Privacy Policy
This Policy is a working disclosure for Turing. It is not a substitute for independent legal advice. A qualified EU/Portugal lawyer or DPO should review it before a public commercial launch — especially sub-processors, transfers, and legal bases under GDPR.
Controller: Turing, Portugal · App: Turing · Contact / data requests: privacy@turingfx.com
1. What we collect
Account data: email, authentication identifiers, and, if you use Google or Apple sign-in, the basic profile they share.
Content you provide: your questions, uploaded images or documents, and generated results.
Usage & billing data: credits used, plan, transactions (payments are handled by our processor; we do not store full card numbers), and device or log data (IP, timestamps) for security and analytics.
2. How we use it
To provide the Service (process your requests and generate answers) — performance of contract.
To operate accounts, credits, and payments — contract / legal obligation.
To secure the Service and prevent abuse — legitimate interests. Safety logs store a category and timestamp only, not the harmful prompt.
You own your content (prompts, uploads, simulations, results). Sharing a live sim or gallery item is opt-in.
We do not use your questions or uploads to train a public model. The model processor is configured for zero retention / no training where the account allows it. Limited, aggregated usage data may be used to keep the Service reliable. You can export or delete your data in Settings.
3. Sub-processors & third parties
We use trusted third parties strictly to run the Service. Current technical stack:
- Hosting: Railway (compute + web)
- Database & authentication: Supabase (EU, eu-central-1 by default /
DATA_REGION) - Payments: Stripe
- Email (optional): Resend
- AI inference: a contracted model processor under a data-processing addendum; inputs are not used to train public models when zero-retention is on
We do not sell data or run third-party ads. A current list is also available at privacy@turingfx.com.
4. International transfers
Some processors may operate outside the EU/EEA. Where they do, we rely on appropriate safeguards such as EU Standard Contractual Clauses.
5. Data retention
We keep account and conversation data while your account is active and as needed to provide the Service, comply with law, and resolve disputes. Default erasure window after account deletion: 30 days (RETENTION_DAYS), subject to legal retention. You can delete conversations and delete your account in Settings. Encryption in transit (TLS) and encryption at rest for the database (Supabase) are on.
6. Your rights (GDPR)
You may access, correct, delete, restrict, or object to processing of your data, request portability, and withdraw consent. Contact privacy@turingfx.com. You may also lodge a complaint with the Portuguese supervisory authority (CNPD) or your local authority.
7. Security
We use technical and organizational measures to protect your data. No system is perfectly secure; we cannot guarantee absolute security.
8. Children
Turing is not directed to children under 16. We do not knowingly collect their data.
9. Cookies / local storage
We use necessary cookies and local storage to run the app and keep you signed in. We do not run a marketing-analytics banner at this time.
10. Changes
We may update this Policy. Material changes will be notified and you may be asked to re-accept.
11. Contact
Controller: Turing, Portugal · privacy@turingfx.com · support: hello@turingfx.com