Privacy Policy: Nawame (application)

Version 1.2.14 of 23 October 2026

1. Data controller

The controller of personal data processing is:

• HTTP5000, a SAS (French simplified joint-stock company) with a share capital of €15,024,
• SIRET (company registration number) 43190337600033, VAT number FR48431903376,
• Registered office: 3 rue Passet, 69007 Lyon, France,
• Publishing director: Maximilien HAIBI,
• Contact (personal data): info@nawame.eu.

2. Founding principle: what is private stays private

Nawame is designed so that a user's personal content is neither read nor exploited by the Publisher. What is private remains invisible to other users and to any organization for as long as the user does not decide to share it. Sharing is always an explicit act of the user. In a memory declared a collaborative channel, that act is joining: personal, explicitly confirmed (confirmation word, code received by email, or console) and revocable at any time; it allows contributing to the common content without re-confirming each contribution. A channel has no private layer within the collaborative thread itself: private work remains possible, but in separate annex memories that no one else reads. A participant who does not join reads according to their rights and does not contribute.

With respect to the Publisher, the guarantee depends on the applicable mode (see section 8):

• in standard mode (the default), content is technically decryptable by the Publisher. This technical access is strictly limited: reserved to a small number of authorized persons, it is exercised only to operate, maintain and secure the Service, or upon a duly issued judicial order, and never to read or exploit content for any other purpose (see 8.1);
• in sovereign mode, the Publisher does not hold the key and cannot decrypt, including upon a judicial order.

3. Data processed

Secrets: the Service does not host the values. Nawame does not host passwords, API keys or other secret values and is designed never to receive their value. When a user chooses to record where a secret is stored, only a pointer is kept (logical name, readable location, usage, and coordinates or a link to the client's external vault); the value stays with the holder (see §7 bis). Any encrypted keys inherited from an earlier version are never again decrypted or disclosed: they are flagged as "to be rotated".

3 bis. Minimum age: Nawa is reserved for people 18 years of age or older

The Service, and Nawa in particular (public beta), is reserved for people 18 years of age or older. There is no route for minors and no parental authorization. On entering Nawa (app, WhatsApp or Telegram), the person attests that they are 18 or older through an explicit, unticked box or button; the record (document "majority", version, date, context) is kept in the consent log, on the basis of performance of the contract (condition of access). The attestation is declarative: the Publisher asks for neither a date of birth nor an identity document and does not check age. An earlier account gives it at its next access to Nawa, which stays closed until it is given; without it, nothing is opened and nothing more is kept. If the Publisher learns that an account belongs to a person under 18, it closes it and erases its content under the conditions of section 9. For a gift (§5 ter), the person giving may give it only to a person 18 or older, and the recipient is informed of this condition before accepting.

4. Purposes and legal bases

5. Content and its (non-)exploitation

The Publisher does not exploit the content of memories for commercial purposes, profiling or model training. Content is stored, versioned and returned according to the user's instructions and the access rules they have defined (private personal spaces, organizations, teams).

5 bis. Nawa: voice conversation, quality signals and technical telemetry

Nawa is Nawame's conversational application: a presence the person talks with to compose their personal memory as they tell their stories. The content of these exchanges (typed text, or transcribed speech) is neither read nor exploited by the Publisher for any purpose other than operating the Service.

Nawa is not available in sovereign mode, in this version. Three distinct contents are concerned, each under a different regime:

1. Content specific to Nawa (the complete transcript of every exchange with Nawa, typed text or transcribed speech, including a finished story; recording segments; suggestions, including the text of those already kept, only forgotten suggestions being cleared of their content) is not encrypted to the standard promised by sovereign mode (§8.2): it is stored in clear text server-side, with no retention limit other than full account erasure (only an explicitly abandoned draft or recording is deleted before that, see §9). The messages you have addressed to Nawa are included in your export, with their date and channel, as are what you said you do not know and the history of your connected AI settings (§5 quinquies); the rest of this content is not, but remains subject, like the rest of your data, to the right of access and to a targeted erasure request (§11). Rather than weaken the sovereign promise or write in clear text for an account that has chosen this mode, the Publisher refuses access to Nawa (reading and writing) for any account in sovereign mode: this content then remains inaccessible through Nawa. The block is reversible: disabling sovereign mode from the console reopens Nawa normally, with no loss of this content. This does not affect that account's working memory (Nawame console), which remains usable normally. 2. What Nawa has already written into working memory before sovereign mode was activated (a memory that was kept, a Nawa Story, a reflection recorded from the Journal, a perspective, a prepared edition) is a copy, distinct from the Nawa-specific content described above: once written, it follows the ordinary regime of memory (§3, §5), at the standard, clear-text level, like any other memory not placed in sovereign mode. Blocking Nawa does not make it inaccessible: it remains readable from the console, by a connected AI with the appropriate rights, and it is included in an export. Enabling sovereign mode retroactively encrypts neither this copy nor Nawa's own content (point 1). 3. An edition already shared with another person remains readable by its recipient(s) even if the narrator later enables sovereign mode: an edition is necessarily in clear text (it cannot be prepared from a sovereign source), and the share was a deliberate choice made by the narrator before that activation. Withdrawing that share from the interface is not yet possible once the account has switched to sovereign mode (planned extension, see the "sovereign Nawa" roadmap item): contact info@nawame.eu for manual handling in the meantime, or disable sovereign mode to regain normal access to Nawa (point 1).

Speech and transcription. When the person speaks aloud, no raw audio recording is retained by the server: the audio passes through volatile memory for the duration of its transcription, is transmitted to the provider the Publisher relies on for transcription and speech synthesis (see §6), then discarded. It is never written to disk, backed up or logged. Only the transcribed text is kept server-side, under the same conditions as typed content. On the person's own device, the recording stays in local browser storage until its transcription is confirmed; after an interruption, it is kept there to allow resumption, then erased on resumption or on a later recording past a technical delay. It is never transmitted anywhere other than to the transcription provider.

A second technical measurement, distinct from and predating the quality signals described below, associates technical operating information about a recording (duration, platform, technical browser identifier) with the session and account concerned, to diagnose recording incidents. Unlike quality signals, it is tied to the account and the session; it is retained until the account is erased.

Quality signals (Service reliability). To diagnose and improve Nawa's reliability (for example: a failed recording, a navigation aid wrongly suggested), the Service records structured technical events, strictly bounded:

• Categories collected, and nothing else: the type of technical difficulty encountered (for example a failed transcription), a technical error code, the outcome (success, failure, abandoned, recovered), the screen concerned, the reason a navigation aid was shown (for example an ambiguity or low confidence in understanding), the options offered within that aid and the choice made (inferred from keywords in the typed message, never copying it), a timestamp rounded to the hour, and technical measurements (duration, device type).
• No intimate content, no free text. The content of a conversation, a memory or a typed message never enters these events, including when the person chooses "Other" within a suggested navigation aid.
• No account or session identifier is retained with the event itself.
• Handled with caution, never described as anonymous. This data is strictly technical, but the Publisher does not present it as legally anonymous: at low volume, an indirect correlation with other internal technical logs remains possible. This is precisely why it remains governed by the safeguards below rather than presented as falling outside the scope of this policy.
• Retention: 30 days at most, with automatic deletion (see §9).
• Legal basis: legitimate interest (Art. 6(1)(f), see §4), without dedicated consent: the data is minimal, structured, content-free, and diagnostic access (excluding the application's own role and backups) is restricted to read-only, column by column, with no identifying column (account, session, name, address) on this table whatsoever.

