MONSORA PRIVACY POLICY
This Policy explains what we do with information about you when you use Monsora. It is written to be read alongside the Monsora Terms of Service, the Acceptable Use, Content and Collection Guidelines, the Subprocessors List, the Browser Extension Privacy Notice, the Imported Cookies Confirmation, the AI Processing and Auto-Filing Notice and, where your access is provided under it, the Test Programme Terms. Terms defined in the Terms of Service have the same meaning here.
1. WHO WE ARE AND WHAT THIS POLICY COVERS
1.1. Who we are. Monsora is operated by Shanghai Shichu Culture Technology Co., Ltd., with registered address at No. 25-1 Hongcao Road, Xuhui District, Shanghai ("Monsora", "we", "us" or "our"). Where this Policy says that we are the controller of your personal data, or uses equivalent language such as business, we mean that entity.
1.2. Our representative in the European Union. Because we have no establishment in the European Union but offer the Services to users there, we would in principle appoint a representative under Article 27 of the EU General Data Protection Regulation. During the current test phase, however, we do not actively target or market the Services to users in the European Union, and any processing of the personal data of EU users is occasional and incidental to the test. On that basis we rely on the exemption in Article 27(2) of the EU GDPR and have not appointed a representative at this stage. Before EU users become part of the ordinary user base of the Services, or before we begin actively recruiting or marketing to users in the European Union, we will appoint a representative under Article 27 and publish the representative name and contact details in this Policy.
1.3. Our representative in the United Kingdom. Because we have no establishment in the United Kingdom but offer the Services to users there, we would in principle appoint a representative under Article 27 of the UK GDPR. During the current test phase, however, we do not actively target or market the Services to users in the United Kingdom, and any processing of the personal data of UK users is occasional and incidental to the test. On that basis we rely on the exemption in Article 27(2) of the UK GDPR and have not appointed a representative at this stage. Before UK users become part of the ordinary user base of the Services, or before we begin actively recruiting or marketing to users in the United Kingdom, we will, where Article 3(2) of the UK GDPR applies, appoint a UK representative and publish the representative name and contact details in this Policy.
1.4. What this Policy covers. This Policy covers the Monsora desktop application, the Monsora browser extension (the "Extension"), the cloud storage and synchronisation that form a core part of the Services, the AI Features, the command-line interface, the Monsora web application and our official website. It does not cover any third-party product or platform that you choose to use alongside Monsora, including any external image or video generation service that you use to create material before you bring that material into Monsora. Those services have their own privacy policies and we have no control over them.
1.5. What this Policy does not cover. Monsora is not available to anyone under eighteen (18), and this version contains no advertising, no sharing feature and no public pages. The desktop application is distributed only from our official website, and the Extension is distributed through the Chrome Web Store and our official website. Statements in this Policy about the absence of those things describe this version as it stands on the effective date. If any of them changes we will update this Policy in accordance with Section 17 before the change takes effect.
1.6. How to contact us. You can reach us at any time at hi@monsora.ai. Section 18.2 sets out who handles privacy requests, and Sections 14 and 15 set out how to exercise your rights.
2. WHERE YOUR DATA LIVES
2.1. Your library and where its primary copy lives. Your "Vault" is your library of imported material together with the Capsules you organise within it, including combination Capsules and the historical versions and variant branches of a Capsule. Monsora stores the primary copy of your Vault and the User Content in it in cloud infrastructure that our providers operate on our behalf, in a United States West region. Monsora also keeps a "local cache" on your device, consisting of thumbnails and a search index, so that the application is fast and works offline. The local cache is on by default, you can disable it in the settings, and it is not the primary copy of your content. Disabling the local cache does not stop your content being stored in the cloud, and it does not turn off the AI Features or product analytics.
2.2. What reaches us. Because the primary copy of your Vault is stored in the cloud, your User Content, including the files, their file names, tags, prompts, seeds, model parameters, Capsule version and lineage information and thumbnails, reaches us and the providers who store it for us. The AI Features described in Section 6 additionally transmit the material concerned to our model provider for processing, and the product analytics described in Section 5 generate usage events. The AI Features and product analytics are on by default, subject to the consent gating described in Sections 5, 6 and 8 for users in the European Economic Area, the United Kingdom and Switzerland. When you sign in, use the command-line interface, or use a feature that connects to our servers, our servers generate the access logs described in Section 3.9; and where you use the optional timestamping feature described in Section 3.7, only a cryptographic hash of your material is submitted to the timestamping provider.
