1. Data Controller

Data processing is managed by Alex Zecca, publisher of the Usembic service. Contact: contact@usembic.io

2. Data Collected

We only collect data necessary for the service: • Identity: Name, surname, email address • Technical data: IP address, connection logs • Content: Documents imported for AI analysis

3. Purposes (Why we process your data)

Your data is processed for the following purposes: • Providing the backlog generation service • Managing your user account • Technical product improvement (bug fixes) • Service-related communications (notifications, updates)

4. Subprocessors and Transfers

Our subprocessors: • OVH (France): application hosting and account data • Backblaze B2 (Central Europe): storage of imported documents • OpenAI (USA): artificial intelligence processing The transfer to OpenAI (United States) is governed by Standard Contractual Clauses (SCCs) approved by the European Commission. Important note: In accordance with OpenAI API terms, your data is NOT used to train their AI models.

5. Data Retention

Your data is retained as long as your account is active. Upon account deletion, all your data (profile and documents) is permanently deleted within 30 days. Technical logs are retained for a maximum of 12 months for security and debugging purposes.

6. Your Rights

Under the GDPR, you have the following rights: • Right of access: obtain a copy of your data • Right to rectification: correct inaccurate data • Right to erasure: request deletion of your data • Right to restriction: limit the processing of your data • Right to portability: receive your data in a structured format • Right to object: object to the processing of your data You can exercise these rights simply by sending an email to: contact@usembic.io For complaints, you may contact the CNIL (French Data Protection Authority): www.cnil.fr