Agentic technical telemetry (OpenTelemetry). To diagnose latency, errors and regressions in Nawa and improve how it operates, the Service may also record structured technical traces describing the steps of a single processing run. These traces are separate from conversation content and from the quality signals described above.

• Categories collected: technical operation performed (for example message processing, memory retrieval, model call, memory-write decision, sending), outcome and closed error code, duration, channel (Telegram, WhatsApp or application), model family and provider, coarse token/cost/size classes, retrieval depth, retry classes, and structured indicators of memory use and memory-write decisions.
• Ephemeral correlation for one processing run only: a random agent_run_id is created to link the technical steps of one processing run. It is not derived from the account, phone number, channel or a memory; it is not reused for the next message and is not intended to track a person over time.
• No content in traces: no message, prompt, response, transcript, memory, story, search query, name, email address, phone number, Telegram/WhatsApp identifier, account/memory/session identifier, URL, raw User-Agent or free-form exception message. Free-form values are rejected in favor of closed lists, booleans and classes.
• No profiling or model training: these traces are used only for diagnosis, operational security, performance measurement and improvement of Nawa's reliability. They are not used for advertising, commercial profiling or model training.
• Hosting and access: traces are hosted in the European Union on the Publisher's infrastructure, with access restricted to persons authorized for diagnosis. Transport is encrypted and authenticated; dedicated storage is encrypted at rest.
• Retention: 30 days maximum, followed by automatic deletion (see §9).
• Legal basis: legitimate interest (Art. 6(1)(f), see §4). The interest pursued is to detect incidents, latency and regressions and improve Service reliability using minimal technical data and no content. You may exercise your right to object to this processing by writing to info@nawame.eu; the request will be assessed under the conditions provided by the GDPR.

Any future feedback you provide as free text (a future explicit feedback form, distinct from the technical signals described here) would be the subject of separate information and, where applicable, a separate collection of consent, before it is put in place.

5 ter. Nawa: a gift offered by someone else

This section is the information that the GDPR (Article 14) requires for a person whose data does not come from them: someone to whom a loved one gives Nawa. It is written to be read without having an account.

When someone gives you Nawa ("the person giving"), they can prepare your welcome: a few things they tell about you, questions they would like to ask you and a personal message. They send you the invitation link themselves, from their own messaging app. Nawa does not write to you first and sends you nothing until you have opened that link. If you do not open it, nothing happens for you and what was prepared is deleted when the gift expires.

• Who is responsible. HTTP5000, SAS, publisher of Nawame (contact details in §1). For any question or request: info@nawame.eu.
• Where the data comes from. From the person who gave you Nawa, not from you and not from a public source. Nawa always tells you who it comes from. It is not your memories: it is that person's words.
• What data. The free text that person wrote about you (things told, questions, message), the first name or label they use for you, and the state of the gift (prepared, sent, accepted, opened). In the current flow, they give Nawa neither your phone number nor your email address. The ones you give afterwards to prove that the link is really for you concern you directly: they are collected from you (§3).
• Sensitive data. The person giving is asked not to share anything about health, beliefs, intimate life or opinions, and sensitive topics are detected and refused. This detection is automatic and does not guarantee the absence of such items: if one gets through, it is never used for anything other than its transport, it is never processed on the basis of legitimate interest, and you may ask for its immediate deletion.
• Single purpose. To welcome you: to let the person giving prepare and pass on a private invitation, and to let you read it if you accept it. These items are not used for search, for consolidating your memory, for statistics, for training models, for marketing, or to build a profile of you. They are neither read by Nawa's search nor built into the instructions of its language model: only your own words are.
• Legal basis, one flow at a time (1): preparation by the person giving. What they write is first filed in their own private memory, which remains theirs (§2 and §5): the Publisher processes it on their behalf, in performance of the contract concluded with them (Art. 6(1)(b)), without reading or exploiting it.
• Legal basis (2): envelope kept before your acceptance. Legitimate interest (Art. 6(1)(f)), strictly limited to allowing the person giving to prepare and pass on a private invitation. This interest was weighed against your rights: retention is indispensable for transport (without it, the invitation cannot be passed on); strong minimisation (the text alone, nothing else about you); short duration (30 days at most); no use, no commercial enrichment, no profiling; nothing is shown to you until you have proved your phone and your email address; declining, blocking and deletion are easy. A person to whom a loved one gives a service reasonably expects a message to be passed on to them, not to be exploited: which is why it is not. This basis never covers sensitive data.
• Legal basis (3): after your acceptance. Performance of the contract (Art. 6(1)(b)) for what is strictly necessary to the service (handing you what was prepared, letting you confirm, correct or ignore it). Where a feature genuinely requires Article 9 data (for example a piece of health information that you confirm in your own words), it is your own speech: it rests on your explicit consent (Art. 6(1)(a) and 9(2)(a)), expressed by that act and withdrawable at any time.
• Before you see anything. The link you received delivers nothing. A fixed text, with no name and no content, refers you to this information. After your phone and email address are verified, you see the person's first name and the description of this processing, then you accept or decline. If you accept, the person can then open what they prepared for you; you only read it at that point.
• Your memory. Nothing enters your memory unless you say it yourself, in your own words. Confirming, correcting or ignoring an item does not create a memory by itself.
• The questions. The person giving can prepare up to 50 questions. They are presented only one at a time, and only after a first free conversation; each one can be ignored, postponed or muted for everything its author asks. A postponed question remains available as long as the link exists; its text is emptied as soon as it is handled, withdrawn or expires. Once the gift is opened, these questions follow the rules for questions between relatives (§5 octies).
• Their own memories. The person giving can also tell their own memories: they remain theirs and private, unless they choose to share them.
• Retention. What the person prepared is deleted no later than 30 days after the gift was created if it has not been opened. Once opened, each item is deleted as soon as you have handled it (confirmed, corrected, ignored) and no later than 30 days after it was opened, except the questions, which remain available as described above. The gift's tracking line, with no text at all, is deleted 60 days after the gift ends. Your refusal to receive anything from that person is kept as long as your account exists, so that it is respected.
• Who receives this data. The Publisher's processors listed in §6 (hosting) and, when you talk to Nawa through WhatsApp or Telegram, the operator of that messaging service, which acts on its own account. The person giving receives nothing of what you do: they only know that you accepted. No data is sold or transferred.
• Your choices. You can decline, ignore each item, stop receiving anything from that person (they are not told and can no longer get you to accept a link or a gift through Nawa), or delete your account at any time: everything about you is then erased, including what had been opened for you.
• Your rights. Access (these items appear in your account export once opened), rectification, erasure, restriction, and objection to this processing without having to justify yourself, by writing to info@nawame.eu (answer within one month, §11). You may also lodge a complaint with the CNIL (§11).
• What the person giving has already kept. What they wrote about you in their own private memory is their content, which the Publisher does not read (§2). You may nevertheless write to us for any request concerning you: we examine it under the conditions of the GDPR, taking into account that this memory belongs to another person.

