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anatome Platform — Privacy Policy (v0.1, draft)

Who this is for: API customers (apps building on platform.anatome.dev). ChatGPT / personal accounts: the policy that governs you is https://anatome.dev/privacy — NextSolutions is the controller there, including Article 9(2)(a) explicit consent for health-adjacent body metrics. Status (this API-customer document): Draft, pending review by a qualified attorney. Source Markdown: /privacy?format=md.

1. Who we are

anatome is operated by NextSolutions. We are a data processor for the data our customers (app developers) submit via the API on behalf of their end-users, and a data controller only for the minimal operator data (your developer account email, billing, usage aggregates).

2. What we collect

• Operator data: your email (dashboard login), app name, API key metadata, billing info. Used to operate your account.
• Customer app data: whatever you choose to send via per-user endpoints (workouts, meals, body metrics, supplement logs, etc.). This is submitted by the app you authorized and is isolated per app_id + app_user_id via Postgres Row-Level Security. We do not read it except to operate + secure the Service.
• Request metadata: endpoint, method, status, timestamp, IP, user-agent, request id, RapidAPI subscriber id (if applicable). Used for rate-limiting, quota enforcement, abuse detection, and debugging. Retained 90 days at per-request granularity, then aggregated (see TOS §5).
• AI usage: model, token counts, cost. Used for billing. The content of AI prompts/responses is NOT stored beyond the response returned to you.

3. Lawful basis (GDPR)

• Operator data: contract (Art 6(1)(b)) + legitimate interest (Art 6(1)(f)) for operating the Service.
• Customer app data: we process it as your data processor under Art 6(1)(b) (your contract with us). You are the controller for your end-users' data and are responsible for your own lawful basis + privacy disclosures to them. Where that data is health data (GDPR Art. 9), you must have an Article 9 condition (typically explicit consent) before sending it here.
• Request metadata: legitimate interest (Art 6(1)(f)) for security, rate-limiting, and debugging.

4. Your rights (GDPR Articles 15–20)

You can access, rectify, or port your operator data via the dashboard. For end-user data you submitted via per-user endpoints, use the corresponding DELETE endpoint (see TOS §5 for the 30-day rollback + hard-delete sweep). To exercise other rights, email support@anatome.dev.

5. Data retention

See TOS §5. Summary: request logs 90d → aggregated; inactive demo accounts 60 days without key activity → may be hard-deleted; deleted user data 30d rollback → hard-deleted; backups purged on next rotation; idempotency cache 24h.

6. Sub-processors

• OpenRouter — AI model routing. Receives only the prompt content for AI endpoints, not your stored data. https://openrouter.ai/privacy
• Cloudflare — edge proxy + DDoS protection for the federated exercise API. Receives request metadata. https://www.cloudflare.com/privacypolicy/
• RapidAPI (if you subscribe via RapidAPI) — billing + subscription management. Receives your RapidAPI subscriber id. https://rapidapi.com/legal/privacy-policy
• Stripe (paid plans) — payment processing. Receives billing info. https://stripe.com/privacy
• Hetzner — server hosting in Falkenstein, Germany.

We do not sell your data. We do not use your data to train AI models.

7. International transfers

Data is processed in the EU (Hetzner Falkenstein) + US (Cloudflare). Transfers are under Standard Contractual Clauses where required. If you self-host, no transfer occurs.

8. Security

Postgres RLS per app_id/app_user_id. API keys are SHA-256 hashed (we store only the hash). Constant-time compares for admin tokens. Rate-limiting per key. Scoped keys (read/write/ai/ users/admin). Bound keys (bound_app_user_id) for per-user isolation. The cross-tenant isolation is covered by an automated test run before every deploy.

9. Self-hosting

There is no self-hosted edition of this platform, so NextSolutions is always the processor for data held here. The exercise/anatomy wiki at wiki.anatome.dev is a separate, Apache-2.0 product with its own storage and its own privacy terms; this policy does not describe it. If you self-host that wiki, this policy does not apply to your instance — publish your own.

10. Contact

support@anatome.dev. We have not appointed a Data Protection Officer; privacy questions go to that address. Do not use dpo@anatome.dev — that mailbox is not staffed.