1. Purpose and Roles
This Notice details how personal data is handled in practice across the website, console, and public API. Mindrift is the controller for account, billing, moderation, and API metering data. Infrastructure operators that process data on our behalf (hosting, GPU compute, email delivery, payments) act strictly as processors: they follow documented instructions, process only what is necessary, and are contractually barred from any secondary use, including model training.
2. Processing Register (Summary)
- Identity and access: email, username, avatar, hashed secrets, roles, session and API key metadata. Purpose: authentication and account administration. Basis: contract.
- Creations: prompts, parameters, reference images, outputs, collections, reports. Purpose: generation, gallery, moderation. Basis: contract; moderation under legitimate interests and legal obligation.
- Billing: balance, invoices, fees, charge records. Purpose: metering, invoicing, tax compliance. Basis: contract and legal obligation.
- Trust and safety: warnings, suspensions, appeals, IP and device signals. Purpose: enforcement and legal defense. Basis: legitimate interests and legal obligation.
- Telemetry: API logs (endpoint, model, tokens, cost, duration), error traces. Purpose: operation, debugging, abuse prevention. Basis: legitimate interests, minimized and access-restricted.
3. Compute and Storage Flow
Generation payloads are transmitted to GPU infrastructure solely for the duration of the computation and then discarded by design; only the resulting image (stored on our CDN for your retrieval), the prompt record, and the metering entry persist. Account and billing records live on secured database infrastructure with daily encrypted backups. API keys are stored exclusively as salted hashes: a leaked database reveals no usable key.
Cross-border transfers rely on adequacy decisions where available, otherwise on standard contractual clauses plus encryption in transit (TLS 1.3) and at rest (AES-256), strict need-to-know access, and processor audit rights in our contracts.
4. Retention Schedule
- Account lifetime: identity, creations, settings, API history.
- On deletion request: immediate hard delete from production systems; encrypted backups purged within 30 days; CDN copies invalidated and removed within the same window.
- Billing records: up to 7 years (tax law).
- Serious-violation safety records: retained as strictly necessary for legal defense or cooperation with authorities, under restricted access with periodic necessity review.
- Anonymized aggregates: irreversibly anonymized statistics (no re-identification possible) may be kept indefinitely for capacity planning.
5. Exercising Your Rights
Write to [email protected] from your account email stating the right and scope (access, export, correction, deletion, restriction, objection, consent withdrawal). We verify identity proportionately to the sensitivity of the request and answer within 30 days, extendable once by 60 days for complex cases with prior notice. Deletion executes per Section 4, subject only to billing, safety, and legal-hold exceptions which we will name explicitly in our reply. You retain the right to complain to your supervisory authority (CNIL in France).
6. Security Measures and Breach Response
Measures include TLS 1.3, AES-256 at rest for sensitive stores, hashed credentials and keys, scoped API permissions with IP allowlists and expiry, role-based production access with logging, segregated moderation tooling, and periodic external testing. No system is impregnable. On discovering a breach likely to risk individual rights, we contain, assess, notify the competent authority within 72 hours where required, and notify affected users without undue delay with facts, likely impact, and concrete protective steps.
7. Processors and Changes
Processor categories: GPU compute, hosting/CDN, transactional email, payment processing, and (for unlawful-content cases) competent authorities. A nominative sub-processor list is available on written request. Material changes to processors or this Notice are posted here at least 14 days in advance, and by email for significant changes.