5 quater. Nawa: the feedback you choose to send to the team

You can tell the Nawa team what bothers you, what you would like, or what does not work. It is always an action on your part: Nawa never passes anything about you to the team on its own initiative.

• What is sent. Only the text you reviewed and confirmed ("I confirm that this text may be sent to the Nawa team"), the type you chose, the channel it came from, the date and an internal identifier of your account. Never your conversations, never your memory, never the name of an AI provider. What is recorded is exactly the text you confirmed, without rewriting.
• Why, and on what basis. Improving Nawa at your request: your consent (Art. 6(1)(a)), given by the confirmation, withdrawable at any time. Do not put sensitive data in this text: it does not need any.
• Who reads it. Only the people of the Nawa team in charge of product and support, explicitly designated; not every administrator has access. Every read is logged (the number of texts read, never their content). No artificial-intelligence processor receives this text. The team's weekly review contains only numbers and labels, with no free text, and hides groups that are too small.
• What you receive. A short reply chosen among a few formulas (thank you, taken into account, in progress, fixed, more detail would help), which you read in your Nawa space. Never an unsolicited message in your messaging app.
• Your rights. You see what you sent and can withdraw a piece of feedback at any time: it is then deleted immediately. It is included in your data export and deleted with your account.
• Retention. 365 days at most from the last trace (sending, reply or handling), then automatic deletion.
• Limit. A limited number of pieces of feedback per day and per account protects the service; an identical piece sent twice is recorded once.

5 quinquies. Nawa: what you tell it, how it is kept and how it is re-read

This section explains what becomes of what you say to Nawa, and what it is used for. It supplements §5 bis, which describes the content specific to Nawa.

• What is kept. The messages you address to Nawa (through WhatsApp, Telegram, in the app, by voice once transcribed and, if you turned it on, those your connected AI passes to it, see §7) are kept as you wrote or said them, with their date and the channel they came through. This is the source material of your memory: filed memories are drawn from it, but a filed memory can be reworked or leave out a detail, whereas the source material remains what you actually said. It is not a separate, independent memory: it is the continuity source of the Nawa memory. It is stored like the rest of the content specific to Nawa (§5 bis point 1), in clear text server-side, for the lifetime of the account (§9).
• Kept first. Each message is recorded before any other operation, without any language model being involved: a failure or a misunderstanding does not make it disappear.
• Automatically re-read when searching. When filed memory is not enough to answer a question (a detail you said that was not kept), Nawa may automatically re-read this source material, only to answer you from what you actually said. The answer says when and through which channel you said it. This re-reading is not used for profiling, statistics or model training. To check that an excerpt really answers your question, excerpts may be submitted to the processor in §6 that handles Nawa's text processing, under the same conditions as the rest of Nawa's operation. A re-read text is information, never an instruction: Nawa carries out nothing that it contains.
• Never one more fact about you. A reply written by Nawa or by an AI is never automatically turned into a fact about you: an inference stays an inference, what someone else told you stays reported, a question is never evidence, what you deny stays denied, and a correction from you replaces the earlier value, which is no longer presented as true. A sensitive topic is never kept automatically: it waits for your decision.
• Nawa's replies in the current conversation. So that the conversation stays coherent and Nawa does not repeat itself, its own replies may exist temporarily in the active conversation, alongside your messages. This copy never becomes a memory, is never used as material about you (neither for a story nor for re-reading during a search) and disappears as soon as the passage is filed away, or after 20 minutes of silence. "Forget what I told you about …" removes it too, and it is erased with the account.
• Provenance is kept. Each item keeps its date and channel, and shows whether it comes directly from you or from messages passed on by your connected AI. As Nawa cannot verify that a text passed on by an AI is exactly yours, it is never presented as a word-for-word quotation.
• What you said you do not know. When you say you do not know something ("I don't know Paul's surname"), Nawa remembers it as such: it answers "you told me you do not know" rather than "I find nothing", and does not mechanically ask you the question again. If you learn it later, the answer takes its place.
• Your actions. You can correct what Nawa has kept. You can tell Nawa "forget what I told you about …" (in French, "oublie ce que je t'ai dit sur …"), in the messaging channel or in the Nawa app: the words concerned are no longer re-read by searches, immediately, and what Nawa had already filed on that subject (kept memories, pending proposals) is removed too. This action is yours: your connected AI cannot do it for you, you do it in Nawa (messaging or app). Forgetting a memory also removes from searches the words it came from. You can say "ne rien retenir" (keep nothing): your messages stay kept (nothing is lost) but are never re-read while the pause lasts. For definitive deletion, the usual mechanisms apply (§11): erasing a passage rewrites both copies in which it appears (the source material and the full transcript of the exchange), and closing the account erases everything (§9).
• What you type, even before you send it. When this protection is active in your app, what you type in the conversation is kept as you go, on your device and on our servers, even before you send it, so that you lose nothing. Once sent, this draft is emptied. A draft you do not send is emptied no later than 90 days after your last keystroke. A draft is never read by the language model. Recorded speech stays on your device until it is transcribed: no sound recording is kept by our servers (§5 bis).
• Your connected AI. Your connected AI's reading of this material depends on your setting (consent, see §7); passing your messages to Nawa depends on a separate setting that only you can turn on, in the Nawa app (see §7).
• Legal basis. Performance of the contract, since it is the Nawa service you use; for Article 9 data that you entrust, your explicit consent (§4).
• Your rights. These items are included in your data export and covered by the rights of access, rectification and erasure (§11).

5 sexies. Orders and paid subscriptions

This section applies to every paid order: Nawame subscription (Plus or Organization), Nawa subscription (Nawa, Nawa Bavard, Nawa Duo), gift or read-aloud credit. It supplements the terms of sale.