2.3. Imported cookies stay on your device. The imported-cookies feature described in Section 9.2 operates locally on your own device. Imported cookies are not sent to our servers and are not recorded in our logs, telemetry or product analytics.
2.4. What this means for your requests. Because the primary copy of your Vault is in the cloud, we are able to access it to provide the Services, and we can return, export and delete it when you ask us to as described in Sections 12 and 14. We cannot, however, retrieve anything that exists only in the local cache on your device and has never been stored in the cloud; that material is under your control on your own device. If you ask us to act on material of that kind, we will tell you that we do not hold it and explain how to act on it yourself.
2.5. Uninstalling the application. Removing the Monsora application from your device does not close your account and does not delete the primary copy of your Vault stored in the cloud. Depending on your operating system, uninstalling may leave the local cache in place or remove it. To delete the content stored in the cloud, or to close your account, use the in-application deletion controls or contact us as described in Sections 12 and 18.
3. PERSONAL DATA WE COLLECT
3.1. Overview. This Section lists the categories of personal data we collect, and the source of each category. We do not buy personal data, and we do not collect personal data from data brokers, advertising networks or social media platforms beyond the limited sign-in information described in Section 3.2.
3.2. Account data. When you create an account we collect your email address, your account credentials or the sign-in identifier issued by the sign-in provider you choose, your date of birth as submitted to the age gate described in Section 16.2, your username and, where applicable, your invitation code, the devices on which you sign in together with the device identifier and login time, and the dates on which your account was created and last accessed. If you sign in using Google, we receive your email address, name and profile pictures from that provider. If you sign in using Discord we receive your email address and user name from that provider. We do not receive your password from those providers and we never ask for the password to any third-party account.
3.3. Content you store. Monsora stores the primary copy of the files in your Vault, together with the thumbnails and previews generated from them, deduplication hashes, and the associated metadata, which may include file names, tags, prompts, seeds, model parameters, Capsule version and lineage information and provenance information. We refer to all of this as your "User Content". Your User Content may itself contain personal data, including images of identifiable people, and it is entirely your choice what to place in it.
3.4. Content processed for the AI Features. The AI Features are on by default, subject to the consent gating in Sections 6 and 8. When they operate, the material submitted to them, being the images you add, images extracted on your device from any video you add (not the video files themselves), the text associated with that material, and your text or image search queries, together with the metadata needed to process them, is transmitted to our model provider as described in Section 6.
3.5. Imported cookies. Where you use the imported-cookies feature, the cookies you select are handled locally on your device as described in Section 9.2. We do not receive or store those cookies.
3.6. Extension data. Where you install and use the Extension, it operates inside your own browser to provide collection features. The Extension reads the content of a web page only when you start a collection action, and when you save an asset the relevant media file is uploaded to your Vault. It reads the address of the active tab locally to support collection, and we do not collect it as browsing history. It does not access the files stored on your device. The Browser Extension Privacy Notice describes what the Extension accesses.
3.7. Evidence Package and timestamping data. If you use the optional Evidence Package or timestamping features, we process the information needed to provide them, including the records they generate. Timestamping may involve sending limited information about your material, such as a cryptographic hash, to a third-party timestamping provider.
3.8. Product analytics. We collect a limited set of product-analytics events from the desktop application, consisting of feature-usage counts, timestamps and a small set of approved technical properties, some of which are derived from our own service logs. These events are pseudonymised, being keyed to an internal account code rather than published under your name, and we have designed them so that they never include your file names, file paths, file contents, prompts, thumbnails or any free-text from your Vault. Section 5 explains the status of these events and the choices you have over them.
3.9. Server logs. Where you connect to our servers, which happens when you use the cloud storage or the AI Features, when you sign in, or when you use the command-line interface, our servers generate standard access logs containing your IP address, the date and time of the request, the request path, the response status and basic technical information about your client. We use these logs only for the purposes stated in Section 7.
