Legal information

Privacy policy and GDPR

Last updated: 22 October 2026

DraftTo be approved by Amaury, ideally reviewed by a lawyer, before going live. English translation of the French version, still to be reviewed. Highlighted fields need to be filled in.

In short

Data is stored in the European Union. We don't sell it and don't use it for advertising. This website has no trackers and no analytics cookies.

Two different roles

For our customers' data (accounts, billing, use of the application), Apophisia is the data controller.

For the data our customers import into Replexa (leads, prospects, emails exchanged), the customer is the data controller and Apophisia acts as a processor: we process that data only on the customer's instructions, to provide the service. If you are a prospect contacted through Replexa, please contact the company that wrote to you first; we will help them respond to your request.

Data controller

Apophisia, [address]. Contact for any question about your data: [dedicated email, e.g. privacy@replexa.eu].

Data processed and purposes

DataWhyLegal basis
Email, name, password (hashed), two-factor authentication factorCreate and secure your accountPerformance of the contract
Workspace, members, roles, login logsRun the service, securityPerformance of the contract, legitimate interest
Billing data (via Stripe)Collect subscription payments, accountingPerformance of the contract, legal obligation
Connected mailboxes and their credentials (encrypted)Send and receive your campaign emailsPerformance of the contract
Leads, emails sent and received, statusesProvide the service on the customer's behalf (processing)The customer's own legal basis
AI usage (volume, not content)Count AI creditsPerformance of the contract

Service providers (processors)

ProviderRoleLocation
Supabase, Inc.Database, authenticationIreland (AWS eu-west-1)
Cloudflare, Inc.Hosting of the website and the application, network protectionGlobal network, US company [to check: data localisation options]
Anthropic, PBCAI model (Claude) used to classify replies and draft messagesUnited States [to check: processing region and transfer safeguards]
StripePayments and billingEuropean Union and United States
ResendWorkspace invitation emails (if enabled)[to check]

Services you connect yourself (Google Calendar, HubSpot, Pipedrive, Salesforce, Airtable, Zapier, Make, n8n…) receive the data needed for the integration you enabled, under their own terms.

For transfers outside the European Union, we rely on the EU-US Data Privacy Framework when the provider is certified under it, and otherwise on the European Commission's standard contractual clauses [to be confirmed provider by provider].

Artificial intelligence

To classify a reply or draft a response, the relevant text is sent to Anthropic's API. Under its commercial terms, Anthropic does not train its models on data received through its API [to check against the current terms]. Incoming email content is treated as data, never as instructions to the agent.

Security

  • Mailbox passwords, integration keys and tokens are encrypted at rest and never returned by the API.
  • Two-factor authentication available on every account, and enforceable across a whole workspace.
  • Strict data separation between workspaces, with roles and permissions per member.
  • Encrypted HTTPS connections between your browser and the application.

Retention periods

  • Account and workspace: for the duration of the subscription, then [period] after deletion.
  • Data imported by the customer: until the customer deletes it or deletes the workspace.
  • Invoices: 10 years [depending on the applicable law].
  • Technical logs: [period].

Cookies

The replexa.eu website only sets strictly necessary cookies, with no advertising or analytics: rx_lang remembers the language you picked with the language switcher (one year), and rx_ref keeps the code from a referral link (7 days) so the application can credit the referral when you sign up. Your theme choice is kept in your browser's local storage and never leaves your device.

The app.replexa.eu application only uses cookies needed for it to work: your login session, your chosen theme and the menu state. They are not used for advertising or analytics, so they do not require consent.

Your rights

You can request access to your data, its rectification, erasure, restriction or portability, and object to its processing. A workspace owner can export all of its data as JSON from the application. For any request, write to [dedicated email]; we reply within one month.

You can also lodge a complaint with the supervisory authority: [CNPD in Luxembourg or CNIL in France, depending on where Apophisia is established].