• What is collected with each order. Acceptance of the terms of sale in force (version and date), renewed with each order; the express request that performance begin before the end of the withdrawal period, through an unticked box (text displayed, version and date); the age attestation (purchases are reserved for persons aged 18 or over, terms of sale 4.3), kept in the consent log as for entry into Nawa (§3 bis). The order itself (plan, period, amount paid, dates) is billing data.
• Customer organization (Organization plan). The Organization plan is reserved for professional customers. When subscribing, the person who subscribes declares that they act for the purposes of a professional activity or on behalf of a legal person, and states the name, address and an official identifier of the customer organization (SIREN or RNA number in France, intra-Community VAT number or registration number outside France). This information is used to open the payment and to issue the organization's invoices, issued by the payment provider (§6), which keeps it with the billing customer; the Service erases it from its record as soon as the checkout session ends (paid or abandoned). It only keeps the proof of the declaration: account that made it, organization, text (version) and date, order reference and acceptance of the terms of sale (version, date). An intra-Community VAT number appears on the invoice without any exemption or reverse charge. Only the paying account and the Publisher's authorized staff see invoices, payment methods and billing details (terms of sale 3 bis.6).
• Withdrawal. The consumer may withdraw online from the Settings of the Nawame console, as from their Nawa space or a gift page (terms of sale 7.5). The date and time of the declaration, the amount due and the amount refunded are recorded; for a Nawame subscription, also the first and last name, the contract concerned and the email address at which to receive the acknowledgement. The acknowledgement, sent by email, restates the content of the declaration. The refund is carried out by the payment provider.
• Termination. Termination from the Settings of the console or from the Nawa space (terms of sale 6.3 and 6 ter.6) is recorded with its date; its confirmation is sent by email with the end date of the subscription.
• Subscription paid twice. If a second paid subscription is opened in parallel for the same account or the same organization, it is terminated and its payments are refunded in full (terms of sale Article 8). To carry out this refund and retry it after a failure, the Service keeps only the identifier of that subscription at the payment provider (a pseudonymous identifier), a date bound, the number of attempts and their dates: no name, address or amount. This information is deleted automatically 13 months after the refund.
• Email notices. The Service sends you the confirmation of your order, the renewal notice for an annual subscription (between three months and one month before the renewal date), notice of the end of a beta or complimentary licence, confirmation of a termination or of its cancellation, and a warning of a failed payment. These are messages linked to the contract, never marketing.
• Legal basis. Performance of the contract and pre-contractual steps (Art. 6(1)(b)); legal obligation (Art. 6(1)(c)) for the information and proof required by the French Consumer Code (express request, withdrawal, renewal, termination) and for invoices.
• Retention. See §9.

5 septies. Nawa Duo: two people, two private memories

Nawa Duo is a subscription paid by one person ("the payer") for themselves and for a second person (terms of sale, Article 6 ter.4).

• Two accounts, two memories. Each person has their own account and their own personal memory, with the same protection as any Nawa account (§2). The Duo creates no sharing: the payer never sees the other person's memory, nor their conversations, messages, the content of their exchanges or the usage notices that concern them; the reverse is equally true. No AI connected by one of the two people reads the other's memory.
• What is processed for the Duo. The link between the subscription and the second person's account (place taken or free, date they joined); the invitation to join the Duo (its state and, where applicable, the first name or label the payer chose); the payer's billing data. The second person provides no payment data.
• What each person sees. The payer only sees whether the second place is taken. The second person knows who the invitation comes from and that their place depends on the payer's subscription.
• Legal basis. Performance of the contract concluded with the payer (Art. 6(1)(b)); for the second person, performance of their own contract of use (Terms of Service), once they have accepted the invitation. As for a gift, the payer passes on the invitation themselves: Nawa does not write to the second person first.
• End of the Duo. When the subscription ends, the second person keeps their account and all their memory, on the free plan. They may at any time export or erase their memory and delete their account, without the payer learning anything other than that the place is free.
• Retention. The link between the place and the account follows the subscription, then the billing data (§9). An invitation that has not been used is deleted when it expires.

5 octies. Nawa: links and questions between relatives

Two people who use Nawa can link to each other ("Nawa link") to ask each other questions. This section describes what passes from one to the other. A link gives access to no memory: Nawa never automatically sends a relative a memory or any content of the person who invited them.

• The link. A person invites a relative through a link that they pass on themselves; no address book is read and Nawa does not write to the relative first. The link exists only if the relative accepts it. Either of them may end it.
• What the relative receives. A question asked by the other person, whose exact text they reviewed and confirmed, with an indication of who is asking. Nothing else: not their memory, not their conversations, not a memory entry. The relative may answer, postpone or skip; the person who asked is not told about a skip.
• Prepared questions. The person who invites a relative, or who gives them Nawa (§5 ter), can prepare up to 50 questions. They are presented only one at a time, and only after a first free conversation; each one can be ignored, postponed or muted for everything its author asks. A postponed question remains available as long as the link exists; its text is emptied as soon as it is handled, withdrawn or expires. Muting is the relative's choice alone, reversible by them, and the author is not told.
• The answer stays with the relative. It lives in the relative's conversation, like anything they say to Nawa (§5 quinquies), and is never passed on automatically. The relative may choose to pass it on, through a separate action (preview of the exact text, then confirmation): the person who asked then receives read access to that text, which the relative can withdraw.
• Data about other people. A question or an answer may mention other people. They are processed only in this context, for the two linked people, with no profile and no commercial use. Users are asked not to share sensitive data about a third party.
• Legal basis. Performance of the contract of each of the two people (Art. 6(1)(b)), who have both accepted the link; for Article 9 data that one of them shares about themselves, their explicit consent (§4).
• Retention and erasure. The text of the question is kept for transport only: it is emptied as soon as the question is answered, skipped, withdrawn by its author or expires. A question presented and left without follow-up expires 30 days after it was presented; a postponed question remains available as long as the link exists and expires when the link ends; the text of the questions of an author muted for more than 90 days is emptied (the mute remains). An unsent draft lasts no more than a day. The tracking line, with no text, is deleted 90 days after the question. An answer passed on is the relative's content, kept and erased like their memory. Closing an account erases its questions, answers and links (§9).

5 nonies. Nawa: read-aloud credit

Nawa can read aloud its answers and texts from your memory, using a credit bought in advance (terms of sale, Article 6 quinquies).

• Never without you. Reading aloud is never enabled by default: it only happens at your request, or if you enabled it yourself.
• What is processed. Your credit purchases (pack, date, amount: billing data), your credit balance and its use (duration read and date). This record of use keeps no text. At the time of reading, the text to be read is sent to the speech synthesis provider listed in §6, under the same conditions as the rest of Nawa's speech.
• Legal basis. Performance of the contract (Art. 6(1)(b)); legal obligation for invoices and withdrawal (Art. 6(1)(c)).
• Retention. Purchases: with the billing data (10 years). Balance and record of use: during the validity of the credit (24 months per pack), then deleted; erased with the account (§9).

5 decies. Nawa: sharing with your relatives

This feature is being opened gradually: as long as it is not offered to you in Nawa, none of what follows applies to you and nothing is shared.

