Privacy Policy
Last updated: 12 October 2026
This text exists in English and French (French version). For consumers residing in France, the French version prevails.
This policy explains what personal data PANDAPROG processes when you use Sooveryn (the website www.sooveryn.com and the server your AI client connects to), why, for how long, and what your rights are. It applies the General Data Protection Regulation (GDPR) and the French Data Protection Act.
1. Data controller
PANDAPROG, trade name of Cyril Pierron, sole trader (entrepreneur individuel, EI), RCS Meaux 751 200 155, 9 rue Carnot, 77450 Montry, France. Contact: support@sooveryn.com. We have not appointed a data protection officer: write to this address for any question.
If you entrust Sooveryn with personal data about other people as part of a professional activity, you are the controller of that processing and we act as your processor (section 12 of the Terms of Sale and Use).
2. Data we process
Sooveryn processes two quite separate things: your account data (who you are, your subscription) and your agents' memory (what your personas remember about your work). They are stored apart and never mixed. On top of that comes what the service records in order to run.
2.1 Your account
- Identity: email address, display name, password if you chose one, and the language you use the website in (French or English), so that we write to you in that language. You sign up and sign in with your address alone, through a code or a link sent by email; the password is optional. It is never stored in clear: we only keep a fingerprint of it (bcrypt), from which it cannot be recovered.
- Sign-in codes: when you ask for a code to sign up or sign in, we keep the email address entered, a fingerprint of the code and of the link we sent (never the code or the link themselves), the language of the page, where your visit came from and the IP address of the request, to check the code and limit abuse. Until the code or the link has been used, no account is created.
- API keys (access tokens): their name, their creation and last-use dates, a fingerprint of each key and an encrypted copy that lets you display it again.
- Subscription and billing: your customer and subscription identifiers at Stripe, the plan, the billing period, the status and dates of the subscription. Stripe collects and keeps, on its side, your billing details, your VAT number where applicable, your payment methods and your invoices. We never receive your card numbers.
- Emails and support: the service emails we send you (sign-in codes, password reset, confirmations, reminders, consolidation summaries, which may quote titles of your memories) and the messages you send us; when you ask for a copy of your data, the dates on which its download opens and closes, and the administrator who opened it.
- Where your account came from: when you sign up, the website that sent you to Sooveryn (its domain name only, for example reddit.com) and, if there is one, the campaign given in the link's address ("utm" parameters), as well as the first page you saw. This information is only read during your visit and is never written to your browser.
- Sooveryn Desktop beta: if you leave your email address on that app's page to be told when its beta opens, we keep that address, the language of the page and the date. This does not create an account, and the address is not tied to any account. It is optional.
This data, apart from the address left for the beta, is needed to create and use an account: without it, we cannot provide Sooveryn.
2.2 Your agents' memory
- Memories: what your personas record while you work, with the history of their versions.
- Session contexts: what a persona notes so that your next session picks up where the previous one stopped.
- Personas and skills: the ones you create, and the catalogue personas you activate.
- Projects: their names and how you group them.
- Consolidation, if your plan includes it: the proposals it makes on your memory.
Your memory is encrypted with a key specific to your account (section 3). It is only used to provide the service to you: we do not sell it, we do not look at it (except in the cases set out in section 3) and we train no AI model with it.
From your account, your agents only receive your display name, to greet you, and what your plan includes, so that they know what they can do. They never receive your email address, your billing details or your payment methods, and nothing from your account is written into their memory.
2.3 What the service records in order to run
- Usage log: for each call to Sooveryn (a tool call from your AI client or a request from the website), the date, the tool or address called, the persona and project concerned, the result, the duration, the volume of data, the IP address and the identifier of the software used (user agent). For the Consolidation option, the number of tokens and the cost of the calls to the AI model. Successful and refused sign-ins, password changes, operations on API keys, and each opening and each closing of the copy of your data, with the administrator who made them. This log never contains the text of your memories or your secrets.
- Error log: the type of technical error, a technical message and trace of limited length, the date. It never contains the content of your requests.