3.10. Support and enforcement records. If you contact us, or if we take action on your account under the Acceptable Use, Content and Collection Guidelines, we keep a record of the correspondence and of the action taken, including any appeal you submit and the outcome. If we are required by law to make a report about content, we keep the record described in Section 10.8.
3.11. Website data. Our official website collects the limited technical information described in Section 9.4.
4. CLOUD STORAGE
4.1. Cloud storage is a core part of the Services. The cloud storage and synchronisation described in this Section, which we call the "Cloud Services", are a core part of Monsora and not an optional add-on. The primary copy of your User Content is stored through them, as described in Section 2. You can disable the local cache on your device, but you cannot use Monsora without your content being stored in the cloud.
4.2. What we do with your content. We store your User Content so that we can return it to you, synchronise it between your own devices, generate thumbnails and previews so that your library is usable, index its metadata so that search works, generate deduplication hashes, convert file formats where that is necessary to display or return your content, and maintain backups so that your content survives a technical failure on our side. That is the whole of it. We do not publish your User Content, we do not use it to advertise or promote Monsora without your separate consent, and we do not use it to develop, train, fine-tune, evaluate or improve any artificial-intelligence or machine-learning model. Section 6.5 states this last point in full.
4.3. Private by default. This version of Monsora contains no sharing feature of any kind. There is no link sharing, no public page and no shared Capsule. Content you store is accessible to your own account only, subject to the limited internal access described in Section 13.4 and the legal disclosures described in Section 10.7.
4.4. Storage allowance. Your cloud storage is subject to a storage allowance. During the test phase the allowance is 100 GB or other capacity that we designated, and after the test phase it is 2 GB or other capacity that we designated. Reaching the allowance prevents further uploads. It does not cause us to delete anything you have already stored. Where a change to your allowance causes existing content to exceed it, we give you thirty (30) days notice, followed by a ninety (90) day grace period, after which your account enters a read-only state in respect of the excess; during and after that state you continue to be able to view, download and export all of your stored content, and we do not delete stored content by reason of the excess.
4.5. Historical Capsule versions. Each Capsule may retain historical versions to support rollback and lineage. Historical versions are retained while your account and the relevant Capsule exist. They are deleted when you delete your account, and we will give effect to a valid request to delete personal data as described in this Policy, notwithstanding any description of a version as permanent. Nothing in this Section limits any statutory right you have to erasure or deletion.
4.6. Getting your content back. You can export your User Content at any time in its original file formats together with its metadata in a structured, commonly used and machine-readable form, including while your account is in a read-only state. If you are established in the European Union or otherwise entitled to the benefit of Regulation (EU) 2023/2854, Section 14.4 explains the additional portability and switching rights that apply.
5. PRODUCT ANALYTICS
5.1. What we collect and why. We collect feature-usage counts, timestamps and a small set of approved technical properties in order to understand which parts of Monsora are used, to find defects, and to decide what to build next. Some of these properties are derived from our own service logs. This is particularly important during the test phase, which exists for that purpose.
5.2. We do not use third-party analytics or advertising tools. Monsora contains no third-party analytics software-development kit, no crash-reporting software-development kit, no advertising-network code and no cross-site or cross-app tracking technology, save that our official website uses a page-view measurement service provided by the web-hosting provider named in Section 10.2. Product-analytics events are processed on infrastructure we control. We do not sell or share this or any other personal data, and Section 15.4 makes that commitment in the specific statutory language used in the United States.
5.3. Whether analytics events identify you. We describe these events as pseudonymised rather than anonymous. They are keyed to an internal account code and stripped of directly identifying content, but they remain personal data and are given the full protection of this Policy.
5.4. Your choice in the European Economic Area, the United Kingdom and Switzerland. If you are in the European Economic Area, the United Kingdom or Switzerland, or anywhere else the law requires it, we ask for your consent before enabling product analytics or storing or reading any identifier on your device for analytics purposes, and we do not collect analytics events until you give it. You can withdraw that consent at any time in the application settings; we will then stop collecting new analytics events and stop deriving usage counts about you from our service logs, with no effect on your ability to use Monsora. Declining analytics does not degrade the product and is not treated as a reason to limit your account.
5.5. Your choice elsewhere. If you are outside those regions, product analytics are on by default and you may turn them off in the application settings at any time; we will then stop collecting new analytics events and stop deriving usage counts about you from our service logs. Disabling product analytics does not limit any other Monsora feature.