• Nothing is shared by default. Your memories are private. For a person you have linked to Nawa (§5 octies), you can choose what they may consult: Private, For my relatives (only what is clearly not sensitive) or Almost everything (everything, except what you keep "always private", what you have excluded, and what Nawa cannot pass on). Before opening more, Nawa shows you what that person will be able to see and asks you to confirm; an AI can never open on your behalf, it can only restrict.
• Who can read. Only a relative you have linked to Nawa, who has their own Nawa account and is an adult; never through a public link.
• What your relative sees. Only the memories these settings allow them, at the moment they ask, in their own conversation or in "Relatives". They do not know what is hidden from them, nor how much, nor why. A story they ask you for ("The story of…") is assembled from your own accounts only, with no language model and no text-processing provider.
• Withdrawing access. The change applies from the next request, everywhere. It does not erase what your relative has already read, copied or exported. "Remove Claire from everywhere" does not notify Claire.
• Your sensitive memories. Some of your memories may concern your health, your beliefs or your intimate life. When you first open your memories beyond "Private", Nawa tells you so and asks for your express agreement for it to show them to the relatives you choose. You can withdraw everything at any time, for the future; what has already been read cannot be taken back.
• The other people you talk about. Nawa does not pass on a memory that names a living person until it has been able to verify that it is not sensitive, and never passes on health, belief or intimate-life data concerning another living person.
• No reading log. You have no access to what your relatives have read, and they have no access to your settings; a relative never learns why a memory is not shown to them.
• A relative's AI. Your relative can read your memories from the AI they have connected to Nawa only if you have expressly allowed it (§7).
• Sovereign mode. Nawa is not available in sovereign mode (§5 bis): while that mode is on, your relatives read none of your memories in Nawa. Turning it on also withdraws the "My relatives' AI" permission (§7), which does not come back by itself when you leave that mode: it must be given again.
• Checking that a memory is not sensitive. To know whether a passage can be shown to a relative, Nawa classifies it, only if you share with at least one relative (or ask to show a specific memory). First with a fixed word list, applied on its own servers, without any provider. Then by submitting the text of each passage, one at a time, without your account name or any identifier, to the language model that already serves the Nawa companion (Opper and Qwen, §6): it only states whether the passage touches on health, beliefs, intimate life or another sensitive category. This classification never decides alone and cannot open anything by itself: at the "For my relatives" level, a passage is shown only if both the fixed list AND the model find it not sensitive, or if you declared it not sensitive yourself; a specific memory you choose to show is shown only if the fixed list finds nothing sensitive, no answer finds it sensitive and you declare that it may be read. Without your declaration, at the slightest doubt, on error or if the model does not answer, the passage stays closed at the "For my relatives" level. The result (sensitive, not sensitive or uncertain, and the categories concerned) is kept without the text; it stops applying as soon as the passage changes, is deleted afterwards, and immediately when the passage or the account is erased; it is included in your export.
• Legal basis. Performance of your contract, for the passing-on service you request; your explicit consent, given when you first open your memories beyond "Private", for those that touch on your health, your beliefs or your intimate life; legitimate interest, strictly limited, for the mention of other people in your own account.
• Retention. Your settings and their history are kept for the lifetime of your account and deleted with it. Nawa keeps a record of the sources of a story a relative requested (never their text), to make it unavailable if you withdraw access; this record is replaced with each new request and deleted when nothing is allowed any more or with either account (§9).
• Your rights. Your settings, your withdrawals and the people you share with (designated by their name) are included in your export. Your relative exercises their right of access over what they can read, never over your settings. A person mentioned in a shared memory may write to us at info@nawame.eu: we examine their request under the conditions of the GDPR, taking into account that this memory is another person's account (§11).

5 undecies. Nawa: "After me"

This feature is being opened gradually. It lets you write what you would wish for your memory after your death.

• Intentions, nothing more. You can record your wishes, change them or withdraw them whenever you like. They remain yours and private. This is not a will nor a binding directive: Nawa keeps them for you but does not apply them. Nothing is opened or passed on automatically, now or after your death, and no access right is changed automatically. The people you name are neither notified nor given access. No testamentary value attaches to these wishes.
• What is kept. The successive versions of your wishes: linked relatives or short labels, categories of memories (fixed list), short texts.
• Who receives them. No one. If you express them through your connected AI, they pass through its provider, like everything you write to it (§7).
• Legal basis. Performance of the contract; your explicit consent if a wish contains health, belief or intimate-life data.
• Retention and rights. For the lifetime of the account; erased with it; included in your export.

6. Recipients and processors

Data may be processed, on behalf of the Publisher and on its instructions, by the following processors:

Processing of Nawa's text: Opper and its sub-processor. Messages addressed to Nawa, and the memory excerpts needed to answer, file or verify them, are sent to Opper, a model access gateway established in Sweden, which routes them to the Qwen3.8-Flash model run by Novita in the United States: this is a transfer outside the European Union, governed as set out in §8. According to the information published by Opper (security documentation and trust center, consulted on 20 October 2026): Opper does not use its customers' data to train models and does not share it with providers for that purpose; by default, Opper does not keep the content of requests and only keeps, for each call, a usage record without content (cost, number of tokens, duration, model) for 5 years for billing; Novita does not keep the content of requests and does not use it to train models. Your memory itself remains hosted in Europe (§8): only the one-off processing of text goes through this model.

The secrets vault is not a processor of the Publisher. The secrets manager where the user actually stores their values (for example Bitwarden) is the client's external vault, chosen and controlled by the user: the Publisher deposits no value there on the user's behalf and has no access to it. Nawame keeps only a pointer to that vault (see §7 bis).

Messaging apps (WhatsApp, Telegram). When you talk to Nawa through one of these messaging apps, your messages transit through that app's operator, which you chose: it acts on its own account, under its own privacy policy, outside the Publisher's responsibility for that transit.

For the Organisation offer, the Publisher acts as processor for the client organisation with regard to the content of its spaces, under an agreement compliant with Article 28 of the GDPR; the organisation is then the controller of that content and informs you accordingly. The Publisher remains the controller of your login account, of the security of the service and of billing. The Publisher governs its own processing relationships through agreements compliant with Article 28 of the GDPR (Regulation (EU) 2016/679). No data is sold to third parties. The list of processors is kept up to date; any substantial change is subject to notice, and a new processor for a client organisation is notified to it at least 30 days in advance.

7. Connection to third-party AIs (processing outside the Publisher's scope)

When a user connects a third-party AI through MCP (for example Anthropic/Claude, OpenAI/ChatGPT, Google/Gemini, Mistral), the data they choose to transmit to that AI is subject to the privacy policy of the relevant AI provider.

• It is the user who controls what is transmitted to the AI.
• This processing is carried out by the AI provider, chosen by the user, and falls outside the Publisher's responsibility.
• The user is invited to review the privacy policy of the AI provider they connect.
• The same provider may appear here and in §6 (for example Mistral) without conflating the two processing activities: in §6, the Publisher relies on it for Nawa's own internal operation and remains responsible for it; here, it is the user's personal choice, outside that responsibility.

What a connected AI can read through the Nawa connection. A connected AI (ChatGPT, Claude or another) inherits at most the rights of the person and reads only what it asks for, within those limits. For Nawa's personal memory, it can consult:

• what is filed: the memories the person has kept (by default);
• what the person recently said to Nawa and has not yet been filed, as well as proposals awaiting their decision, and, since version 1.2.4, their older words that Nawa has not filed, whatever channel they came through, only if they have turned this option on. It is off until the person turns it on. A setting given before 7 October 2026 does not cover these older words: it must be given again;
• what a relative shares with the person (§5 decies), only if that relative has expressly allowed it (see "A relative's AI" below).

What this means. As soon as a connected AI reads content, that content goes to that AI's provider, which processes it under its own policy (retention, possible reuse, location), outside the Publisher's control. This applies to what the person recently said as much as to what is filed: the Publisher cannot recall what the provider has already received. Reads of filed memories are logged, without their content, in the log of reads (§10); the AI can also propose a memory, which enters the memory only if the person validates it.

