Privacy Policy

1. Data Controller

The data controller responsible for personal data collected via Ricly is:

Ricly — a commercial name (nom commercial) of Samir Benabdelmoumen, auto-entrepreneur (entreprise individuelle) registered in France (SIRET 889 343 687 00022).
Email: hello@usericly.com (prefix subject with [Privacy] for privacy-related requests).

Given the scale of our operations (under 250 employees, no large-scale special-category processing), we are not required to appoint a formal Data Protection Officer (DPO) under GDPR Article 37. Privacy-related requests are handled directly by the data controller.

2. Data We Collect

We collect only the data needed to provide the Service. Categories:

2.1 Account data

• Email address — provided by you at sign-up (Firebase Authentication).
• Optional name — if provided in settings.
• Authentication token — managed by Firebase, never stored by us in plain text.
• Billing email — captured separately by Stripe at checkout if it differs from your sign-up email (Stripe Link users typically have this scenario). Stored as billing_email ; never used for transactional emails which always go to your sign-up email.

2.2 Subscription & billing data

• Subscription status — Free / Pro / Pro+ / Founding Monthly / Founding Lifetime / Family.
• Stripe customer ID — opaque identifier for billing reconciliation.
• Payment method — handled entirely by Stripe ; we never see or store card details.
• Invoice history — accessible to you via the Stripe Customer Portal.

2.3 Usage & analytics data

• Module opens — which Ricly modules you launch (anonymous count per module per day).
• Upload counts & bytes — number of files uploaded via Upload & Share and total storage used. Not the file content.
• Last seen timestamp — to identify dormant accounts for re-engagement emails (opt-out available).
• App version & macOS version — to diagnose crashes and ensure compatibility.
• Anonymized error reports — when the app crashes, we may receive a stack trace via Apple MetricKit ; no personal data is included.

2.4 Files (Upload & Share only)

• Files you upload via the Upload & Share feature are stored encrypted at rest on Cloudflare R2.
• File metadata stored: file name, size, MIME type, upload timestamp, expiry date, download count.
• File content is NEVER analyzed, indexed, or shared with any third party (other than the link recipients you choose).
• Files expire and are permanently deleted per your plan: 3 days (Free), 30 days (Pro), 60 days (Pro+).

2.5 Network & device data

• IP address — used for abuse prevention, rate limiting, and approximate country detection. Provided by Cloudflare network edge.
• Country code (ISO-2) — derived from your IP. Used for locale-appropriate pricing display (EUR vs USD) and analytics.
• Device identifier — a unique ID per Mac, used to enforce per-device limits on Pro+ AI features.

2.6 AI input data (Pro+ only, on demand)

• When you use a Pro+ AI module (background removal AI, image upscaling AI, etc.), the input file (image, audio, document) is sent to the relevant AI provider for processing.
• We do NOT retain a copy of the AI input data beyond the processing window. The AI provider's retention policy applies separately (see Section 6.4).

2.7 What we do NOT collect

• The content of files processed locally (conversions, compression, OCR, etc.). These run 100% on your Mac.
• Your browsing history, location history, or any third-party app data.
• Sensitive personal data under GDPR Art. 9 (health, beliefs, biometrics) — we do not request or process this.
• Card payment details (handled by Stripe ; we are out of PCI scope).

3. Why We Process Your Data (Purposes)

• Service delivery. Authenticate you, enforce subscription tier, route uploads.
• Billing. Process payments, send invoices, manage subscriptions.
• Customer support. Respond to your emails and bug reports.
• Product improvement. Aggregate anonymized usage stats to decide which modules to improve.
• Security & fraud prevention. Rate-limit abusive IPs, detect anomalies, prevent fraudulent chargebacks.
• Communication. Send transactional emails (welcome, payment receipts, dunning) and, if you opted in, occasional product updates and marketing.
• Legal compliance. Retain billing records as required by French fiscal law.

4. Legal Basis for Processing (GDPR Art. 6)

• Contract performance (Art. 6.1.b) — account, billing, support, file delivery, Upload & Share, AI features.
• Legal obligation (Art. 6.1.c) — accounting/fiscal retention, response to legal authorities.
• Legitimate interest (Art. 6.1.f) — abuse prevention, security, anonymous analytics, short-term IP retention.
• Consent (Art. 6.1.a) — marketing emails, optional analytics. Withdrawable at any time via Settings → Email notifications or by emailing us.

5. Cookies & Tracking

The Ricly macOS application does NOT use cookies or any form of tracking ID beyond a per-device identifier kept locally on your Mac.

The website usericly.com uses only strictly necessary cookies (session, language preference, dismissed banners). We do not currently use third-party analytics cookies, advertising cookies, or social media trackers on the website. If we add any in the future, we will display a GDPR-compliant consent banner before any non-essential cookie is set.

6. Third-Party Subprocessors

We use the following services to operate Ricly. Each is a data subprocessor under GDPR Art. 28 and processes data only under our written instructions (Data Processing Agreement, DPA, signed where applicable).

6.1 Authentication & database

• Firebase Authentication (Google LLC, USA) — manages user sign-up, email verification, and login sessions. Data: email, password hash (we never see plain text), authentication metadata. Under EU Standard Contractual Clauses (SCC) for international transfers.
• Firebase Firestore (Google LLC, USA) — stores your account state (plan, settings, founder status). Under EU SCC.
• Cloudflare D1 + Workers (Cloudflare, Inc., USA) — application backend database and edge compute. Hosted in the EU (Frankfurt and Paris regions) where possible. Under EU SCC.

6.2 Payments

• Stripe Payments Europe Ltd (Ireland) — handles all payment processing, tax collection (Stripe Tax), and billing portal. We never receive card data. Stripe's privacy policy: stripe.com/privacy.

