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Legal · Lynx Group GmbH

Privacy Notice

Version
2026-10-20.1
Effective
Not yet in effect

This is an archived version. The current version is 2026-10-21.1.

Summary of changes: Our home page, the editor and previews no longer load fonts or code libraries in your browser from Google Fonts, the Tailwind CSS CDN, jsDelivr or unpkg: we now serve these files from our own servers. The live editor's preview still uses CodeSandbox's package service. Your rights and our processing are otherwise unchanged.
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TrueOwned Privacy Notice

This notice explains how Lynx Group GmbH processes personal data when it operates TrueOwned. It replaces the Privacy Policy dated 5 July 2026.

1. Who is responsible

Lynx Group GmbH, Kaiserstuhlstrasse 2, 8154 Oberglatt, Switzerland, UID CHE-230.130.559 ("Lynx", "we", "us"), operates TrueOwned at trueowned.com and is responsible for the processing described in this notice. For privacy questions and requests, write to hello@trueowned.com or to the postal address above.

Our representative in the European Union under Article 27 GDPR is Cloudkasten GmbH (rep4eu), Seestr. 20 G, 50374 Erftstadt, Germany, https://rep4.eu. You and EU supervisory authorities can contact our representative instead of us, or in addition to us, about any matter concerning our processing of personal data.

We have not appointed a data protection officer, as neither Swiss law nor the GDPR requires one for our processing.

The Swiss Federal Act on Data Protection (FADP) applies to our processing. The EU General Data Protection Regulation (GDPR) also applies where we offer TrueOwned to businesses and their staff in the EU.

This notice covers processing for which we decide the purposes and means: our website, customer accounts, billing, support, business contacts and the security of the Service. Section 2 explains how the Service processes content on our customers' instructions.

2. Business accounts and customer websites

TrueOwned is a service for businesses, but the information it handles can still be personal data, for example about employees, sole traders, representatives, people shown in uploaded photographs, and visitors of published sites.

When we process personal data in customer website content, prompts, images, form submissions or visitor records on a customer's instructions, the customer is the controller and we act as its processor under our Data Processing Agreement (or as a subprocessor where the customer works for its own client). The operator of a published website is responsible for that site's privacy notice, lawful collection of enquiries and any visitor choices. Please contact that operator about its site or the enquiries it received; we help it respond as required.

A site exported to the customer's own hosting does not send later visitor data to us unless it uses a TrueOwned function that does.

3. What data we process and where it comes from

Account data. Name, work email address, business name, address, country, role, VAT and registration numbers, and sign-in details. We receive these from you, from your organisation's administrator and from Emorise Login, our sign-in service. If you sign in with Google, Microsoft or GitHub, we receive your name, email address and account identifier from that provider.

Billing data. Plan, invoices, transaction status and billing contact. Stripe collects and holds your card and other payment method details; we never receive or store full card details. We store only the Stripe identifiers of your customer record and subscription.

Service data. Support messages and attachments; project and website settings; prompts, text, source code, uploaded photographs and videos; generated Output; connected integrations and deployment destinations; credit and usage records. Customer content can contain personal data about people other than the account user. Where your organisation supplies information about you, your organisation is the source.

Technical data. IP address, time stamps, browser and device information, session identifiers, access and error logs, security events and the features you use. For managed sites and forms we process visitor request data and form submissions on the site operator's instructions.

Generation records. For AI actions we record the model and version, settings, references and hashes of inputs and outputs, the provider that served the request, credits charged and, for AI images and scroll videos, a provenance record of how the content was made and marked. We use these records to deliver the Service, for billing, for security and to prove the AI origin of content.

Contract records. Which version of our Terms, the DPA and this notice your organisation accepted or acknowledged, when, by whom (name and email address) and from which IP address and browser; and, for each scroll video, who confirmed holding the rights in its photographs or video, when, and the wording confirmed. We keep these records as evidence of the contract and of the licence conditions of the video models.

4. Purposes and legal bases

Purpose Data Legal basis under the GDPR
Create accounts and provide the Service you ordered Account, business contact, project and operational data Performance of a contract (Art. 6(1)(b)) where you are the contracting customer; otherwise our legitimate interest (Art. 6(1)(f)) in serving the business you work for and its authorised users
Charge for the Service and keep accounting records Billing contacts, invoices, transactions, credit ledger Performance of a contract (Art. 6(1)(b)) or legitimate interest (Art. 6(1)(f)) in administering the account; for accounting records, our legitimate interest (Art. 6(1)(f)) in complying with the Swiss Code of Obligations, and legal obligation (Art. 6(1)(c)) where EU or Member State law imposes the duty
Sign-in, security, abuse prevention and fault investigation Account data, technical logs, relevant content and incident evidence Legitimate interest (Art. 6(1)(f)) in a secure and reliable service; legal obligation (Art. 6(1)(c)) where EU or Member State law requires it
Answer support and business enquiries Contact details and correspondence Steps at your request before or under a contract (Art. 6(1)(b)); otherwise legitimate interest (Art. 6(1)(f)) in answering business correspondence
Mark AI Output and prove its origin Generation records, provenance records Legal obligation (Art. 6(1)(c)) under Article 50 of the EU AI Act; legitimate interest (Art. 6(1)(f)) in transparent AI content
Inform you about changes to the Service, prices or these documents Contact details Performance of a contract (Art. 6(1)(b))
Establish, exercise or defend legal claims and meet lawful disclosure requests Relevant account, transaction, contract and incident records Legitimate interest (Art. 6(1)(f)); legal obligation (Art. 6(1)(c)) where a binding duty applies