How to turn it off. The person can at any time turn off the reading of their unfiled words (AI connection settings, "Connect Nawa" screen), which restores the reading of filed content only, or revoke an AI's connection, which cuts all future access. A withdrawal does not erase what the provider has already received: you must then turn to the provider. In case of difficulty, write to info@nawame.eu. The legal basis for a connected AI's reading of the person's words is their consent (§4).

Working memory (Nawame): author of a memory and replaced memories. Since version 1.2.7, when an AI connected with a user's rights reads a working memory the user is allowed to read, the response may contain:

• the author of the memory: the display name of the person who wrote it (or the label of the organization's service identity), and its nature (human, AI or service). The name is read at reading time: if it changes, the new name is passed. An erased account appears as "ancien membre (effacé)" (former member, erased). Never an email address, never the AI provider, and nothing for an organization embedded in a publisher's product (Embedded). The AI may also search the memories written by a person, but only among those the user can already read: an unknown person or one out of the user's view returns nothing;
• the memories a memory has replaced, when the question is about the past: their date, the date they stopped applying, the memory that replaces them and the reason for the replacement if it is readable, with a statement that they no longer describe the current situation. Rights are checked at every read: a version the user can no longer read is neither passed nor named; a replaced memory in sovereign mode follows §8.2: without an open sovereign session, only its items kept in clear (title, location, dates, replacing memory) are passed, never its content or a sealed reason; the search for precedents by meaning passes none.

These items reach the provider of the connected AI, like any content read (see below); they are only passed to an AI connected by an authorized user, with that user's rights. A member who does not want their name passed can change their display name in the console, or exercise their rights (§11) by writing to info@nawame.eu.

What a connected AI can pass to Nawa. A connected AI can also pass to Nawa the messages you write to it, so that Nawa keeps them as the source material of your memory (§5 quinquies). This happens only if two conditions are met:

• you have turned on, you alone, in the Nawa app, the separate setting "Ton IA peut transmettre tes messages à Nawa" (your AI can pass your messages to Nawa). It is off until you turn it on; the AI can neither turn it on for you nor rely on it without it. It is withdrawable at any time; turning it on and withdrawing it are recorded with their date and the version of the text;
• and you have asked, in that conversation, to enter Nawa mode (for example "Active Nawa"). Without that request, nothing is passed on, even if the setting is on.

What is passed on: only your messages, as you wrote them, with their date and channel. Never the AI's replies, which never become facts about you. These messages are marked as passed on by your connected AI, because Nawa cannot verify that the text passed on is exactly yours. For some developer tools, a small program that you install yourself passes your messages on automatically, only in a session where you have turned on Nawa mode. A daily cap limits the number of messages passed on, and Nawa can switch this feature off for everyone in the event of a problem. A limit to know about: Nawa receives only what the AI passes to it. On some consumer applications, an AI may forget to pass on a message: Nawa then flags the gap as soon as it detects it and never invents what is missing, but a message that was never passed on is not kept.

How to stop the passing on. Turn off the setting "Ton IA peut transmettre tes messages à Nawa" in the Nawa app, or leave Nawa mode in the conversation, or revoke the AI's connection. Stopping applies to the future: what Nawa has already kept remains subject to your actions (§5 quinquies) and your rights (§11). Nothing changes for what your AI's provider receives: it receives what you write to it anyway, as explained at the start of this section; passing on only means that Nawa keeps it too. The legal basis for this passing on is your consent (§4).

A relative's AI. If you expressly allow it (setting "Your relatives can also read what you share with them from their AI", off by default), the AI a relative has connected to Nawa can read the memories you share with them, and nothing more. That AI is a third-party service, chosen by your relative and not by you, subject to its own terms, and may be located outside the European Union.

• Giving permission: only you, in the Nawa app, in two steps (the text of the permission is shown to you, then you confirm). Neither an AI nor Nawa can give it on your behalf.
• Withdrawing it: at any time, in one action, from the app, or by writing to Nawa on WhatsApp or Telegram "Retire l'IA de mes proches" (in English, "Remove my relatives' AI"). The withdrawal applies from the next reading. A message passed on by an AI never changes this setting. Your relatives keep their access in Nawa.
• What withdrawal cannot do: it cannot erase what has already been handed to that service. The Publisher can neither recall nor have erased what a relative's AI has already read.
• Sovereign mode: turning on sovereign mode withdraws this permission; it does not come back by itself when you leave that mode.
• Legal basis: your explicit consent (§4). Your actions (allow, withdraw) are kept with the version of the text, the channel and the date, without any content (§9).

7 bis. Secrets: "pointer" model, no value hosted

Nawame does not host passwords, API keys or other secret values, and is designed never to receive their value:

• No value passes through the Service. No connection tool (MCP) accepts a secret value, and the server holds no means of reading the value of a secret in a third-party vault.
• Only a pointer is kept when the user chooses to indicate where a secret is stored: readable logical name, readable location, usage, and, where applicable, the coordinates of the item in the client's external vault (provider, identifier, project/collection, region) and a direct link. This information is not the secret's value.
• Reuse without disclosure. To retrieve a secret, the Service returns the pointer and the link; the value is obtained by the user (or by the AI with its own access) directly from the external vault.
• Key seen by mistake. If a value reaches the Service by mistake, it is treated as compromised (trace purged, incident logged without the value, return refused, rotation recommended). Inherited encrypted keys are never again disclosed; they are flagged "to be rotated".

8. Hosting, location and encryption at rest

Data is hosted in Europe (Hetzner, Germany). The Publisher favors processors located in the European Union. A transfer outside the EU takes place for the processing of Nawa's text: the language model is run in the United States by Novita, a sub-processor of Opper (§6). Under its published data processing agreement, Opper undertakes to process data outside the European Economic Area only in a country covered by an adequacy decision or subject to appropriate safeguards within the meaning of Article 46 of the GDPR (Regulation (EU) 2016/679) (for example standard contractual clauses). Any other transfer outside the EU carried out by the Publisher is avoided; should one occur (for example via an international payment provider), it would be governed in the same way. The same applies to the off-site backup copy, entrusted to Backblaze, Inc. (a US-law company), which stores archives already encrypted by the Publisher, with a key it does not hold, in a data centre in the Netherlands, under the standard contractual clauses of its data processing agreement. Being hosted in the European Union does not, by itself, exclude every international transfer or every possible access by a provider subject to the law of a third country. You can obtain information about these safeguards by writing to info@nawame.eu. The specific case of the self-hosted relay of sovereign mode, which is not operated by the Publisher, is addressed at the end of this section.

Two encryption modes, two distinct promises. The Service has two modes; which one applies depends on an explicit choice by the user.

8.1. Standard mode (default)

Memory content is encrypted at rest (at the level of the storage volume of the database and its backups), with the encryption key held by the Publisher. The Publisher can therefore, technically, decrypt content solely for the needs of operating the Service or upon a duly issued judicial order: encryption at rest protects against access to the storage medium; it does not make the content inaccessible to the Publisher.

Publisher access in standard mode. Technical access to production data is reserved to a small number of persons authorized by the Publisher. It is exercised only to operate, maintain and secure the Service (diagnosing an incident, restoring, correcting a defect), or to answer a duly issued judicial order. It is never exercised to read or exploit content for any other purpose. When access is opened on a user's behalf (for example a connection key issued for a diagnosis they requested), that access is visible to the user in their "my account" area and logged with its reason. If you want no Publisher access to your content to be technically possible, use sovereign mode (8.2).

