214ID App Privacy Policy

214 Innovation & Development ("214ID," "we," "our," or "us") operates the iOS application 214ID Executive AI Fluency (the "App"). This policy explains what information we collect, how we use it, who we share it with, and your rights as a user.

1. Information We Collect

Account identity. When you sign in with Apple, Apple provides us with a unique identifier for your account (your Apple "sub" value). Depending on your choice at sign-in, Apple may also provide your email address. We store this identifier and, if provided, your email address in our database to associate your saved data with your account.

User profile. You may optionally provide your professional role, organization type, industry, organization size, and a brief context statement. This information is stored on your device, not on our servers. A short summary of it accompanies each refinement request solely to calibrate the feedback you receive, and like the rest of the request it is processed transiently and not retained.

Prompt content and documents. When you use the Prompt Refinery, the text you submit and any reference material you attach (pasted text, PDFs, Word files, and images) are transmitted to our backend servers and then to Anthropic’s API to generate structured feedback and a refined prompt. This processing is transient: prompt content and document content are held in memory only for the duration of your request, are not retained on our servers after the request completes, and are never written to persistent storage or server logs.

Saved prompt library. If you choose to save a refined prompt to your library, the prompt content (your original prompt, the refined prompt, and the associated feedback) is encrypted on your device with AES-256 before it is uploaded to our servers. The encryption key is generated on your device and stored in your device Keychain; iCloud Keychain may sync it to your other devices, but it is never transmitted to 214ID. Our servers store only the encrypted data plus non-content metadata (task type, timestamps, and whether reference material was attached and of what type, never its content). 214ID cannot decrypt, read, or search your saved prompt content. A local copy of your saved prompts is also kept on your device so your library works offline.

Trust Receipts. Each time you run a prompt refinement, a Trust Receipt is generated: a signed record containing metadata about the interaction (the model used, the task type, timestamps, token counts, whether reference material was attached and its type and size, explicit confirmation that your prompt, documents, and the response were not retained, and a cryptographic signature). Trust Receipts do not contain your prompt text or document content. Receipts are issued and signed by our servers, where a copy is stored for verification, and are also stored on your device.

Learning module progress. If you use the App’s learning modules, we store your progress on our servers: which modules you have started or completed, the step you are on, and timestamps. The text you enter in module exercises and the model’s responses are processed transiently, like refinement requests, and are not stored on our servers.

Subscription and transaction data. When you purchase a subscription, Apple processes the payment. We receive a verified transaction record from Apple’s App Store Server API, which we store to maintain your subscription status. We do not receive or store your payment card details.

Session tokens. We issue a session token to your device when you sign in. This token is stored in your device’s Keychain and is used to authenticate your requests to our servers. It does not contain personal information.

Usage analytics. The App counts certain in-app events locally on your device (for example, how many times you have refined a prompt). These counts are stored only on your device using iOS local storage and are never transmitted to us or any third party.

Server logs. Our backend infrastructure (Cloudflare Workers) generates standard server logs that may include your IP address, user identifier, request timestamps, HTTP status codes, and non-content request metadata such as task type, attachment count and size, token counts, and latency. These logs are retained for up to 30 days for security and operational purposes. Prompt content, document and image content, profile context, and model responses are never written to server logs.

2. How We Use Your Information

• To authenticate you and maintain your session.
• To deliver prompt refinement feedback powered by Claude Opus (Anthropic’s AI model).
• To calibrate feedback quality using your optional profile information.
• To maintain your subscription status and verify entitlements.
• To generate and verify Trust Receipts.
• To track your progress through learning modules.
• To store prompts you explicitly choose to save to your library, in encrypted form we cannot read.
• To operate, maintain, and improve the App and its backend infrastructure.
• To comply with legal obligations.

We do not use your information to train AI models. Your prompts and documents are transmitted to Anthropic subject to Anthropic’s data usage policies, which include API usage terms that restrict training on API-submitted content. See Section 4 for details.

3. How We Store Your Information

Our backend runs on Cloudflare’s infrastructure (Workers, D1 database, and R2 object storage). Data at rest is encrypted by Cloudflare. Data in transit between your device and our servers is encrypted using TLS.

Refinement requests are processed in memory during a request; prompt content and document content are not written to any persistent storage on our servers.

Saved library content exists in two places: a local copy on your device (iOS on-device storage) and an encrypted copy on our servers. The server copy is sealed on your device with AES-256-GCM before upload; the encryption key lives in your device Keychain, may sync to your other devices through your personal iCloud Keychain, and is never sent to 214ID. We hold ciphertext we cannot decrypt. Because we do not hold your key, we also cannot recover your server-stored library if the key is lost (for example, by resetting iCloud Keychain with no signed-in device remaining).

Trust Receipts are stored on our servers and on your device; they contain interaction metadata and signatures only, never prompt or document content. You can delete locally stored prompts and receipts at any time from within the App (Settings → Clear Library & Receipt Data); server-side copies are removed when you delete your account (see Section 7).

4. Information Shared With Third Parties

We share information with the following third parties to operate the App. We do not sell your information to any party for advertising or marketing purposes.

Anthropic, PBC. Your prompt text and any attached document or image content are transmitted to Anthropic’s API to generate feedback and a refined prompt. Anthropic processes this data as a service provider under their API terms. Anthropic does not use API-submitted content to train its models by default. Only content you submit for refinement is sent to Anthropic; your saved library is encrypted on your device and is never shared with Anthropic or any other third party. For more information, see Anthropic’s Privacy Policy.

