we can try to resolve the concern.
## 12. Changes and contact
We may update this policy when the service, providers or applicable requirements change. We will post the new version, change the date above and provide additional notice for material changes where appropriate.
Questions or requests can be sent to [kriscerni@gmail.com](mailto:kriscerni@gmail.com).