8.2. Sovereign mode (optional, end-to-end encryption)

When the user enables sovereign mode, the content of the memories concerned is encrypted with a key derived from a passphrase held by the user alone. The Publisher retains neither that passphrase nor the key, and holds no recovery, escrow or reset mechanism.

• The Publisher cannot decrypt this content. When served with a duly issued judicial order, or another request from an authority that it is legally bound to answer, it can hand over only the encrypted content and the metadata remaining in clear text. It can provide neither the passphrase, nor the key, nor the content in clear text.
• What is encrypted: the content of memories, the change summary attached to each new version, and the map of a space (an orientation note maintained automatically, whose narrative thread is written freely by you or by your AI).
• What remains in clear text on the Publisher's side: the titles of memories; the tags; the names of spaces, folders, subfolders and sections; the search keywords you or your AI use, and the filters and topics accompanying them; the name, location and usage of secret pointers, together with the coordinates of the external vault they designate (§ 7 bis); the author (human or AI); the dates and timestamps; the sequence of versions; the names of organizations, teams and circles; invitations and shares (recipients, roles, dates); the audit log (actions and access refusals: who, what, when, never the content), the log of reads by an AI (which memories, when, through which client) and the technical logs of calls to the Service (tool called, declared AI client, key prefix, duration, outcome; never the arguments or the content); the account and billing data. This enumeration is exhaustive as regards the encryption undertaking: anything not listed in it is encrypted. It is, however, indicative as regards sensitivity: you alone are the judge of what you place in a heading. Sovereign mode protects what you write, not the way you file it nor what you search for. It therefore does not make use of the Service anonymous and conceals neither the existence, nor the heading, nor the rhythm of memories.
• Nawa remains unavailable in this mode, in this version (see §5 bis): its own content is not yet encrypted to that standard, and the Publisher refuses access to Nawa for a sovereign account rather than writing to it in clear text.
• In-session arrangement (offer A). The user opens a working session themselves for a connected AI from the Service's console, in their browser, where they enter their passphrase. The passphrase is never communicated to the AI and never passes through the application connection channel (MCP): the tool provided for that purpose accepts no passphrase. The key is derived in volatile memory for the duration of the session, is never written to disk or logged, and is erased when the session is closed, when it expires, or when the Service restarts. During that session, opened by the user, the server handles the content in clear text in volatile memory, for the time needed to answer the AI's requests. Outside a session opened by the user, and at rest, the Publisher holds no means of reading the content.
• Relay arrangement (offer B). The passphrase and the key are never transmitted to the Publisher, including during a working session (see 8.3).
• Loss of the passphrase. The encrypted content becomes permanently unreadable, with no remedy or restitution possible, including by the Publisher (see Article 11 ter of the Terms of Service). Backups and exports likewise contain only ciphertext.
• Activation, deactivation and record. Enabling sovereign mode requires an acceptance box to be ticked, checked server-side; disabling it requires an explicit confirmation, checked in the same way. Each act is timestamped and entered in a log that is appended without rewriting, together with the version of the legal text displayed at the time of the act. Disabling the mode applies to future writes only: it decrypts nothing, and content already encrypted continues to require the passphrase (Article 11 ter.11 of the Terms of Service).
• Consequences for your rights. The right of access and the right to portability are exercised over what is held: the export of a space in sovereign mode is delivered encrypted, together with its clear-text metadata, and opens only with your passphrase or your relay. The right to erasure, for its part, is exercised normally: deletion of the encrypted content and of its metadata remains possible and effective.

8.3. Self-hosted relay of sovereign mode (outside the Publisher's scope)

Under the relay arrangement, decryption is performed by a relay that the user deploys and operates themselves, with the host of their choice, from a guide and code provided by the Publisher for documentation purposes.

• This relay is not a component of the Service and is not a processor of the Publisher: the Publisher does not operate it, has no access to it and deposits no key in it, following the same logic as the external vault in §7 bis.
• What leaves the Publisher's servers towards that relay is encrypted content together with the metadata remaining in clear text. The Publisher never transmits the key, which it does not hold.
• The host chosen by the user may be located outside the European Union (the application hosting platforms commonly used for this purpose often are). The resulting transfer of data is decided and carried out by the user, on their own behalf: it is for them to choose that host and, where they act as a controller in their own right, to govern that transfer with the appropriate safeguards provided by the GDPR (Regulation (EU) 2016/679).
• The Publisher is not responsible for the operation, security, availability or configuration of this relay, nor for the processing carried out or the incidents occurring within it, including the loss of the key kept there.

9. Retention periods

Exact rule when an account is closed. Personal memory is kept for the lifetime of the account: that is the service requested. When the account is closed, for whatever reason, personal content (private memory, content specific to Nawa, messages addressed to Nawa, messaging channels, contact details) is erased from the live database within 30 days at most, then from backup copies by rotation within the following 30 days: when the person closes their own account from within the Service (exact phrase "je supprime mon compte" or "I delete my account", §11), erasure from the live database is immediate; when closure is requested from the Publisher in writing or decided by it, the Publisher carries it out without delay and within 30 days at most. Encrypted backup copies are kept 30 days and then destroyed by rotation: they hold nothing of the person 30 days at the latest after erasure from the live database, and serve only to restore the Service. Only what a legal or accounting obligation requires is kept, without content: billing and payment data (10 years) and the depersonalized audit log, for the periods in the table above. The common content of an organization is not destroyed: the name-based attribution is anonymized (§11). Gift envelopes follow their own short period (§5 ter).

10. Security

The Publisher implements appropriate technical and organizational measures:

• server-side access control (access is verified before any read/write; a connected AI inherits at most the rights of the person);
• encryption of secrets and communications;
• strict isolation between organizations and between spaces;
• an audit log of actions and sensitive operations (writes, shares, key issuance and revocation, exports, access refusals) and a log of reads made by a connected AI (which memories, when, through which client; never the content), visible to the organization's members according to their rights;
• storage of credentials in protected form (never in clear text).

11. Your rights (GDPR)

In accordance with Regulation (EU) 2016/679 and the French "Informatique et Libertés" Act (Data Protection Act), you have the following rights:

• Right of access to your data, including the messages you have addressed to Nawa (with their date and channel), what you said you do not know and the history of your connected AI settings;
• Right to rectification of inaccurate data;
• Right to erasure ("right to be forgotten"): actual erasure of your personal data upon request, under the conditions provided by law and according to the tiered logic described below;
• Right to object to certain processing, including processing based on legitimate interest (Nawa telemetry described in §5 bis, the gift envelope described in §5 ter), by writing to info@nawame.eu;
• Right to withdraw your consent at any time, where it is the basis of the processing, without affecting what was done before the withdrawal;
• Right to portability: export of your memory in a reusable format (Markdown and JSON), which contains these messages, what you said you do not know and the history of your settings;
• Right to restriction of processing;
• Right to set directives concerning the fate of your data after your death.