6. AI FEATURES AND YOUR CONTENT
6.1. Enabled by default, with consent gating. The AI Features are enabled by default, so that features such as semantic search work from the first time you use Monsora. There is one exception. If you are in the European Economic Area, the United Kingdom or Switzerland, we do not transmit any of your content to the AI Features until you have given the explicit consent described in Section 8.3. In every case we show you a brief explanation before your content is transmitted for the first time, and you can turn the AI Features off at any time in the application settings.
6.2. What the AI Features do. The AI Features build and run semantic search across your Vault and, at your option, generate descriptions of your images. To do this they process the images you add, images extracted on your device from any video you add (the video files themselves are not transmitted), the text associated with that material, and your text or image search queries. The search index and any image descriptions generated are stored until you disable the AI Features, delete the content concerned, or close your account.
6.3. Auto-filing. Where you import material without selecting a target Capsule, the AI Features may analyse it and propose a classification. A proposed result is presented to you for review before the material is formally filed. You can change any filing afterwards. The AI Processing and Auto-Filing Notice describes this in plain language.
6.4. Who processes it. Inference is performed by Google LLC, acting for us under contract, through the Gemini application-programming interface on a billing-enabled paid service tier. Google processes your content in order to return a result to us, and it applies its own automated safety screening to the content submitted to it, which Section 6.8 describes. On the paid tier we use, Google does not use your prompts or the responses to improve its products.
6.5. No model training. We do not use your content to develop, train, fine-tune, evaluate or improve any artificial-intelligence or machine-learning model. Under the terms of the paid Gemini service we use, Google does not use the prompts you submit or the responses it returns to train, fine-tune or improve its general-purpose models. If that position ever changes, we will tell you before the change takes effect, and you will be able to stop using the AI Features and continue using the rest of the service. This commitment concerns training. It is separate from the abuse-monitoring retention by the provider, which Section 6.8 addresses.
6.6. No human review by us. We do not review the content you submit to the AI Features. Our internal access to content is limited to the narrow circumstances described in Section 13.4.
6.7. Automated results are suggestions. The AI Features produce suggestions. They do not make any decision about you, your account or your access to Monsora. No decision producing legal effects concerning you or similarly significantly affecting you is made by solely automated means. Enforcement decisions under the Acceptable Use, Content and Collection Guidelines are made or reviewed by a person.
6.8. Screening, retention and location at the model provider. Google applies its own automated safety screening to the content we send it, in order to detect illegal and prohibited material, and it may use a limited amount of authorised human review as part of that screening. Google keeps abuse-monitoring logs, which may include the prompts, the surrounding context and the outputs, for up to fifty-five (55) days, after which it deletes them. Content may be processed, and those logs held, in a country other than the one in which you are located. Our Subprocessors List states the current retention period and the current processing locations. If you are in the European Economic Area, the United Kingdom or Switzerland, you should assume that every use of the AI Features involves a transfer of the content you submit out of those regions, whether or not that content is flagged, and the safeguards described in Section 11 apply to every such transfer. If you would prefer that none of your content is subject to this screening or to that transfer, turn the AI Features off; the rest of the service remains fully available to you.
7. WHY WE USE YOUR PERSONAL DATA, AND OUR LEGAL BASES
7.1. How to read this Section. For each purpose we state what we use, why, and the legal basis on which we rely if you are in the European Economic Area, the United Kingdom or Switzerland. If you are elsewhere, the legal-basis statement does not apply to you but the purposes do, and we use your personal data only for the purposes listed.
7.2. To give you an account and let you sign in. We use your account data to create and maintain your account, authenticate you and secure access. Our legal basis is performance of our contract with you.
7.3. To operate core cloud storage. We use your User Content and account data to store, synchronise, index, display and return your content as described in Section 4.2. Our legal basis is performance of our contract with you.
7.4. To operate the AI Features. We use the content you submit to those features, and the metadata needed to process it, to produce the result you asked for and to provide semantic search. If you are in the European Economic Area, the United Kingdom or Switzerland, our legal basis is your consent under Article 6(1)(a) of the GDPR, and where the content includes special-category data, your explicit consent under Article 9(2)(a) as described in Section 8.3.
