01Introduction
Your privacy matters to us. This Policy explains how Madless ("we", "our", "us") collects, uses and safeguards personal information when you interact with our website, web application, and API (collectively, the "Services").
The data controller is Havetobe Limited (trading as Madless), a company registered in England and Wales under company number 17255387, with registered office at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom. Havetobe Limited is registered as a data controller with the UK Information Commissioner's Office (ICO) under registration number ZC195618; our entry is on the public register at ico.org.uk. You can reach us about anything in this Policy at [email protected].
02Information We Collect
2.1Account Data
- Email address, display name, and profile photo.
- Authentication tokens (managed by Google Cloud — we use passwordless email verification and do not store passwords).
- Space and role membership.
- API keys you create for programmatic access.
2.2User Content
Content you create, upload, or share through the Services, including but not limited to:
- All user-generated content you create within the platform (concepts, pages, files, concept history).
- Drive files of any type, along with file metadata (name, size, type).
2.3Usage Data
- Log files, IP address, browser type, and pages visited. IP addresses may be stored in session records for security purposes.
- Feature usage (e.g. which modules you access, actions taken) for rate limiting and platform integrity.
- Page views and performance metrics (page load times, Core Web Vitals) collected via Cloudflare Web Analytics — cookieless, no fingerprinting, and no personally identifiable information included.
2.4Billing Data
Payment information (card details, billing address) is collected and processed directly by Stripe. We do not store or access your card details. Stripe provides us only with subscription status and invoice history to manage your account.
2.5AI-Processed Data
Artificial intelligence is used in two places, and only two: when something enters your space, and when you ask a question. The following content may be sent to our AI providers (see Section 6) for processing:
- When you keep something — its text is sent to Cohere to generate semantic embeddings, which power search and candidate connections for you to review. Nothing is added to your space until this succeeds.
- Images and video frames you keep — sent through Vercel AI Gateway to a selected inference provider to generate a description, recognised items, and in-image text (OCR). Madless may use Anthropic, OpenAI, or Alibaba Cloud for this processing. This is a condition of the file entering your space, not an optional enrichment added later.
- Audio and video you record or keep — sent directly to xAI for transcription (speech-to-text), likewise before the item enters your space. This transcription does not pass through Vercel AI Gateway.
- When you ask a question — the question, and the excerpts of your own material that search retrieved for it, are sent through Vercel AI Gateway to a selected inference provider to compose an answer and again to check each claim against those excerpts. Madless may use Anthropic, OpenAI, or Alibaba Cloud. Nothing is sent unless you asked.
We keep the answer and the record of which of your own material it was built from. We do not build or store a profile, a personality model, or any other interpretation of you, and nothing reads your content on a schedule to form conclusions about you in the background. Your content is never used to train AI models. Our AI providers are contractually prohibited from using your data for model training or any purpose other than processing your request.
03How We Use Information
- Provide, maintain, and improve the Services.
- Authenticate your identity and enforce access control.
- Process payments and manage subscriptions.
- Respond to your requests and support queries.
- Enforce rate limits and prevent abuse.
- Run trust and safety checks to keep the platform safe for all users (see Section 9).
- Send transactional emails (e.g. magic sign-in links, security alerts). You may not opt out of these.
- Read what you keep so it can be searched, cited and answered from, and answer the questions you ask (see Section 2.5).
- Send occasional product updates (you may opt out at any time).
Lawful bases for processing
Under the UK GDPR we rely on the following lawful bases:
- Performance of a contract — to create your account, provide the Services, and process your billing.
- Legitimate interests — to keep the platform secure, prevent abuse and fraud, run trust-and-safety checks, and improve the Services. We balance these interests against your rights and freedoms.
- Consent — for optional processing such as product-update emails, which you can withdraw at any time.
- Legal obligation — to comply with applicable law, including tax, accounting, and lawful requests from authorities.
