FactPrism Ltd ("FactPrism", "we"), company number 17563839, registered office 26 Gowering Way, Abingdon, OX14 1ZH, United Kingdom, is the controller of the personal data described here. Contact: support@factprism.com. [dpo or uk representative if required]
1. What we collect
| Data | Why | Lawful basis (UK/EU) |
|---|---|---|
| Your Apple sign-in identifier, and a keyed hash of the email Apple shares (we don't store the address itself) | To create and secure your account | Contract |
| A device security key (Apple App Attest) and a keyed device fingerprint | To protect accounts and enforce device limits | Legitimate interests (security, fraud prevention) |
| Purchase records from Apple (transaction ids, product, dates) | To give you what you paid for | Contract |
| Your questions to IRIS and the answers we deliver | To answer them, and to keep a record of what we delivered | Contract; legitimate interests (record-keeping) |
| Usage: companies opened, exports, credits used | To run limits and fair use, and to plan capacity and cost | Contract; legitimate interests |
| The country your connection comes from (we don't store your IP address) | Security monitoring | Legitimate interests (security) |
| Access records: the invitation you used, and if you joined through an organisation, which one and when. Also a keyed hash of the email address an invitation was sent to | To control who can use PRISM, and to manage organisation seats | Contract; legitimate interests |
We do not collect your name, contacts, location beyond country, or any bank or brokerage details. We do not ask about your finances or investment goals.
2. What we don't do
- We don't sell personal data, or share it for advertising.
- We don't track you across other apps or websites.
- We don't put your personal data into AI prompts. The AI models receive company filings and the text of your question, not your identity.
3. Who we share with
We share data only with service providers who process it for us under contract:
- hosting and database: [hosting provider];
- AI model providers, which receive only filings and question text: [AI model providers];
- Apple, for sign-in, purchases and App Attest.
If you joined through an organisation, we may tell that organisation whether you've accepted its invitation and are an active member. We don't share your research activity with it. [legal: confirm what is shared with organisation customers]
We may also disclose data where the law requires it.
4. International transfers
[transfer mechanism]
5. How long we keep it
- Account data (identifiers, sessions, devices, balances) is kept while your account is open and deleted when you delete your account.
- Purchase records are kept for as long as tax and accounting law requires ([number of years]).
- Security logs are kept for [number of days]. After an account is deleted, the logs keep only a tombstone, with no personal identifiers.
- Research records (the answers and reports we delivered, with their sources) are kept after your account is deleted, in pseudonymous form. They are no longer linked to you. We keep them so we can show exactly what PRISM said and on what evidence. [legal: confirm retention period and basis]
- Device fingerprints are kept in keyed-hash form after deletion, so device limits can't be reset by deleting and re-creating an account. [legal: confirm period]
6. Your rights
Depending on where you live, you can ask to access, correct, delete, restrict or port your data, and object to processing based on legitimate interests. Email support@factprism.com. You can delete your account in the app at any time (Account → Delete account). In the UK, you can complain to the ICO (ico.org.uk). In the EU, you can complain to your local supervisory authority.
7. Security
Data is encrypted in transit and at rest. Secrets are kept in a managed secret store, and access is logged.
8. Children
PRISM is not directed at children under 13 (16 in some EU countries), and we don't knowingly collect their data.
9. Changes
We'll post updates here, and tell you in the app about material changes.