DRAFT — pending legal review. These documents are not yet in force; they describe the intended terms for alter's public launch.

Alter Privacy Policy

Effective date: 16 July 2026 · Last updated: 16 July 2026

1. Who we are

Alter (“alter”, “we”) is an AI second-brain service operated by Ishaan Chaturvedi, a sole trader trading as “alter”, of Sage House, 16 Colina Road, London N15 3FB. We are the data controller for the personal data described here. Contact: privacy@nullsutra.com. We are established in the United Kingdom, so the UK GDPR and the Data Protection Act 2018 govern our processing of your personal data, and our supervisory authority is the UK Information Commissioner's Office (ICO); we are registered with the ICO under registration number ZC200352. Our servers and encrypted backups are hosted in the European Union (Hetzner, Germany). If you are in the EU/EEA, the EU GDPR also applies to the processing of your data.

2. What we collect

  • Account data — email address, name, password hash (or Google account identifier), subscription status.
  • Your content — the thoughts you capture and everything alter derives from them: wiki entries, briefings, artifacts, conversations, research documents.
  • Billing data — handled by Stripe; we store your Stripe customer and subscription identifiers, never card numbers.
  • Operational telemetry — error reports, sign-in logs, request latency, per-feature usage counts. Telemetry events are structurally prevented from containing your content (schema-enforced in CI).
  • Optional product telemetry — aggregate feature-usage signals you can switch off in Settings → Privacy.

3. Why we process it (lawful bases)

  • Providing the service, AI processing, billing — contract (GDPR Art. 6(1)(b)).
  • Security, abuse prevention, operational telemetry — legitimate interest (Art. 6(1)(f)).
  • Optional product telemetry — consent (Art. 6(1)(a)), revocable in Settings.

We do not sell your data. We do not use your content for advertising.

Special category data in your captures

Because alter lets you capture any thought, your content may sometimes include special category data under Article 9 UK GDPR — for example information about your health, sex life, religious or philosophical beliefs, political opinions, trade-union membership, genetics, biometrics, or ethnicity. We do not ask for this, and the service does not require it — you decide what you write. Where your captures contain special category data, we process it only to provide the service to you, relying on your explicit consent under Article 9(2)(a) UK GDPR, which you give when you accept this policy at registration. You can withdraw that consent at any time by deleting the content or your account (see §6); withdrawal does not affect processing already carried out.

4. AI processing and your content

To classify, compile, and answer, your captures are sent to large-language-model providers through alter-managed accounts:

  • Anthropic and OpenAI process capture-derived text. Both publish API policies stating customer API data is not used to train models. Both currently apply their standard ~30-day API data retention; we have not yet signed enterprise zero-retention agreements — that upgrade is planned before public general availability.
  • Perplexity receives Explore-mode search queries via its Sonar API, which per its published policy retains no request data and does not train on it.

5. Storage, encryption, retention

Content fields are encrypted at rest (AES-256-GCM) in our database; files are stored encrypted in EU-hosted object storage. Your data is retained while your account is active. Encrypted database backups are kept off-site (EU jurisdiction) on a 30-day rolling retention.

6. Deletion and export (your rights)

  • Export (portability): Settings → Privacy → “Export all data” produces a machine-readable JSON bundle of your account data, immediately, over an authenticated connection.
  • Deletion (erasure): Settings → Privacy → “Delete my account” immediately and permanently deletes your account and all content from the live system (typed confirmation required; no recovery). Copies inside encrypted backups expire within at most 30 days. Your subscription is cancelled at the same time; Stripe retains billing records it is legally required to keep as an independent controller.
  • You also have rights of access, rectification, restriction, and objection, and the right to lodge a complaint with the UK Information Commissioner's Office (ICO) — ico.org.uk/make-a-complaint, helpline 0303 123 1113. If you are in the EU/EEA you may instead complain to your local supervisory authority.

Requests beyond the in-app flows: privacy@nullsutra.com.

7. Sub-processors

Current list, with roles and regions: sub-processors. We update that page when the list changes.

8. International transfers

Our servers and backups are in the EU. Our LLM providers (Anthropic, OpenAI, Perplexity), Stripe, and error monitoring may process data in the United States. As a UK controller we rely on the UK Extension to the EU–US Data Privacy Framework where a provider is certified under it, and otherwise on the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses.

9. Cookies and local storage

The app uses browser local storage for your session token and preferences. We set no third-party advertising or analytics cookies. We use a self-hosted, cookie-free analytics tool (Umami) to count page visits; it sets no cookies, stores no personal identifiers, and the data never leaves our own servers.

10. Children

Alter is not directed at children under 16 and we do not knowingly process their data.

11. Changes

We will notify account holders by email and in-app before material changes take effect.

Privacy Policy — alter