7.5. To keep Monsora secure and available. We use server logs, account data and technical information to detect, investigate and prevent unauthorised access, abuse, fraud and technical failure, and to restore service. Our legal basis is our legitimate interest in the security and integrity of the service, and compliance with our legal obligations where a specific obligation applies.
7.6. To improve Monsora. We use product analytics to understand feature usage and prioritise development. Where you are in the European Economic Area, the United Kingdom or Switzerland, or where the law otherwise requires consent for the storage of or access to information on your device, our legal basis is your consent, which you can give or withhold separately and withdraw at any time. Elsewhere, our legal basis is our legitimate interest in improving a product you use, and you can still turn analytics off.
7.7. To communicate with you. We use your email address to send service messages about your account, the test phase, security matters and changes to this Policy or the Terms of Service. Our legal basis is performance of our contract with you and our legitimate interest in keeping you informed. This version involves no marketing email. If we introduce marketing email we will ask for your consent first where consent is required.
7.8. To enforce our terms and keep users safe. We use account data, support records and, where strictly necessary, the limited content access described in Section 13.4 to investigate reports and enforce the Acceptable Use, Content and Collection Guidelines. Our legal basis is our legitimate interest in a lawful and safe service, compliance with our legal obligations, and in the case of the reporting obligation described in Section 10.8, compliance with a legal obligation and the substantial public interest in the protection of children.
7.9. To comply with law and to establish or defend legal claims. We use whatever personal data is strictly necessary for these purposes. Our legal basis is compliance with our legal obligations and our legitimate interest in establishing, exercising or defending legal claims.
7.10. Change of purpose. If we need to use your personal data for a purpose that is not listed here, we will update this Policy under Section 17 and, where the law requires it, ask for your consent before we do so.
8. SENSITIVE INFORMATION
8.1. Adult material. The Terms of Service and the Acceptable Use, Content and Collection Guidelines permit you to keep lawful adult material in your Vault for your own private use. Because the primary copy of your Vault is stored in the United States cloud infrastructure described in Section 2, such material is uploaded to and stored there, and disabling the local cache on your device does not prevent that upload. Where such material reveals information about your sex life or sexual orientation it is special-category data in the European Economic Area, the United Kingdom and Switzerland, and sensitive personal information in several United States jurisdictions, and we treat it accordingly. We do not use it for any purpose other than operating the features you use, and we do not use it to build any profile of you. Where such material is submitted to the AI Features, the provider-side screening and retention described in Section 6.8 applies to it.
8.2. Images of people. Material you bring into Monsora may contain images of identifiable people, including yourself and others. Where you store that material or submit it to the AI Features, we process it in order to provide those features and for no other purpose. We do not use your User Content, and we do not instruct our model provider, to identify any person, to recognise or match faces, or to group content by the people who appear in it, and we do not create any face geometry, face template or other biometric identifier from your User Content for the purpose of identifying or distinguishing any person. The AI Features are not designed to infer health conditions or other sensitive characteristics from a person’s appearance. If we introduce a feature that would do any of these things, we will first update this Policy under Section 17 and ask for any consent that applicable law requires before that feature is enabled for you.
8.3. Explicit consent for the AI Features. Because content submitted to the AI Features may contain special-category data, we ask for your explicit consent before you use those features if you are in the European Economic Area, the United Kingdom or Switzerland. The consent is separate from your acceptance of the Terms of Service, it is specific to the AI Features, and you may withdraw it at any time in the application settings, after which no further content is submitted. Withdrawal does not affect processing already carried out.
8.4. What we do not collect. We do not ask for and do not want government identification numbers, payment-card data, precise location data, the contents of your communications with other people, or credentials for any third-party account. This version involves no payment, so we hold no payment data at all.
9. COOKIES, IMPORTED COOKIES AND THE EXTENSION
9.1. The desktop application. The desktop application does not use advertising or tracking cookies. It stores information on your device in order to work, including your settings, your sign-in session and the local-cache index described in Section 2.1. Where any identifier stored on your device is used for product analytics rather than for the strictly necessary operation of the application, we do so only where analytics are enabled and, if you are in the European Economic Area, the United Kingdom or Switzerland, only with your prior consent as described in Section 5.4.