06Third-Party Services
We use the following third-party services to operate our platform:
| Service | Purpose |
|---|---|
| Google Cloud | Infrastructure, authentication, database, and the nightly backup of every file you upload. |
| Cloudflare | Object storage (R2) — the live copy of the files you upload, stored in Cloudflare’s EU jurisdiction, which guarantees the bytes stay at rest in the European Union. Cloudflare is also the front door to Madless: it serves every page and blocks attacks before they reach us. And it counts page views, through Web Analytics — without cookies, without fingerprinting, and without following you anywhere. That is why Madless has no cookie banner, and why there is no Google tracking script on this site. |
| Google Cloud Vision | Image safety scanning (SafeSearch) and PDF text extraction (OCR) only — not used to describe image content. |
| Upstash | Rate limiting and caching (stores only hashed identifiers, never personal data). |
| Vercel AI Gateway | Routes image-reading and answer-generation calls to a selected inference provider. Operates with zero data retention; your content is not stored at the Gateway layer. Audio and video transcription does not pass through the Gateway. |
| Cohere | AI processing — semantic embeddings used for search and for candidate connections you review, called directly. Cohere is contractually prohibited from using your content for model training. |
| xAI | AI processing — audio and video transcription (speech-to-text), called directly rather than through Vercel AI Gateway. Receives the audio track you record or upload and is prohibited from using your content for model training. |
| Anthropic, OpenAI, or Alibaba Cloud | Gateway-routed AI processing — Madless may select one of these providers to describe images and video frames as material enters your space, or to compose and check an answer when you ask a question. The provider receives only the content needed for that request and is prohibited from using it for model training. The exact model may change without changing the purpose of processing. |
| Voyage AI | AI processing — reranks semantic search results for relevance, including the retrieval behind an answer. Receives your search query and candidate concept text. Opted out of model training (zero-day retention). |
| Postmark | Transactional email delivery (sign-in links, security alerts). |
| Stripe | Payment processing and subscription management. |
| Sentry | Error monitoring and performance diagnostics (no personal data beyond user ID for correlation). |
| Vercel | Hosting and deployment. |
These providers are contractually bound to protect your data and process it only on our behalf.
6.1Services you connect
The services above are ours. This section is about services that are yours — the accounts you already have elsewhere, which you can connect to bring your own material in.
You can connect mymind, X, Are.na, Readwise, Apple Music, Spotify, Pinterest, or Raindrop. When you do, we store the access credential that service issued to you, encrypted at rest, and we use it for nothing except the imports you ask for. Obsidian and browser bookmarks work differently: you export a file from your own machine and upload it, so no account is connected and no credential is stored.
- We only read. Madless never posts, writes, edits, deletes, or follows anything on a service you connect, and never requests permission to.
- We only read what you picked. You choose each board, channel, playlist, or collection before anything is fetched, and only those are read.
- Nothing runs in the background. Every import is one you started. Madless never reads on a schedule and never goes back on its own — bringing in what is new means asking again.
- Disconnecting deletes the stored credential immediately. We stop being able to reach that service at all, and what you already imported stays yours in your space.
- What we fetch is used only to perform your import, for you. It is never combined with another person’s data, never used for advertising, never sold, and never shared with anyone.
What you import becomes part of your space, under exactly the same rules as everything else you keep — including the processing described in Section 2.5, which is how material becomes readable and searchable, and your rights in Section 12.
07Data Residency
What you keep — the mind itself and its files — and every backup of it are stored in the United Kingdom and the European Union, and nowhere else. There is no location to choose. What sits outside that promise is your account, not what you keep: signing in, billing and email are handled by providers in Section 6 — Google’s Firebase Authentication (a global service), Stripe and Postmark — and are not held to this location; where each one operates is on our Sub-processors page.
- The database and every backup are in the United Kingdom (London). Your concepts, pages, connections, concept history, and the questions you asked with their answers — the mind itself — are stored in one database in London. Backups are encrypted, in Google Cloud Storage in London: your files are mirrored nightly, and the database is snapshotted at least weekly with continuous point-in-time recovery behind it.
- The live copy of your files is in the European Union. The working copy of what you upload — images, video, audio, PDFs, everything in your drive — is stored in Cloudflare R2 under Cloudflare’s EU jurisdiction: a contractual guarantee that the bytes stay at rest in the European Union. The application servers that handle your requests run from the United Kingdom.
7.1International Transfers
Where Personal Data is transferred outside the United Kingdom we rely on the following safeguards:
- For transfers to the United States: the UK Extension to the EU–US Data Privacy Framework where the receiving entity is self-certified.
