PRIVACY POLICY
Effective Date: August 7, 2025
Last Updated: August 7, 2025
1. DATA CONTROLLER INFORMATION
Company: X42 SRL
BCE/KBO Number: 0660 783 004
Registered Address: Rue Paul Devigne 72, 1030 Schaerbeek, Belgium
Privacy Contact: privacy@alfredupskilling.com
Website: alfredupskilling.com
2. DATA WE COLLECT
2.1 Information You Provide
- Account Information: Email address, name
- Professional Information: Current role, company name, professional goals
- Communication Data: Messages and interactions with our AI coaching system
2.2 Automatically Collected Information
- Authentication Data: Magic link tokens (temporary)
- Usage Data: App interactions, feature usage patterns
- Technical Data: Device type, operating system, app version
3. LEGAL BASIS FOR PROCESSING
We process your personal data based on:
- Consent: For optional features and communications (Article 6(1)(a) GDPR)
- Contract Performance: To provide our coaching services (Article 6(1)(b) GDPR)
- Legitimate Interests: For service improvement and security (Article 6(1)(f) GDPR)
4. HOW WE USE YOUR DATA
We use your information to:
- Provide personalized professional coaching services
- Authenticate your access to the app
- Improve and optimize our AI coaching algorithms
- Ensure the security and integrity of our services
- Communicate service updates and important information
5. DATA SHARING AND PROCESSORS
5.1 Third-Party Processors
We use the following carefully selected processor:
- Supabase Inc.: Database hosting and authentication services (EU servers)
5.2 Data Transfers
All personal data is processed and stored within the European Union. We do not transfer your data outside the EU.
6. DATA RETENTION
During beta testing, we retain your data for the duration of your participation. Post-launch retention periods will be:
- Active Accounts: Duration of account plus 30 days after deletion
- Authentication Logs: 90 days
- Support Communications: 2 years
7. DATA SECURITY
We implement appropriate technical and organizational measures including:
- Encryption: AES-256 encryption at rest, TLS 1.2+ in transit
- Access Control: Row-level security and role-based access
- Authentication: Secure magic link authentication
- Infrastructure: SOC 2 compliant hosting infrastructure
8. YOUR RIGHTS
Under GDPR, you have the right to:
- Access: Request a copy of your personal data (Article 15)
- Rectification: Correct inaccurate data (Article 16)
- Erasure: Request deletion of your data (Article 17)
- Restriction: Limit processing of your data (Article 18)
- Portability: Receive your data in a portable format (Article 20)
- Object: Object to certain processing activities (Article 21)
- Withdraw Consent: Where processing is based on consent
To exercise these rights, contact: privacy@alfredupskilling.com
9. COOKIES AND TRACKING
We use only essential cookies required for:
- Authentication: Maintaining your logged-in session
- Security: Preventing unauthorized access
No marketing or analytics cookies are currently used.
10. CHILDREN’S PRIVACY
Alfred AI is intended for professional use. We do not knowingly collect data from individuals under 16 years of age. Users must be at least 16 years old to use our services.
11. AUTOMATED DECISION-MAKING
Our AI coaching system provides personalized recommendations but does not make automated decisions with legal or similarly significant effects. All coaching suggestions are advisory only.
12. COMPLAINTS
You have the right to lodge a complaint with the Belgian Data Protection Authority:
Autorité de protection des données (APD)
Rue de la Presse 35, 1000 Brussels
contact@apd-gba.be
+32 2 274 48 00
13. CHANGES TO THIS POLICY
We will notify you of any material changes to this Privacy Policy via email or in-app notification. Continued use after notification constitutes acceptance of the updated policy.
14. CONTACT US
For any privacy-related questions or concerns:
Email: privacy@alfredupskilling.com
Address: X42 SRL, Rue Paul Devigne 72, 1030 Schaerbeek, Belgium
This Privacy Policy is available in French and Dutch upon request.