1. Who is responsible for your data
OPĒS is published and sold by the operator of the app and of the website nfsynq.net (the "Publisher", "we"). Everything this policy covers is handled at a single address: legal@nfsynq.net.
For the purposes of Regulation (EU) 2016/679 (GDPR), the Publisher is the data controller for the processing described here, and carries out no processing on anyone else’s behalf. No data protection officer is designated: requests are read and answered by the Publisher. If you need the Publisher’s identifying details and place of establishment — to make a formal request, or to bring a complaint — ask at legal@nfsynq.net and we send them to you.
This policy covers the OPĒS application for iOS and Android and the website nfsynq.net. It does not cover the NFSynq Enterprise platform (nfsynq.com), which has its own contractual framework and its own data processing agreement.
2. The principle: we do not want your business data
OPĒS answers questions on food safety by consulting a body of public regulatory knowledge. It is not a place where you file your company's records, and it does not need them in order to answer.
We therefore do not ask for, and the app does not collect, your HACCP plans, your suppliers, your recipes, your analysis results, your production or batch records, or data about your own customers. If you choose to paste such information into a question, you do so on your own initiative: see section 5.
There is no advertising in the OPĒS app, no advertising identifier, no profiling for marketing purposes, and no sale or sharing of personal data with data brokers.
3. What data we process
We process only the following categories of data:
- Account data: your email address and, optionally, a display name — needed to give you access to your subscription across your devices.
- Subscription data: the customer and transaction identifiers returned by Stripe, our payment provider, together with the plan, the start and renewal dates and the status. Stripe also passes on the billing details you give it at checkout — billing name and address, and whatever you add yourself — because they are needed for accounting obligations. We never receive or store your card number.
- The content of the question you ask: it travels to the model, comes back as an answer and ends there. Neither the question nor the answer is retained — there is no archive of conversations. All that remains of usage is a monthly count of how many requests your key has made, with no questions and no answers.
- Technical and diagnostic data: app version, operating system, device model, language and region settings, error logs and the IP address of the request. The app contains no crash-reporting tool of any kind: whatever Apple or Google collect at operating-system level never reaches us.
- Support correspondence: what you write to us through the form on nfsynq.net or by email, and our replies.
- Website: the technical storage strictly necessary (the language, the light/dark theme and the choice you make about cookies, which stay in your browser); aggregated visit statistics from Vercel Web Analytics, with no cookies and no persistent identifier; and, only if you consent, Google Analytics (cookies) and a random marketing identifier stored on your device. Details in section 12.
4. Why we process it, and on what legal basis
- To provide the app and answer your questions — performance of the contract, Art. 6(1)(b) GDPR.
- To manage the subscription, renewals, refunds and invoicing — performance of the contract and legal obligation, Art. 6(1)(b) and (c).
- To keep the service secure and prevent abuse, fraud and automated extraction of the knowledge base — legitimate interest, Art. 6(1)(f).
- To fix defects and improve the accuracy of the answers — legitimate interest, Art. 6(1)(f), on aggregated or pseudonymised data wherever that is sufficient.
- To reply to your support requests — performance of the contract and legitimate interest.
- To comply with accounting, tax and consumer-law obligations — legal obligation, Art. 6(1)(c).
- To send optional messages about new features — your consent, Art. 6(1)(a), which you may withdraw at any time.
- To measure visits to the website in aggregate form (Vercel Web Analytics) — legitimate interest, Art. 6(1)(f).
- For Google Analytics statistics and for the random marketing identifier — your consent, Art. 6(1)(a) GDPR and Art. 5(3) of Directive 2002/58/EC, which you may withdraw at any time from “Cookie preferences” in the footer.
- To introduce OPĒS to food-sector professionals and businesses that are not yet our users — legitimate interest, Art. 6(1)(f) and recital 47 GDPR, with the right to object at any time: see section 13.
5. How the AI works, and what happens to your questions
The model that answers your questions runs on infrastructure operated by the Publisher. Your questions are not sent to any third-party AI provider: there is no external model vendor in the chain, and no one outside the Publisher and its processors ever sees what you ask.