9.2. Imported cookies and the built-in browser. Monsora includes a built-in browser that lets you reach third-party services from inside the application. So that you do not have to sign in again to platforms you already use, you can import your existing sign-in cookies from another browser on the same device. After you select the specific sites concerned and confirm on your device, the Monsora extension reads the cookies for those selected sites only and passes them to the built-in browser. This process runs entirely on your device. The imported cookies are not sent to us or to anyone else, they make no outbound network connection carrying them to us, and they do not appear in our logs, telemetry or product events. They are stored locally, in a dedicated area used only by the built-in browser, in the standard form of a cookie and with their own expiry, and we keep no copy on our servers. They remain subject to their own expiry and to your deletion, and you may remove them at any time. The Imported Cookies Confirmation describes this in plain language.
9.3. The Extension. The Extension operates inside your own browser to provide collection features such as batch capture and reference selection, and is distributed through the Chrome Web Store and our official website. The Browser Extension Privacy Notice describes what the Extension accesses and how imported cookies are handled. See Section 3.6.
9.4. The website. Our official website uses only the cookies and similar technologies necessary to operate the site and to measure page views through the web-hosting provider named in Section 10.2, and, where you are in the European Economic Area, the United Kingdom or Switzerland, any non-essential cookie or non-essential page-view measurement is set only with your prior consent.
9.5. The web application. Our web application sets a first-party cookie, monsora_installation, which is HttpOnly, Secure and SameSite=Lax, applies throughout our site and expires after one year. Its value is a randomly generated identifier that contains no information about you or your content, and our servers keep only a keyed hash of it. It is set when a sign-in begins, whichever sign-in method you use, and we use it only to recognise the same browser installation, so that your session is tied to the device it was opened from, an existing device record is reused instead of a new one being created on every sign-in, and your sessions remain secure. It is not used for advertising, for tracking you across sites or for product analytics. Because it is strictly necessary to operate the web application, it is set without consent, including in the European Economic Area, the United Kingdom and Switzerland. You can delete it at any time through your browser settings; it is then created again the next time you sign in.
10. HOW WE SHARE YOUR PERSONAL DATA, AND OUR PROVIDERS
10.1. We do not sell or share your personal data. We do not sell your personal data, and we do not share it for cross-context behavioural advertising. We disclose personal data only to the providers described below, who act for us under contract, and in the limited circumstances described in Sections 10.7 and 10.8.
10.2. Providers who store and run the Services. The providers who store the primary copy of your User Content and run the Services on our behalf are: Cloudflare, Inc., which provides our core cloud object storage; Amazon Web Services, Inc., which provides our production database and other infrastructure; Supabase Pte. Ltd., which provides authentication; Google, through Google Workspace, which provides our email; Grafana Labs, Inc., which provides operational monitoring using technical telemetry only and does not receive your name, account identifier, IP address or content; and Vercel Inc., which hosts our official website and provides page-view measurement for it. Each of them processes personal data only to provide its service to us. Our core cloud storage and our production database are located in the United States.
10.3. Model provider. We use Google LLC, through the Gemini application-programming interface, to perform inference for the AI Features, as described in Sections 6.4 and 6.8. It processes the content you submit to the AI Features only to return a result to us, subject to its own screening and retention described in Section 6.8.
10.4. Search re-ranking provider. We use Jina AI GmbH, which forms part of Elastic N.V., to re-rank your search results. It receives your search queries and the small derived preview images needed to re-rank them, and processes them only to return re-ranked results to us.
10.5. Timestamping provider. Where the timestamping feature is used, we submit only a cryptographic hash of your material to DigiCert, Inc., the timestamping provider identified in the Subprocessors List.
10.6. Sign-in providers. If you sign in through Google or Discord, those providers receive sign-in information only, and your use of that provider is governed by its own terms and privacy notice.
10.7. Legal disclosures. We may disclose personal data where we are required to do so by lawful process, or where disclosure is necessary to protect the rights, safety or property of you, us or any third party, in each case limited to what is strictly necessary.
10.8. Child-safety reporting. Where we obtain actual knowledge of apparent child sexual abuse material in content that has reached us, we will report it to the competent authorities and preserve the relevant material as required by applicable law, and we keep a record of that report.