- Technical data: our web server logs (IP address, date, address requested) and, for each password reset request, the IP address and the browser identifier.
- Audience measurement: for each public page viewed, we add one to a counter per day, per page, per referring website and per campaign. This counter holds no IP address, no identifier and no information about your browser: it cannot be used to recognise you.
3. How your memory is protected
- The content of your memory (memories, the history of their versions, session contexts, consolidation proposals) is encrypted in our database with a key specific to your account. That key is itself protected by a master key, kept outside the database.
- To answer your requests, the server decrypts your memory in RAM. A decrypted copy may stay there in a short-lived cache, cleared after a period of inactivity.
- Because the server holds the master key, Sooveryn can technically decrypt your memory to serve you. This encryption mainly protects against theft or leaks of the database and its backups.
- Some information stays unencrypted, because the Service needs it to sort and filter without decrypting: identifiers, the persona and type of each memory, the names of your projects, counters and technical dates, and your account data.
- The personas and skills you create are protected by the same access controls, but without this per-account encryption.
- The administration interface does not show the content of other accounts' memory. No one at PANDAPROG looks at your content, except at your request, to handle a report of illegal content, or where the law requires it.
4. Why we process this data
- Providing Sooveryn: creating and managing your account, keeping your memory, personas, skills and projects, sending them to your AI client, running the website. Legal basis: performance of the contract.
- The Consolidation option, if your plan includes it: suggesting and applying consolidations of your memory. Legal basis: performance of the contract.
- Applying the limits of your plan (quotas). Legal basis: performance of the contract.
- Managing subscriptions, payments and invoices. Legal bases: performance of the contract; our legal accounting and tax obligations.
- Sending you service emails: sign-in code, password reset, confirmation of a subscription, cancellation or withdrawal, reminder before renewal, notice of a change to the terms. Legal bases: performance of the contract; our legal obligations for some of them.
- Telling you when the Sooveryn Desktop beta opens, if you left your address on that app's page, and giving you the announced offer when you sign up with that address. Legal basis: your consent, given by leaving your address; you can withdraw it whenever you like, by writing to us.
- Securing the Service, detecting abuse and fraud (for example an API key used from many IP addresses, or repeated failed sign-ins), diagnosing errors. Legal basis: our legitimate interest in protecting the Service and its users.
- Producing internal usage statistics, to size and improve the Service. Legal basis: our legitimate interest.
- Handling your requests, complaints and the exercise of your rights, and answering authorities. Legal bases: performance of the contract; our legal obligations.
We do not sell your data, we do not use it for advertising and we do not train any AI model on your content.
5. Who receives your data
Your data is only accessible to PANDAPROG and to the following providers, acting on our behalf:
- Scaleway SAS (France): hosting of our servers and database, located in France;
- Stripe Payments Europe Ltd (Ireland): payment, VAT calculation and invoices. Stripe also processes some data as an independent controller (fraud prevention, regulatory obligations), under its own privacy policy;
- an email sending and receiving provider: service emails and the support mailbox;
- Anthropic PBC (United States), only for accounts whose plan includes the Consolidation option (today, the Pro plan): extracts of your memory (contents and titles of selected memories, for example possible duplicates, old entries or groups of memories to consolidate) are sent to it so that its AI model can suggest consolidations (merging duplicates, summaries, updates, archiving). The proposals are applied to your memory automatically, or after you approve them from the Consolidation page, under the Mémoire (Memory) page. If you do not want this, write to us: we turn the Consolidation option off for your account.
We also disclose data where the law, a court decision or an authority requires it.
6. Your AI client and your AI provider
When you activate a persona from your AI client (for example Claude Code), Sooveryn sends that client the persona and the relevant part of your memory, and your client sends them to your AI provider (for example Anthropic, if you use Claude). This happens at your request, within the relationship you have with that provider, under its terms and privacy policy. We do not control what it does with them.
7. Transfers outside the European Union
Our hosting is in France. Some recipients may process data outside the European Union, in particular in the United States:
- Stripe, for some payment operations;
- Anthropic, for the Consolidation option.