回答は、公的情報源から構築した規制知識基盤を参照して生成されます。内訳は、251の国・地域の所管当局、うち251については適用法令と参照先（出典の出所を確認済み）、欧州連合の食品法（現時点で適用値まで収録しているのはこの部分です）、および各国当局（FDA、CFIA、FSA、FSANZ、MHLW）とコーデックス委員会の刊行物です。すべての回答は、依拠した出典と、その出典について宣言された信頼性レベルを明示します。
Questions and answers are not retained. There is no archive of conversations: the question serves to produce the answer and ends there, and there is nothing that could be used to train a model or shown to other users. It is a design decision — and it is also why OPĒS offers no question history.
Please do not include other people's personal data, health data or confidential business information in your questions: OPĒS does not need them to answer.
OPĒS produces informational output, not automated decisions producing legal or similarly significant effects on you within the meaning of Art. 22 GDPR. The decision on how to act always remains with you, or with the professional you rely on.
6. Who else sees the data
- Stripe, our payment provider: it takes the payment, runs the checkout page and the subscriber portal, and issues the receipt. It receives your email address and the billing and payment details you enter at checkout, and it is the only party in the chain that handles your means of payment.
- Our hosting and infrastructure providers, acting as processors under Art. 28 GDPR. Vercel hosts the nfsynq.net website and runs its server functions, so it processes what you send from the forms and the technical logs of the requests, IP address included. Hetzner Online GmbH provides the servers and the database on which your account, your subscription status, your usage count and the assistant that answers you all run: those machines are in Finland, in the European Union, and that is where your data actually sits. Both act on our instructions only, and neither uses your data for its own purposes.
- Our email providers: Resend delivers the emails we send you — confirmation of the withdrawal waiver, support acknowledgements, password recovery — and Cloudflare routes the ones you write to legal@nfsynq.net. If outgoing mail takes the alternative channel, transport is by Apple's iCloud servers. They receive your address and the text of the message.
- Google Ireland Limited and Google LLC, only if you consent to Google Analytics: they receive from your browser the cookie identifiers, the pages visited and technical device data, in order to produce visit statistics.
- Fly.io, the infrastructure provider on which our commercial-communication system runs, as a processor: it receives the arrivals on the website (country and campaign parameters, never the visitor’s IP address) and the professional contact details of section 13, together with the email-sending providers of that system.
- Professional advisers, accountants and auditors, only where strictly necessary and bound by confidentiality.
- Public authorities, where disclosure is required by law.
We do not sell personal data and we do not disclose it for third parties' own marketing purposes.
7. Transfers outside the EEA
The servers and the database that hold your account are in the European Union (Finland), so the data at the centre of the service does not leave the European Economic Area. Some of the other recipients listed in section 6 are established outside it, or use infrastructure that is. Where a processor operates outside the European Economic Area, the transfer takes place on the basis of an adequacy decision of the European Commission or of the Standard Contractual Clauses adopted by Decision (EU) 2021/914, together with the supplementary measures required by the case. Write to legal@nfsynq.net and we tell you which processors are involved, where each of them operates and on what basis, and send you a copy of the safeguards in force on the day of your request. Google, Vercel and Fly.io are companies established in the United States: for them the transfer rests on the Commission’s adequacy decision on the EU-US Data Privacy Framework (Implementing Decision (EU) 2023/1795) where the company participates in it, and otherwise on the standard contractual clauses.
8. How long we keep it
- Account and subscription data: for as long as the account exists. When you delete your account — which you can do yourself, at any hour, at nfsynq.net/delete-account — the email address, the business name, the password, the sessions and the API keys are removed straight away, not after a waiting period. Accounting records of what was bought (plan, price, period) are kept for 10 years as tax law requires, without your email address.
- Questions and answers: not retained, so there is no period to state. All that remains is the monthly count of requests per key, kept for as long as it is needed to manage the subscription.
- Technical logs: 12 months.
- Support correspondence: 24 months from the closure of the request.
- Deletion receipts: kept without a time limit, and containing nothing that identifies you — a random number, a date and a summary of what was removed and what had to stay. It is the proof that a deletion happened, and it survives because nothing else about you does.
9. Your rights
Under Articles 15 to 22 GDPR you have the right to obtain access to your data, its rectification or erasure, the restriction of processing, the portability of the data you provided in a structured, commonly used and machine-readable format, and to object to processing based on our legitimate interest.
Where processing is based on consent, you may withdraw it at any time, without affecting the lawfulness of the processing carried out before the withdrawal.