We do not send marketing emails, and we do not use analytics or advertising tracking. Where we rely on legitimate interests, we have weighed them against your rights; you can ask us for details. Under Swiss law, we process personal data lawfully, in good faith, proportionately, for the purposes stated here and transparently.

Personal data in customer content that we process only on a customer's instructions is governed by that customer's legal basis and our DPA; we do not reuse it for our own purposes.

5. AI features

When you use an AI feature, we send the prompt, the selected project context and the content needed for that feature to the AI provider that runs it:

  • Text, code and design (including image analysis): Anthropic Claude 5.5 models, reached through OpenRouter, Inc. (USA) and served only by Amazon Bedrock (Amazon Web Services) or Google Cloud Vertex AI (Google). Every request is restricted to zero-data-retention endpoints with data collection denied, and OpenRouter does not log prompts. Requests are processed in the United States or the EU or, when Amazon or Google serve them through a global endpoint, in another region where that provider operates.
  • Images: FLUX.1 [schnell], run by fal – Features & Labels, Inc. (USA). fal receives only the text prompt. Payload storage at fal is switched off, and fal deletes its copy of the generated image after one hour.
  • Scroll videos: LTX-2.5 (with Wan 2.2 as fallback), which we run on GPU servers of Modal Labs, Inc. (USA). Modal receives your keyframe photographs and video instructions and keeps function inputs and outputs for up to 7 days. The model authors (Lightricks, Alibaba, Google) receive nothing.

None of these providers may use your content to train their models. We do not use customer content or personal data we process for customers to train AI models. AI requests may pass automated safety checks at the provider.

Do not submit special categories of personal data (for example health data), criminal-record data, identity documents, passwords or payment secrets to AI features. This does not reduce our duties for data we actually receive.

6. Who receives data

We share personal data only as needed with:

  • the service providers listed in our provider register, which names each provider, what it does, the data it receives, its countries, its retention and the transfer safeguard;
  • independent providers you choose or use directly: Stripe for its own fraud-prevention and legal duties, GitHub when you connect your repository, Google, Microsoft or GitHub when you sign in with them, Unsplash for stock photographs, and CodeSandbox, whose package service the live editor's preview uses in your browser (Section 9);
  • professional advisers, authorities and courts where we have a legal reason; and
  • a buyer or successor in a business transaction, under appropriate safeguards and with notice to you.

Emorise Login (login.emorise.com) is our own sign-in service, operated by Lynx Group GmbH on our server in Germany. It is not a separate recipient. Your Emorise Login account also lets you sign in to other Lynx (Emorise) products with the same credentials; we use it for single sign-on and account security only. The Logto software we use for it is self-hosted, and its vendor receives no personal data.

7. International transfers

We process data in Switzerland (Lynx, remote administration) and Germany (our server at Hetzner in Falkenstein and Amazon email in Frankfurt). Switzerland and the EU recognise each other's data protection as adequate.

Some providers process data in the United States: Cloudflare (storage of uploads, generated media and backups; hosting and delivery of published sites), OpenRouter with Amazon Bedrock and Google Vertex AI (AI text, which these providers can also serve from other regions through their global endpoints), fal (AI images), Modal (scroll videos) and Stripe (payments). Stripe and Cloudflare also process data in their global networks, and Unsplash in Canada. CodeSandbox (Section 9) delivers code packages to your browser from its global network.

For each transfer we use one of these safeguards, as stated per provider in the provider register:

  • adequacy: Canada for Unsplash; certification under the EU-US and Swiss-US Data Privacy Framework for Cloudflare, Amazon Web Services, Google, Microsoft, Stripe and GitHub (checked 16 October 2026);
  • standard contractual clauses of the European Commission with the adaptations required for Swiss transfers, included in the provider's data processing agreement, for OpenRouter, fal and Modal, which are not certified under the Data Privacy Framework.

We add further protection by sending only the data a feature needs, by encrypting data in transit, by using zero-data-retention AI endpoints and by keeping provider retention short. You can ask for a copy of the safeguards at hello@trueowned.com; we may redact unrelated confidential terms.

8. How long we keep data

We keep personal data only as long as the purpose requires, and we delete it within the following maximum periods. Deletions follow a documented internal procedure and are passed on to the providers concerned.

