Privacy Policy
Last updated: 2 October 2026
Your brain is yours. We process your saved content to provide, protect and back up Brainbox. This policy explains what the rebuilt service stores, who processes it and how to exercise your rights.
1. Who we are
Brainbox ("the Service") is operated by CIF AI Holdings Limited (company no. PVT-L51DY5MR), a private limited company incorporated in the Republic of Kenya under the Companies Act, 2015, trading as thexi.dev ("we", "us", "our"). CIF AI Holdings Limited is the data controller for your account data. For any privacy question, contact [email protected]. Registered office: Serengeti Homes, Kongoni 9B, Ngong Road, Kileleshwa, Nairobi, Kenya; postal address P.O. Box 12168, 20100 Nakuru, Kenya.
2. What we collect
- Account identity: your verified Google email, Google account identifier and workspace identifier. Google handles your sign-in. Session cookies keep you signed in for up to 12 hours; short-lived sign-in and consent cookies bind the login to your browser.
- Saved content: memories, lessons, session digests and Journey relationships you or connected apps explicitly submit. Brainbox does not automatically capture every conversation in your AI apps.
- Operational data: request and error metadata, authentication records, usage counts and delivery status needed to run, secure and support the Service. Our operator counters exclude memory text, search queries and conversation titles.
- Registration enquiries: information you choose to submit through the Register Interest form, hosted by HubSpot.
3. How we use it
- To authenticate you and route requests to your own workspace.
- To store, retrieve, correct and back up your saved content.
- To secure the Service, manage capacity and diagnose faults.
- To handle registration enquiries, support and essential service notices.
- With your separate opt-in, to send a weekly activity email. You can unsubscribe without closing your account.
We process data to provide our contract with you, on your consent where required, and for our legitimate interests in operating and securing the Service, subject to applicable law. Optional weekly email uses separate consent; registering interest does not subscribe you to it.
AI processing: Cloudflare Workers AI processes memory and search text to create numerical embeddings used for retrieval. The rebuilt service does not automatically generate session summaries or send your memories through an answer-generation model. Connected AI apps may process retrieved memories under their own policies.
We do not sell your saved content or use it to train our own models. Processing providers handle data under their applicable service and data-protection terms. This is not end-to-end encryption: authorised operational access may be needed to provide support, security or recovery.
4. Where your data lives & who processes it
| Provider | Purpose | Location |
|---|---|---|
| Account authentication | Google's international infrastructure | |
| Neon | PostgreSQL workspace databases and search vectors | Configured AWS Europe (Frankfurt) region |
| Cloudflare | Public website, application and MCP service, authentication state, usage counters, Workers AI embeddings and R2 backups | Distributed infrastructure; not limited to Kenya |
| Resend | Optional weekly activity email and delivery/suppression metadata | Configured US East region |
| HubSpot | Register Interest form and submitted enquiries | Configured North America form region |
The public thexi.dev website also loads the Tarjumi translation widget and uses Cloudflare services. The registration form loads HubSpot only after you choose to load it. Providers may process technical information such as IP address and browser details. The signed-in Brainbox workspace and connected AI apps are separate surfaces with different processing.
International processing: data may be processed outside Kenya. We use contractual provider protections, access controls and encrypted transport to safeguard it, and will provide information about applicable transfer arrangements on request. Contact us before storing data subject to a specific residency requirement.
The rebuilt service uses the providers above. Recovery of historical data from the earlier AWS deployment is still pending; it has not automatically been imported into the new workspace.
5. Backups
Scheduled nightly exports write consistent workspace snapshots to Cloudflare R2. The retention target is 14 days. Cleanup runs after successful exports; failed exports can delay removal of older backups. This is a retention target, not a guarantee that every copy expires exactly on day 14.
Backups can contain earlier or deleted content until cleanup. Recovery must honour deletion records rather than silently restoring forgotten memories. Backups are an operational recovery measure; keep your own copies of critical information.
6. Your rights
Under the Kenya Data Protection Act, 2019, and other applicable laws, you can request information, access, correction, erasure, objection and portability of your personal data.
- Access and export: browse and recall your saved content through the workspace or connected apps. The dashboard lets you download your workspace’s latest published backup snapshot and shows its completion date. It reflects that recorded state; changes made afterwards are not included. This snapshot is not a complete account export. Contact [email protected] for an account export.
- Correction and individual deletion: use correction and Forget controls in the workspace or authorised API. Forget removes the active item's content and vector; backup copies expire through the backup process. Fingerprints and deletion markers remain to prevent accidental re-import.
- Account deletion: send a request to [email protected]. We verify the requester and confirm the deletion steps, timing and any lawful retention. Full account deletion is currently handled by request, not a dashboard button.
- Optional email: change the preference or use the unsubscribe link. Email opt-out is separate from account deletion.
- Complaint: contact Kenya's Office of the Data Protection Commissioner or your local supervisory authority.
7. Retention — the lifecycle of a memory
| Data | Lifecycle |
|---|---|
| Active saved content | Retained while your workspace is active until you delete it. Correction replaces active text; the rebuilt service does not keep a browsable copy of every earlier version. |
| Deletion markers | Fingerprints and tombstones remain to prevent forgotten content being re-imported; these are not guaranteed to be anonymous. |
| Application backups | 14-day target, with cleanup after successful exports. |
| Activity counters and webhook event records | 35-day application retention window, pruned when the relevant service runs. |
| Email delivery records | 180-day application retention window, pruned when the relevant service runs. Preference and suppression records remain to respect your choice. |
| Enquiries and service-provider records | Kept as needed to handle the enquiry, run the Service and meet legal obligations. Provider logs and recovery copies have separate retention arrangements; ask us for details. |
The optional weekly email contains activity counts and a sign-in link, not saved memory text or conversation titles. Resend receives the recipient address and delivery metadata. Open and click tracking are disabled on the sending domain.
8. Security & breach notification
Brainbox uses verified Google identity, scoped credentials, isolated workspace databases, encrypted transport, access controls and usage limits. Keep your connected apps and machine keys secure, and authorise only apps you trust. No system is perfectly secure.
If a breach affecting your personal data occurs, we will notify the ODPC within 72 hours of becoming aware of it and notify you without undue delay, as the Kenya DPA requires.
9. Children
The Service is not directed at children under 16, and we don't knowingly collect their data.
10. Changes
We'll post changes here and update the date above. We'll notify you of material changes by email.