You can exercise these rights by writing to legal@nfsynq.net. We reply within one month, extendable by two further months for particularly complex requests, as provided by Art. 12(3) GDPR. Erasure does not have to wait for that reply: you can delete your account yourself, at any hour, at nfsynq.net/delete-account — it takes effect immediately, closes any subscription still open and leaves you a receipt number as proof. There is, in any case, no question history to delete, because questions and answers are not retained (section 5).
If you consider that your data is processed unlawfully, you may lodge a complaint with a supervisory authority. Art. 77 GDPR lets you choose the authority of your habitual residence, of your place of work or of the place where the alleged infringement occurred: you never have to find ours in order to be heard. If you would rather address the authority that supervises the Publisher, ask at legal@nfsynq.net and we tell you which one it is.
10. Security
Data is encrypted in transit (TLS) and at rest. Access to production systems is restricted to a minimum number of authorised persons, logged and protected by multi-factor authentication. We maintain an incident procedure and, where a personal data breach is likely to result in a high risk to your rights, we notify you and the supervisory authority within the terms of Articles 33 and 34 GDPR.
11. Children
OPĒS is a professional tool and is not directed at children. It must not be used by anyone under 16, or under the higher age set by the law of your country for consent to information society services. We do not knowingly collect data of minors; if you believe a minor has created an account, write to legal@nfsynq.net and we will delete it.
12. Cookies, local storage and statistics
The nfsynq.net website distinguishes four things. Only the first is always active; the others need your choice or are described here so that you can object.
- Strictly necessary (no consent): the language, the light/dark theme and the choice you make on this notice, kept in your browser and never sent to us; and the technical session cookies of people signing in to their account.
- Aggregated statistics without cookies (Vercel Web Analytics): it counts visits and page views with no cookies, no persistent identifier and no tracking across different sites. Legal basis: legitimate interest; you may object by writing to legal@nfsynq.net.
- Google Analytics (only with your consent): it sets cookies (_ga and _ga_*, up to two years) and sends browsing data to Google to produce visit statistics. Without your consent no Google script is loaded and no cookie is stored.
- Random marketing identifier (only with your consent): a random number stored in the browser’s local storage (key nfsynq_marketing_anon_id) that tells us whether a visit comes from someone who has already arrived and from which campaign. It contains no personal data and we do not link it to your account. Without consent we store nothing on your device: the visit is still counted anonymously (country and campaign parameters, no IP address, no stored identifier).
Your choice lasts 12 months, then we ask again. You can change it whenever you like from “Cookie preferences” in the footer: withdrawing is as easy as consenting, and when you withdraw we delete the Google Analytics cookies and the marketing identifier from your browser.
The app does not use the advertising identifier (IDFA/AAID) and does not take part in any advertising network.
13. Commercial contact with sector professionals
Besides our users, the Publisher may write to food-safety professionals and businesses (consultants, quality managers, food businesses) to introduce OPĒS. If you received an email from us without having signed up, this section tells you who we are, what data we hold about you and how to stop us (Art. 14 GDPR).
- Controller and contact: the Publisher (section 1), at legal@nfsynq.net.
- Data: name, role, professional email address and the business you belong to, plus any reply you send or a request not to be contacted again. No special-category data and no private data.
- Source: publicly accessible information (websites of businesses and professionals, professional directories and registers) and professional-contact search services. We do not receive it from you.
- Purpose and legal basis: presenting a service relevant to your professional activity — legitimate interest, Art. 6(1)(f) and recital 47 GDPR, balanced against your rights. Messages are few, relevant to your role and say how to object.
- Objection: you may object at any time and without giving a reason (Art. 21 GDPR) with the unsubscribe link in the emails or by writing to legal@nfsynq.net. We stop at once and keep only the note not to contact you again.
- Retention: for as long as the communication remains relevant to your role and in any case until you object; anyone who objects or is no longer relevant is removed from the lists.
- Recipients: the infrastructure and email-sending providers of section 6, as processors.
- Rights and complaint: those of section 9, including erasure of your contact details and the complaint to a supervisory authority.
14. Changes to this policy
We may update this policy to reflect changes to the service or to the law. The version and the date of the last update are shown at the top of this page. If a change materially affects how we process your data, we will notify you in the app or by email before it takes effect.
15. Contact
For any question about this policy, or to exercise your rights, write to legal@nfsynq.net. It is one address, read by a person, and it is the only one you need. If a postal address is required — for a formal notice, or because an authority asks for it — request it there and we send it to you, together with the Publisher’s identifying details.