10.9. Business transfers. We may disclose or transfer personal data in connection with a merger, reorganisation or sale of assets, subject to this Policy.
10.10. Our Subprocessors List. The providers who process personal data on our behalf are identified, by legal entity name, country and function, in our Subprocessors List, which is incorporated into this Policy and published at https://monsora.ai/legal/. A change of provider is a change to that list, made with notice as described in Section 15.2 of the Subprocessors List.
11. INTERNATIONAL DATA TRANSFERS
11.1. Our position. Because the contracting entity has no establishment in the European Union or the United Kingdom, our direct collection of personal data from you is not a restricted transfer. Restricted transfers arise where our providers process personal data outside the European Economic Area, the United Kingdom or Switzerland on our behalf, and where our personnel access that data from outside those regions.
11.2. Where your data is processed. The primary copy of your User Content is stored in a United States West region (Oregon). Our production database and the runtime that serves the application are also located in the United States. The AI Features process content in the locations stated in our Subprocessors List. Members of our personnel, including personnel located in mainland China, may access personal data in order to operate and support the Services.
11.3. The safeguards we rely on. Where a provider processes personal data, or our personnel access it, outside the European Economic Area, the United Kingdom or Switzerland, we generally rely on an appropriate transfer safeguard, being the European Commission’s Standard Contractual Clauses, the United Kingdom International Data Transfer Addendum and, for Switzerland, the applicable amendments, together with applicable supplementary measures where required and a transfer impact assessment that we have documented.
11.4. AI Features and transfers. As explained in Section 6.8, if you are in the European Economic Area, the United Kingdom or Switzerland you should assume that every use of the AI Features involves a transfer of the content you submit out of those regions, to which the safeguards in this Section apply.
12. DATA RETENTION
12.1. Account data. We keep your account data for as long as your account exists, and delete it after your account is closed, subject to the limited period reasonably required to remove copies from active systems and routine backups, and to any period for which applicable law requires us to retain it.
12.2. User Content in the cloud. We keep the primary copy of your User Content until you delete it or your account is deleted. When you delete content or close your account, the content first enters a soft-deleted state for a recovery window during which you can restore it. After that window, we remove it from our active systems, together with its non-current versions and our routine backups, within thirty (30) days, except where applicable law requires us to keep a specific record. We may keep a minimal tombstone record noting that the item existed and was deleted. Section 4.5 addresses historical Capsule versions.
12.3. End of the test phase. At the end of the test phase we do not delete your account or your stored library. Your account moves to our then-current storage terms, including the post-test storage allowance described in Section 4.4. We give you at least fourteen (14) days' notice before the end of the test phase. Any reduction in your storage allowance is subject to at least thirty (30) days' prior notice, followed by a ninety (90) day grace period after the reduction takes effect. If your stored content exceeds the applicable allowance after that grace period, your account becomes read-only in respect of the excess, and we do not delete stored content by reason of the excess. The Test Programme Terms describe this transition.
12.4. Local cache. The local cache on your device is not part of your Vault and is controlled through the application settings and your operating system. Deleting an item from your cloud library may cause it to be removed from the local cache as well, and removing the local cache does not delete the copy stored in the cloud.
12.5. Analytics and logs. We keep product analytics and server logs for no longer than the periods stated as outer limits in our internal retention schedule, and we configure our systems to delete them at or before those limits.
12.6. Provider retention. Where a provider retains content on its own legal or safety grounds, the applicable retention period is stated in our Subprocessors List.
12.7. Support, enforcement and legal records. We keep support records for as long as necessary for the purpose for which they were created. We keep records of reports, decisions, notices and appeals under the Acceptable Use, Content and Collection Guidelines for two (2) years from the date of the final decision, except where a longer period is required by law or needed to establish, exercise or defend a legal claim. Records of any report we are required by law to make are kept for the period the relevant law requires.
13. DATA SECURITY
13.1. The measures we take. We protect personal data using technical and organisational measures appropriate to the risk, including encryption of data in transit and, for stored content and credentials, encryption at rest, role-based access control, multi-factor authentication for privileged and remote access, and logging of access and administrative activity. No method of storage or transmission is completely secure, and some security risk is inherent in any online service.
13.2. Local cache on your device. The local cache on your device is stored by the application within your own operating-system environment. It is not separately encrypted by Monsora, and we recommend that you enable full-disk encryption on your device to protect it.
