Privacy Policy
This document is provided in English. Items marked [TODO] are placeholders that must be completed and reviewed by qualified counsel before public launch.
1. Who we are
This Privacy Policy explains how [TODO: legal entity name] ("TokenHub", "we", "us") collects and uses personal information when you use the TokenHub website, console, applications and API (the "Service"). We are the controller of the personal information described here. [TODO: EU/UK representative and data protection officer, if required]
2. Information we collect
Information you provide
- Account data: email address, display name and password. Passwords are stored only as salted scrypt hashes. A phone number is optional and only stored if you choose to provide it.
- Content: prompts, messages, files and attachments you submit, and the outputs returned (together, "Content"). Conversation history and attachments are stored encrypted at rest so you can return to them.
- Billing data: top-up and invoice records, and billing details you enter. Card payments are handled by [TODO: payment processor]; we receive limited information such as the payment status, amount and last four digits, not full card numbers.
- Communications: messages you send to support, feedback and access requests.
Information collected automatically
- Usage and metering data: model used, token counts, cost, latency, status and error codes for each request.
- Device and log data: IP address, browser or client type, timestamps and security logs (for example, failed sign-in attempts).
Information from third parties
If you choose to sign in with a third-party identity provider (for example Google or Apple, when available), we receive the basic profile information you authorise, such as your email address and name.
3. How we use information
- To provide the Service: authenticate you, route requests to the model you select, return outputs, and keep your history.
- To meter usage, charge your balance, issue invoices and prevent fraud.
- To secure the Service: rate limiting, abuse detection, and investigating incidents.
- To support you and send service-related notices (such as security alerts, billing notices and changes to our terms).
- To comply with legal obligations and enforce our Terms of Service.
We do not sell your personal information, and we do not use your Content to train models [TODO: confirm].
4. Legal bases
Where the GDPR or similar laws apply, we rely on: performance of our contract with you (providing the Service and billing); our legitimate interests (security, fraud prevention, improving reliability), balanced against your rights; your consent where required (which you can withdraw at any time); and compliance with legal obligations. [TODO: confirm with counsel]
5. Model providers and other recipients
- Model providers: when you send a request, your Content and request parameters are transmitted to the provider operating the selected model — currently DeepSeek, Alibaba Cloud (Qwen), Zhipu AI (GLM) and Moonshot AI (Kimi). Each provider processes that data under its own terms and privacy policy [TODO: link each provider policy and describe their retention].
- Service providers: hosting, storage, email delivery, payment processing and customer support vendors that process data on our behalf under contract [TODO: list sub-processors].
- Legal and safety: authorities or other parties when required by law or necessary to protect rights, safety and the integrity of the Service.
- Business transfers: a successor in a merger, acquisition or asset sale, subject to this Policy.
6. International transfers
We and our providers may process information in countries other than yours, including [TODO: hosting region] and, for requests routed to certain model providers, mainland China. Where required, we use appropriate safeguards such as Standard Contractual Clauses [TODO: confirm transfer mechanisms]. You can choose which models to use; avoid sending sensitive personal data in prompts if you do not want it processed in a provider's jurisdiction.
7. Retention
- Account data: for as long as your account is active, then deleted or anonymised within [TODO: period] after account closure, except where we must keep it longer.
- Conversation history and attachments: until you delete them or close your account [TODO: confirm retention period / maximum].
- Usage, billing and invoice records: as required for accounting and tax purposes [TODO: period, e.g. 7 years].
- Security logs: [TODO: period].
8. Security
We use technical and organisational measures appropriate to the risk, including TLS in transit, encryption at rest for upstream API keys, personal identifiers, conversation content and attachments, hashed passwords and session tokens, rate limiting, and restricted administrative access. No method of transmission or storage is completely secure.
9. Cookies and local storage
We use a strictly necessary session cookie (th_session) to keep you signed in, and browser local storage to remember preferences such as your language (th_lang). We do not use advertising cookies. [TODO: update if analytics are added]
10. Your rights
Depending on where you live, you may have the right to access, correct, delete or export your personal information, to object to or restrict certain processing, and to withdraw consent. You can exercise these rights by contacting [TODO: privacy contact email]. You also have the right to complain to your local data protection authority. California residents: we do not sell or share personal information for cross-context behavioural advertising.
11. Children
The Service is not directed to children and is only available to users aged 18 or older. We do not knowingly collect information from children; if you believe a child has provided us information, contact us and we will delete it.
12. Changes
We may update this Policy. We will post the updated version here and, for material changes, notify you by email or in the console before they take effect.
13. Contact
[TODO: legal entity name], [TODO: postal address] · Email: [TODO: privacy contact email]