Apple Inc. Sign in with Apple is used for authentication. Apple processes your Apple ID credentials subject to Apple’s privacy policy. Subscription purchases are processed by Apple through the App Store. Apple’s App Store Server API is used to verify subscription status. For more information, see Apple’s Privacy Policy.

Cloudflare, Inc. Our backend infrastructure is hosted on Cloudflare. Cloudflare may process data that passes through our Workers as part of infrastructure operation. For more information, see Cloudflare’s Privacy Policy.

We may disclose your information if required by law, regulation, or valid legal process, or to protect the rights, property, or safety of 214ID, our users, or the public.

5. Data Retention

Account identity (Apple sub, email) and profile information are retained for as long as your account exists. You may request deletion at any time; see Section 7.

Subscription transaction records are retained for up to seven years for accounting and compliance purposes, even after account deletion.

Server logs are retained for up to 30 days.

Encrypted saved library content, Trust Receipts, and learning module progress stored on our servers are retained until you delete your account.

Data stored on your device (saved prompts, Trust Receipts) is retained until you delete it within the App or uninstall the App.

6. Children’s Privacy

The App is intended for senior professional users and is not directed at children under the age of 13 (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us at privacy@214id.com and we will delete it promptly.

7. Your Rights and Choices

Depending on where you are located, you may have the right to access, correct, or delete your personal information; to restrict or object to certain processing; and to data portability. To exercise any of these rights, contact us at privacy@214id.com.

Deleting local data. Within the App, go to Settings → Clear Library & Receipt Data to delete all locally stored prompts and Trust Receipts.

Deleting your account. Within the App, go to Settings → Delete Account to delete your account and all associated server-side data, including your encrypted saved library and Trust Receipts (excluding transaction records retained for legal compliance). You may also email privacy@214id.com from the address associated with your Apple ID, or contact us through the support address below; we will process emailed deletion requests within 30 days.

Subscription management. You may cancel your subscription at any time through iOS Settings → Subscriptions. Cancellation stops future billing but does not entitle you to a refund of amounts already charged; refund requests are handled by Apple under the App Store terms.

Opting out of Sign in with Apple data sharing. You may control what information Apple shares with us at the time of sign-in. If you used Hide My Email, Apple routes messages through an anonymized relay address. You can manage this in iOS Settings → Apple ID → Password & Security → Apps Using Apple ID.

8. California Privacy Rights (CCPA)

California residents have additional rights under the California Consumer Privacy Act, including the right to know what personal information we collect, the right to delete personal information, and the right to opt out of the sale of personal information. We do not sell personal information. To exercise your rights, contact us at privacy@214id.com.

9. International Data Transfers

Our backend infrastructure is operated in the United States via Cloudflare. Anthropic is also based in the United States. If you access the App from outside the United States, your information may be transferred to and processed in the United States or other countries. By using the App, you consent to this transfer.

10. European Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, the General Data Protection Regulation (GDPR) or equivalent local law applies to our processing of your personal data.

Data controller. 214 Innovation & Development is the data controller for personal data processed in connection with the App. Contact us at privacy@214id.com for any data protection enquiries.

Lawful basis for processing. We rely on the following legal bases:

• Performance of a contract: processing your account identity, session tokens, and subscription data is necessary to provide the App and fulfil your subscription.
• Legitimate interests: operating and securing our backend infrastructure, generating server logs for abuse prevention, and improving the reliability of the App. These interests do not override your fundamental rights.
• Consent: where you voluntarily provide optional profile information (role, organisation, context), we process it on the basis of your consent. You may withdraw consent at any time by removing or updating your profile within the App.
• Legal obligation: retaining subscription transaction records for accounting and tax compliance.

Your rights under the GDPR. You have the right to:

• Access: request a copy of the personal data we hold about you.
• Rectification: ask us to correct inaccurate or incomplete data.
• Erasure: ask us to delete your personal data ("right to be forgotten"), subject to legal retention obligations.
• Restriction: ask us to restrict processing of your data in certain circumstances.
• Portability: receive your personal data in a structured, commonly used, machine-readable format.
• Objection: object to processing based on legitimate interests.
• Withdraw consent: where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at privacy@214id.com. We will respond within 30 days. We may need to verify your identity before fulfilling a request.

International transfers. Our servers are located in the United States. Transfers of personal data from the EEA to the United States are made on the basis of Standard Contractual Clauses (SCCs) where applicable, or under Cloudflare’s and Anthropic’s respective data transfer mechanisms. You may request a copy of the applicable transfer safeguards by contacting us.

Right to lodge a complaint. You have the right to lodge a complaint with your local data protection authority. In the EU, a list of national authorities is available at edpb.europa.eu. In the UK, the relevant authority is the Information Commissioner’s Office (ico.org.uk).

11. Changes to This Policy

We may update this policy from time to time. When we do, we will update the "Last updated" date at the top of this page. If changes are material, we will provide notice within the App. Your continued use of the App after any changes constitutes your acceptance of the updated policy.

12. Contact

If you have questions about this policy or our privacy practices, please contact us:

• General: mattsanf@214id.com
• Website: www.214id.com