13.3. If something goes wrong. If we become aware of a personal-data breach that is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority without undue delay and, where feasible, within seventy-two (72) hours, and we will notify you without undue delay where the breach is likely to result in a high risk to you.
13.4. Limited internal access. A limited number of authorised engineering personnel can reach production systems for incident response and support, under role-based access, multi-factor authentication and logging. Some of these personnel are located in mainland China. Access to your content is limited to the narrow circumstances described in this Policy and is not used to review your content for any other purpose.
14. YOUR RIGHTS IN THE EEA, UK AND SWITZERLAND
14.1. Your rights. If you are in the European Economic Area, the United Kingdom or Switzerland, you have the right to access your personal data, to have it rectified, to have it erased, to restrict or object to its processing, to data portability, and, where we rely on your consent, to withdraw that consent at any time without affecting processing already carried out.
14.2. How to exercise them. You may exercise these rights by contacting us as described in Section 18. We respond within one month, which we may extend by up to two further months for complex or numerous requests, in which case we will tell you within the first month.
14.3. Complaints and our representatives. You may lodge a complaint with your local supervisory authority. You may also contact our EU representative or our UK representative, once appointed as described in Sections 1.2 and 1.3.
14.4. Portability and switching under the EU Data Act. If you are established in the European Union or otherwise entitled to the benefit of Regulation (EU) 2023/2854, you may at any time request that we assist you in transferring your User Content and associated metadata to another provider, or that we delete it, and we will provide reasonable assistance within the periods that Regulation requires, without charge except as that Regulation permits.
15. YOUR UNITED STATES PRIVACY RIGHTS
15.1. Your rights. Depending on your state of residence, you may have the right to know and access the personal information we hold about you, to correct it, to delete it, to opt out of any sale or sharing of personal information and of targeted advertising, and to limit the use of sensitive personal information. This version involves no advertising and no sale or sharing.
15.2. How to exercise them. You may exercise these rights by contacting us as described in Section 18. We will not discriminate against you for exercising them. If we decline a request, you may appeal by replying to our response, and we will inform you of the outcome. You may use an authorised agent to submit a request on your behalf, subject to reasonable verification.
15.3. Sensitive personal information. Where your User Content reaches us and reveals sensitive personal information, we use it only to provide the feature you use, and not to infer characteristics about you. Section 8 describes how we treat this information.
15.4. We do not sell or share. We do not sell your personal information and we do not share it for cross-context behavioural advertising, as those terms are defined under United States state privacy laws. We honour opt-out preference signals, including Global Privacy Control, where applicable law requires it.
16. CHILDREN AND AGE
16.1. Age requirement. Monsora is available only to individuals aged eighteen (18) years or older, and we do not knowingly permit any person under that age to create an account or use the Services. Where the age of digital consent in your country of residence is higher than eighteen (18), you must also meet that age.
16.2. Age gate. We apply a date-of-birth age gate on every sign-in route. If we determine that an account belongs to a person under the applicable age, we will terminate it and delete the associated personal data in accordance with this Policy and applicable law.
17. CHANGES TO THIS POLICY
17.1. We may update this Policy from time to time. Where a change is material, we will give you at least fourteen (14) days advance notice by a reasonable means before the change takes effect, and the version history of this Policy is available online at https://monsora.ai/legal/. We will not use a change to this Policy to sell your personal data, to share it for cross-context behavioural advertising, or to permit the training of general-purpose artificial-intelligence models on your content, and we will not weaken your protections retrospectively in relation to data already collected. Your continued use of the Services after the effective date of an updated Policy constitutes acceptance of it, except where your consent is required, in which case we will ask for it first.
18. HOW TO CONTACT US AND EXERCISE YOUR RIGHTS
18.1. How to contact us. You can reach us at any time at hi@monsora.ai.
18.2. Who handles privacy requests. Privacy requests are handled by our Privacy & Safety Officer at privacy@monsora.ai. You may also contact our EU representative or our UK representative, once appointed as described in Sections 1.2 and 1.3.
18.3. Verification. To protect your personal data, we may need to verify your identity before acting on a request. We will ask only for information reasonably necessary to do so, and we will not use it for any other purpose.