Privacy Policy

1. Data controller

The controller responsible for processing your personal data is:

Etornie has not appointed a statutory Data Protection Officer (DPO); data-protection enquiries are handled via the contact address above. As the controller is established in Switzerland, no Swiss representative is required. Where Etornie offers services to data subjects in the EU, a representative in the Union under Art. 27 GDPR is being designated; until that appointment is recorded here, EU data subjects may use the contact address above.

2. Personal data we process

• Account data: email address, full name, phone number (optional), hashed password, and account role.
• Wallet identity: your Solana wallet address and a derived public handle, when you sign in with a wallet.
• Profile data: profile picture (optional) and notification preferences.
• Case & IP data: intellectual-property cases, trademark/patent/design details, applicant information, uploaded documents and any personal data they contain.
• Payment data: subscription and filing payment records, amounts and status. Card details are processed directly by Stripe; Etornie does not store full card numbers.
• AI assistant data: the questions, messages and files you submit to EtornieGPT and the IP agent.
• E-signature data: signer name and email when a document is sent for electronic signature.
• Technical data: log data, device/IP information, and error diagnostics necessary to operate and secure the service.

3. Purposes & legal bases

We process personal data on the following GDPR Art. 6 bases:

• Performance of a contract (Art. 6(1)(b)): creating and operating your account, managing IP cases, filing with IP offices, processing payments and signatures.
• Legal obligation (Art. 6(1)(c)): retaining financial and tax records and meeting regulatory duties.
• Legitimate interests (Art. 6(1)(f)): securing the platform, preventing fraud and abuse, and improving the service, balanced against your rights.
• Consent (Art. 6(1)(a)): optional notification emails and any non-essential processing; withdrawable at any time.

Under the Swiss FADP, processing is carried out in good faith, proportionately, and for the purposes stated at collection.

4. Blockchain & AI processing

Blockchain (Solana). Etornie records IP attestations, compliance proofs and token mints on the public Solana blockchain. Data written on-chain, including wallet addresses, transaction signatures and cryptographic commitments, is public and immutable and cannot be modified or deleted, including in response to an erasure request. Off-chain personal data linking you to on-chain records is erased on request; the on-chain artefacts themselves remain by design. We use commitments and zero-knowledge proofs to minimise the personal data exposed on-chain.

AI assistant. Prompts and documents you submit to the AI features are sent to our inference sub-processor (Together AI) to generate responses. We do not use your content to train third-party foundation models.

No automated decisions. Etornie does not make decisions producing legal or similarly significant effects about you based solely on automated processing, including profiling (GDPR Art. 22 / FADP Art. 21). The AI assistant is advisory; case decisions are made by people.

5. Sharing & sub-processors

We share personal data with the processors below, each bound by a data-processing agreement, and with intellectual-property offices (e.g. EUIPO, UKIPO) where you instruct us to make a filing. We do not sell personal data.

We update this list as our processors change.

6. International transfers

Where personal data is transferred outside Switzerland or the EU/EEA (e.g. to US-based sub-processors), we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses together with the Swiss addendum recognised by the Federal Data Protection and Information Commissioner (FDPIC), or an applicable adequacy decision.

7. Retention

We keep personal data only as long as necessary for the purposes above. Account and case data are retained for the life of your account; financial records are retained for the statutory period (ten years under Swiss law, Art. 958f Code of Obligations); immutable on-chain data persists indefinitely by the nature of the blockchain. On erasure, data without a retention basis is deleted and the remaining records are anonymised.

8. Your rights

Subject to the GDPR and FADP, you have the right to access, rectify, erase, restrict and object to processing, to data portability, and to withdraw consent. Etornie provides self-service tools to export your data (right to portability) and to erase your account (right to erasure) from your profile page, subject to legal retention obligations.

You may lodge a complaint with a supervisory authority: in Switzerland, the Federal Data Protection and Information Commissioner (FDPIC); in the EU, your local data-protection authority.

9. Security

We apply technical and organisational measures appropriate to the risk, including encryption of credentials and sensitive secrets, optional two-factor authentication, antivirus scanning of uploads, access controls, and audit logging. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Cookies

Etornie uses strictly necessary cookies to keep you signed in (authentication tokens). We do not use advertising cookies. Any future analytics cookies will be subject to your consent.

11. Contact & changes

For any privacy enquiry or to exercise your rights, contact support@etornie.com. We will update this policy as our processing evolves and will indicate the effective date on publication.