6.3 File storage & CDN

• Cloudflare R2 (Cloudflare, Inc., USA) — Upload & Share file storage. Files encrypted at rest. Under EU SCC.

6.4 AI providers (Pro+ AI modules only, on demand)

• Anthropic PBC (USA) — Claude AI for text/document AI features. Inputs not used to train their models per Anthropic's commercial terms. Under EU SCC.
• OpenAI OpCo (USA) — for selected AI image and text features. Inputs not used for training per their API terms. Under EU SCC.
• fal.ai (USA) — AI image upscaling and generation. Under EU SCC.
• Replicate (USA) — selected AI model inference. Under EU SCC.
• PhotoRoom (France) — background removal AI. EU-based.
• PiAPI (Singapore) — selected generative AI features. Under EU SCC.

AI providers are invoked ONLY when you actively use an AI-powered module. Each request sends the necessary input (e.g., the image to upscale) and receives the AI output. We do not pre-emptively send your data to AI providers.

6.5 Email delivery

• Resend (Resend, Inc., USA) — sends transactional and lifecycle emails (welcome, dunning, receipts, opt-in updates). Stores email addresses and send logs. Under EU SCC.

6.6 Auto-updates

• Sparkle Updater (open source, served from our own infrastructure) — checks for app updates by fetching an XML feed from releases.usericly.com (hosted on Cloudflare R2). No personal data is sent ; only the request itself (which includes your IP via standard HTTP). User-Agent includes app version for compatibility checks.

6.7 No advertising, no data sales

We do NOT use advertising platforms, marketing analytics platforms (e.g., Mixpanel, Amplitude, Segment), or social media trackers. We do NOT sell, rent, or share your personal data with any third party for marketing purposes.

7. International Data Transfers

Several of our subprocessors are based outside the European Economic Area (EEA), notably in the United States. For each such transfer, we rely on:

• EU Standard Contractual Clauses (SCC, Commission Decision 2021/914) — signed with each US subprocessor.
• Where applicable, EU-US Data Privacy Framework (DPF) certification of the subprocessor.
• Supplementary technical measures: encryption in transit (TLS 1.3), encryption at rest, access controls.

You may request a copy of the SCCs in force with any subprocessor by emailing hello@usericly.com.

8. Data Retention

We keep your data only as long as necessary for the purpose for which it was collected:

• Account data — for the duration of your account. If you delete your account, we remove personal data within 30 days, except as required by legal retention obligations below.
• Subscription & billing records — 10 years from the end of the fiscal year, as required by French fiscal law (Code de commerce, Art. L. 123-22).
• Upload & Share files — automatically deleted at link expiry: 3 days (Free), 30 days (Pro), 60 days (Pro+). Earlier deletion possible via the in-app revoke button.
• IP address logs — 12 months for security/abuse forensics, then deleted or anonymized.
• Email opt-out records — retained indefinitely to honor your unsubscribe preference even after account deletion.
• Backups — operational backups of databases are kept up to 30 days, after which they are cycled out.
• AI input data — not retained by us. Subprocessor retention varies (see their respective policies).

9. Your Rights (GDPR & Equivalent)

You have the following rights regarding your personal data:

• Right of access (Art. 15) — obtain a copy of the personal data we hold about you.
• Right to rectification (Art. 16) — request correction of inaccurate or incomplete data.
• Right to erasure / "right to be forgotten" (Art. 17) — request deletion of your data.
• Right to restrict processing (Art. 18) — request that we limit how we use your data.
• Right to data portability (Art. 20) — receive your data in a machine-readable format and transmit it to another controller.
• Right to object (Art. 21) — object to processing based on legitimate interest, including direct marketing.
• Right to withdraw consent — for any processing based on consent (marketing emails, etc.), you can withdraw your consent at any time via Settings → Email notifications or by emailing us.
• Right not to be subject to automated decision-making — we do not perform automated decision-making with legal effects on you.

To exercise any of these rights, email hello@usericly.com with subject [Privacy Request]. We respond within 30 days (extendable by 2 months for complex requests, with notice).

10. Security Measures

We implement appropriate technical and organizational measures to protect your data:

• TLS 1.3 encryption for all data in transit between you and our servers.
• Encryption at rest for files in Cloudflare R2 and database records in Cloudflare D1.
• Firebase Authentication best practices: password hashing, rate-limited sign-in, OAuth flows.
• Principle of least privilege: only the founder has direct access to production databases ; subprocessor employees access is restricted per their own security programs.
• Regular security review of code changes (manual code review for every commit touching auth, billing, or data storage).
• Webhook signature verification for all Stripe events.
• Rate limiting on API endpoints to prevent enumeration and abuse.

In the event of a personal data breach likely to result in high risk to your rights and freedoms, we will notify affected users without undue delay (within 72 hours where feasible) per GDPR Art. 33-34.

11. Children

Ricly is not intended for users under 16. We do not knowingly collect personal data from children under 16 (or the applicable minimum age in your country). If you believe a child under 16 has created an account, email us and we will delete the account and associated data.

12. Complaints to a Supervisory Authority

If you believe our processing of your data violates GDPR or your national data protection law, you have the right to lodge a complaint with a supervisory authority. In France, the competent authority is:

CNIL — Commission Nationale de l'Informatique et des Libertés
3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France
cnil.fr/en/plaintes

If you reside in another EU/EEA country, you may contact the supervisory authority of your country of residence.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified to active users by email at least 30 days before they take effect. The current version is always available at usericly.com/legal/privacy. The "Last updated" date at the top of this policy reflects the most recent revision.

14. Contact

For any question, complaint, or request related to this Privacy Policy:

Email: hello@usericly.com (prefix subject with [Privacy] or [GDPR] for prioritized handling).
A postal address can be provided on request by writing to the address above.