- For file storage in the European Union (Cloudflare, Inc.): the UK International Data Transfer Agreement (IDTA) or the EU Standard Contractual Clauses (SCCs) as supplemented by the UK Addendum. Files are held in Cloudflare’s EU jurisdiction, which contractually keeps them at rest inside the European Union.
- Where the Data Privacy Framework does not apply, including for an AI provider that is not eligible or self-certified: the UK International Data Transfer Agreement (IDTA) or the EU Standard Contractual Clauses (SCCs) as supplemented by the UK Addendum.
- Additional safeguards required by Data Protection Laws (encryption in transit, encryption at rest, scoped access controls).
The current list of sub-processors and the locations they operate in is on our Sub-processors page. Customers who need a data processing agreement can review our Data Processing Agreement.
08Logging & Security Monitoring
For security and debugging purposes, we maintain the following:
- Structured application logs for error monitoring and debugging (via Sentry).
- Session records that include login timestamps, device information, and IP addresses for security purposes.
- Rate limit violation tracking to detect and prevent abuse.
These records are retained only as long as necessary for their stated purposes — typically up to 90 days, and longer only where needed to investigate a specific incident or to meet a legal obligation.
09Trust & Safety
To keep the platform safe, we perform automated content moderation:
- Uploaded images are scanned for harmful content using Google Cloud Vision SafeSearch.
- Uploaded documents (PDF, DOCX) have text extracted for automated blocklist matching.
- User-generated content is periodically scanned against configurable blocklist patterns.
- Flagged content is reviewed internally. We may take action including content removal or account suspension.
These scans are automated and do not involve human review unless content is flagged at a high or critical severity level.
User reports and serious flags may be preserved under a legal hold so that evidence is not destroyed during review. Where the law requires it, we may disclose flagged content and relevant account, technical, and evidence information to the National Crime Agency, law enforcement, regulators, or an equivalent competent authority. Access is restricted to what is necessary for safety, investigation, and compliance.
10Backups & Data Retention
- Automated backups of your data are stored encrypted in Google Cloud Storage in London: every file you upload is mirrored nightly, and the database is snapshotted at least weekly with continuous point-in-time recovery behind it.
- A space that has been put to sleep for long inactivity (possible on some free tiers) is skipped by the backup runs while it sleeps: the backups it already has are kept, but nothing new is backed up until the space wakes.
- Deleted content is soft-deleted (moved to trash) and permanently purged after 30 days.
- Account data is retained for as long as your account is active. Upon account deletion, all personal data is removed within 30 days, except where retention is required by law.
- Security logs are retained only as long as necessary for their stated purposes.
11Security
We implement administrative, technical, and physical safeguards to protect data, including:
- Encryption in transit (TLS) and at rest (via Google Cloud Platform defaults).
- Principle-of-least-privilege access controls with role-based authorization.
- CSRF protection, rate limiting, and Content Security Policy headers.
- API request idempotency to prevent duplicate operations.
- Webhook payload signing (HMAC) with SSRF protection.
12Your Rights
Depending on your jurisdiction, you may have the right to:
- Access or correct your personal data.
- Request deletion ("right to be forgotten").
- Object to or restrict certain processing.
- Port your data to another service.
- Withdraw consent for optional processing.
You can do most of this yourself in Settings — export a copy of your data, edit your profile, or permanently delete your account or a space. For anything we can't put behind a button — objecting to or restricting processing, or if you've lost access to your account — email [email protected] and we'll respond within 30 days. UK and EU users hold these rights under the UK GDPR and EU GDPR.
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority, at ico.org.uk or on 0303 123 1113. We would appreciate the chance to address your concern first.
13Children
The Services are not intended for anyone under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us and we will promptly delete it.
14Changes to This Policy
We may update this Policy from time to time. We will post the revised version on this page with an updated effective date. For material changes, we will notify users via email or an in-app notice.
15Contact
Questions about this Privacy Policy, data-subject requests (UK / EU GDPR), or anything else data-protection related? [email protected].
Havetobe Limited (trading as Madless) is a small UK limited company and does not maintain a separate Data Protection Officer. Privacy queries are handled by the founder via the address above; we aim to respond within one working day and within thirty days for formal data-subject requests, as required by law.