Data How long
Account and business contact data, contract records While your account is open; after closure, deleted together with your projects (next row)
Projects, sites, uploads and generated content While your account is open. After closure: a 30-day export window, then deleted from our active systems within a further 30 days. Individual deletion requests: within 30 days
Scroll-video inputs (keyframe photographs, uploaded videos used for a render) 30 days, unless you keep them as project assets
Form submissions on managed sites Deleted with the site or the account, or earlier on the site operator's request
Generation and provenance records As long as the related content exists, then deleted with it; records needed as accounting records are kept as such
Credit ledger, invoices and other accounting records 10 years from the end of the financial year (Swiss Code of Obligations, Art. 958f)
Support correspondence 24 months after the enquiry is closed
Security and access logs 90 days at most, longer only for a specific security incident while it is investigated
Backups Overwritten or deleted within 90 days; restored data is subject to the same deletions again
Emorise Login account Until you ask us to delete it, as you may still use it for other Lynx products; your TrueOwned membership ends when your TrueOwned account is closed

If a legal hold applies, we keep only the records it covers, only for as long as it lasts. Retention at our providers is shown in the provider register.

9. Cookies and similar technologies

TrueOwned uses only technologies needed to sign you in, keep you signed in, protect forms and payments, and remember your editor state. We use no analytics, advertising or other optional tracking, so we do not ask for cookie consent.

Name Set by Purpose Duration
__Secure-trueowned.session-token trueowned.com Keeps you signed in 30 days
__Host-trueowned.csrf-token trueowned.com Protects sign-in against cross-site request forgery Browser session
__Secure-trueowned.callback-url trueowned.com Returns you to the right page after sign-in Browser session
__Secure-trueowned.state, __Secure-trueowned.pkce.code_verifier, __Secure-trueowned.nonce trueowned.com Secure the sign-in exchange with Emorise Login 15 minutes or browser session
gh_app_csrf and the GitHub connection state cookie trueowned.com Protect the connection of your GitHub account Minutes
Emorise Login session cookies login.emorise.com Keep your Emorise Login session Session, or as long as you choose to stay signed in
Stripe cookies (for example __stripe_mid, __stripe_sid) Stripe Fraud prevention on the settings pages, where you manage billing and enter payment details Up to 1 year
Browser local storage trueowned.com Remembers editor and interface state on your device Until you clear it

You can delete or block cookies in your browser; blocking the essential ones prevents sign-in.

Published customer sites are the customer's responsibility. They use self-hosted fonts and no tracking added by TrueOwned. Pages that show Unsplash photographs load them from Unsplash, which receives the visitor's IP address, browser details and the page address. Forms on managed sites use Cloudflare Turnstile to block spam. Customers who add further embeds or analytics must inform their visitors and obtain any required consent.

Our home page and the editor serve their fonts and code libraries from our own servers, also in previews: your browser does not contact Google Fonts, the Tailwind CSS CDN, jsDelivr or unpkg. Our server downloads these public files from those providers without any personal data. The live editor, both the demo on our home page and the editor in your account, runs a preview that loads the open-source code packages it runs from CodeSandbox's package service; the preview software also sends CodeSandbox its load times together with your browser's user agent. CodeSandbox receives your IP address, browser details and the names and versions of the requested packages, but no content of your projects.

10. Security

We protect personal data with measures appropriate to the risk, including encrypted connections (TLS), encryption at rest in our object storage and backups, private storage with short-lived signed links for unpublished uploads, encrypted storage of access tokens and secrets, tenant-scoped access checks, restricted staff access, multi-factor authentication for administrative accounts, and controlled deletion. Our DPA (Schedule 2) describes these measures in detail. No system is perfectly secure; please report a suspected incident to hello@trueowned.com.

11. Your rights

Subject to the legal conditions, you can ask for access to your personal data, correction, deletion, and receiving or transferring your data. Under the GDPR you can also ask us to restrict processing, and you can object at any time to processing based on our legitimate interests, on grounds relating to your particular situation. Where we rely on consent, you can withdraw it for the future. We may ask you to verify your identity or authority. Write to hello@trueowned.com or to our EU representative.

You can complain to a supervisory authority: in Switzerland the Federal Data Protection and Information Commissioner (FDPIC, https://www.edoeb.admin.ch), and in the EU the authority of your habitual residence, your place of work or the place of the alleged infringement. You do not have to contact us first.

We need account and transaction data to provide the Service and meet our legal duties; without it we cannot open an account, take a payment or run the feature you choose.

12. Automated decisions

We do not take decisions based solely on automated processing that have legal or similarly significant effects on you. Generating website content in response to your instructions is not such a decision. Automated checks may block a single request, for example when your credit balance is insufficient or a request breaks our usage limits; you can contact us to have any such block reviewed by a person.

13. Changes

We update this notice when our processing changes and will tell account holders about material changes by email or in the app. Earlier versions remain available from this page.

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