These transfers are covered by the European Commission's standard contractual clauses or by the EU-US Data Privacy Framework. Transfers made by your own AI provider fall under its policy.
8. Retention periods
8.1 Your account
- Identity: as long as your account exists. If your account stays inactive for 3 years (no sign-in to the website, no use from your AI client, no ongoing subscription), we warn you by email, then delete it if we do not hear from you.
- API keys: until your account is deleted. A revoked key no longer gives access to anything, but stays on record, with its dates, as long as your account exists; to erase it sooner, write to us.
- Billing data and invoices: 10 years, to meet our accounting obligations.
- Messages exchanged with support: 3 years after our last exchange.
- Opening of the copy of your data: the latest opening, with its dates and the administrator who made it, until an administrator closes it or your account is deleted; each opening and each closing also appears in the usage log, kept as stated below.
- Where your account came from: as long as your account exists; it is erased with it.
- Address left for the Sooveryn Desktop beta: until you ask us to remove it.
8.2 Your agents' memory
- Memories, personas, skills and projects: as long as your account exists, unless it is deleted earlier. When a memory is edited or deleted, including together with the persona it belongs to, its previous version stays encrypted in its history until your account is deleted; to erase it sooner, write to us.
- Previous session contexts: 30 days.
8.3 What the service records in order to run
- Detailed usage log, including IP addresses: 90 days. Daily totals, without IP addresses, are kept as long as your account exists.
- Error log: 30 days.
- Web server logs and password reset requests: 12 months at most.
- Sign-in code requests: 24 hours.
- Visit counters: anonymous, they are kept without time limit.
8.4 Backups and account deletion
- Backups: deleted data disappears from our backups no later than 30 days after its deletion.
When your account is deleted, we erase within one month your account data, your agents' memory, your API keys and your usage totals, except what the law requires us to keep (billing).
9. Cookies and browser storage
The website sets no cookies. It only keeps, in your browser's local storage, your session token, which is strictly necessary to keep you signed in. This token stops being valid after 7 days and is erased when you sign out. This storage does not require your consent. We use no advertising. We measure the website's audience ourselves, without cookies or browser storage, using anonymous counters (see section 2).
The website's fonts are served by the website itself: no third-party service is contacted when a page is displayed.
Stripe's payment page and customer portal, operated by Stripe, may use their own cookies, in particular to prevent fraud.
10. Security
- Exchanges with the website and with our server are encrypted (HTTPS).
- Passwords are stored as fingerprints (bcrypt).
- API keys are stored as fingerprints, with an encrypted copy.
- Your memory is encrypted in the database (section 3).
- Access to our servers is restricted and protected by firewalls.
In case of a personal data breach, we notify the CNIL and, where the law requires it, the people concerned.
11. Your rights
You have the right to access, rectify, erase, restrict and port your data, and the right to object to processing based on our legitimate interest. You can also give instructions about what happens to your data after your death.
- Access and portability: on request to support@sooveryn.com, sent from your account's email address, we enable in your space the download of your account and all your memory in JSON format. It is free, whatever your plan, and we do it as soon as possible, no later than one month after your request. If you also want a copy of the personas and skills you created, or of any other data, say so in your message.
- Rectification: you change your display name and password from the Mon compte (My account) page (https://www.sooveryn.com/me/account), and your memories from the Mémoire (Memory) page; for anything else, write to us.
- Erasure: you delete from the website your skills and the personas you created, together with their memory; to erase other memories or delete your account, write to us from your account's email address.
To exercise your rights, write to support@sooveryn.com, preferably from your account's email address. We answer within one month. If we have doubts about your identity, we may ask you to prove it.
You can also lodge a complaint with the French data protection authority, the CNIL, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France (www.cnil.fr).
12. Automated decisions
We make no decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you. The limits of your plan apply automatically, as the contract provides; our abuse detection rules only raise alerts, which a person reviews.
13. Minors
You must be at least 15 years old to create an account, and an adult to subscribe to a paid plan. If we learn that an account was created by someone under 15, we delete it.
14. Changes
We may update this policy. The version in force is published on the website with its date. We notify you by email of any significant change.