Tiered erasure (how it applies in practice). Memory is organized in tiers:

• What is private (your personal space) can be actually deleted.
• What lives in the common area (content shared or established within an organization, retained as history) is not destroyed retroactively to the detriment of others: it is handled by anonymization (the name-based attribution concerning you is removed; the entry and its history remain). Free-text content in the common area may require additional scrubbing, handled case by case upon request.

What you said to Nawa can be erased passage by passage on request: erasure rewrites both copies in which it appears, and you can ask Nawa to forget a topic ("forget what I told you about ...", or in French "oublie ce que je t'ai dit sur ...", in the messaging channel or in the Nawa app, never through your connected AI) so that it is never re-read again (§5 quinquies). You may erase your own account from within the Service: this action destroys your private content and anonymizes your presence in the common area; it requires an explicit confirmation (typing the exact phrase "je supprime mon compte" or "I delete my account"). A depersonalized audit log retains a trace of the operation (who, what, when), without the erased data. Erasure from the live database is immediate; encrypted backup copies are purged by rotation within 30 days at most (§9).

Sharing with your relatives and "After me". Your export contains your sharing settings (people are designated by their name), your withdrawals, the history of the "My relatives' AI" permission, your "After me" wishes and your typing drafts. A relative's export shows the people whose story they requested and the dates of those requests, never another person's settings nor the record of its sources; your export contains nothing of what your relatives have read (§5 decies). A person mentioned in someone else's memory may write to us: their request is examined taking into account the rights of the person whose account it is.

Exercising your rights. You may exercise these rights directly within the Service (export, account erasure) or by writing to info@nawame.eu. A response will be provided within the legal time limits (in principle one month). Proof of identity may be requested in the event of reasonable doubt. For the content of an organisation, the organisation, as controller, responds; if you write to the Publisher, it forwards your request to the organisation within 5 working days. For your personal account, the Publisher responds itself.

Complaint. You may lodge a complaint with the supervisory authority, the CNIL (Commission nationale de l'informatique et des libertés: the French data protection authority), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, www.cnil.fr.

12. Cookies and trackers

The Service uses only trackers that are strictly necessary for its operation. As of this version, these are primarily an authentication session cookie (keeps you logged in; technical httpOnly, Secure, SameSite) and, where applicable, technical storage used to limit abuse (for example, rate-limiting login-code requests).

These strictly necessary trackers do not require prior consent and serve no advertising or third-party audience-measurement purpose. The Service does not set advertising cookies, social-network trackers, or behavioral tracking tools. Should a non-essential tracker (for example audience measurement) be introduced, it would be subject to your prior consent through a dedicated mechanism, and this section would be updated.

13. Changes to this policy

This policy may change. The applicable version is dated. Substantial changes are subject to appropriate notice.

Version history.

• Information update of 23 October 2026 (version 1.2.14). The consent version remains 1.2: no new consent is requested. Sections 5 quinquies and 9: Nawa's replies may exist temporarily in the active conversation to keep it coherent; they never become memories, are never used for a story or for re-reading as personal material, and disappear when the passage is filed away or after 20 minutes of silence. No new retention period and no new recipient.
• Information update of 22 October 2026 (version 1.2.13). The consent version remains 1.2: no new consent is requested. Sections 5 decies and 6: checking that a passage is not sensitive before showing it to a relative (fixed list on our servers, then the language model already used by Nawa, only for people who share) is described, with its purpose, data, retention and safeguards; the classification never decides alone and can only restrict. Mention of a content-safety filter at Novita removed (not applied on the route used).
• Information update of 22 October 2026 (version 1.2.12). The consent version remains 1.2: no new consent is requested. Sections 6 and 8: the off-site backup copy is entrusted to a US-law provider (standard contractual clauses, prior encryption) and hosting in the European Union does not by itself exclude every international transfer.
• Information update of 22 October 2026 (version 1.2.11). The consent version remains 1.2: no new consent is requested. Section 6: processor for the off-site copy of backups (Backblaze) and the Publisher's role for the Organisation offer (processor of the client organisation, agreement compliant with Article 28). Section 11: exercising rights for the content of an organisation.
• Information update of 21 October 2026 (version 1.2.10). The consent version remains 1.2: no new consent is requested. Sections 5 ter and 5 octies: questions prepared by the person giving or inviting (up to 50, presented one at a time after a first free conversation, ignored, postponed or muted for their author; a postponed question remains available as long as the link exists) and the giver's own memories, which remain theirs and private; these sections described the earlier state. Section 5 decies added: sharing with your relatives (Private by default, three levels, preview and confirmation, no opening by an AI, withdrawal without effect on what has already been read, other people mentioned, no reading log, sovereign mode, legal bases including your explicit consent at first widening for your sensitive memories, retention, rights). Section 5 undecies added: "After me", mere intentions, never carried out automatically. Section 7: a relative's AI, only with your express permission, withdrawable for the future, without being able to recall what has already been handed to it, withdrawn when sovereign mode is turned on. Section 5 bis: no raw audio recording kept, passing through volatile memory for the duration of transcription, never written to disk, backed up or logged. Section 5 quinquies: typing drafts. The consents for these features are collected at the time of the action, with no new general consent. Sections 3, 4, 9 and 11 aligned.
• Information update of 20 October 2026 (version 1.2.9). The consent version remains 1.2: no new consent is requested. Section 5 septies: Nawa Duo, two accounts and two private memories, the payer never sees the other person's memory. Section 5 octies: links and questions between relatives (what the relative receives, legal basis, retention, erasure). Section 5 nonies: read-aloud credit. Sections 3, 5 sexies and 9 aligned.
• Information update of 20 October 2026 (version 1.2.8). The consent version remains 1.2: no new consent is requested. Section 6: since 14 October 2026, Nawa's text (conversation, consolidation, memory search and verification, stories) is processed by the Qwen model through Opper (Sweden), run in the United States by its sub-processor Novita; Mistral AI now processes speech only (transcription and speech synthesis). Section 8: this transfer outside the European Union and how it is governed.
• Information update of 19 October 2026 (version 1.2.7). The consent version remains 1.2: no new consent is requested. Section 7: an AI connected with a user's rights may receive the display name of the author of a working memory the user can read (never an email address or the AI provider) and search a person's memories among those the user already reads, as well as the memories a memory has replaced for a question about the past (rights checked at every read, sovereign mode rules applied); sections 3 and 4 aligned.
• Information update of 16 October 2026 (version 1.2.6). The consent version remains 1.2: no new consent is requested. Section 5 sexies added: orders and paid subscriptions (acceptance of the terms of sale with each order, express request, age attestation, customer organization of the Organization plan and professional declaration, withdrawal and termination from the Nawame console, refund of a subscription paid twice, email notices); sections 3, 4 and 9 aligned. Retention of the professional declaration of the Organization plan (§9): details of the customer organization erased at the end of the checkout session, proof of the declaration kept 5 years after the end of the relationship or the last order, 90 days after an abandoned checkout; no VAT exemption or reverse charge.
• Information update of 13 October 2026 (version 1.2.5). The consent version remains 1.2: no new consent is requested. Sections 3 and 9: your actions on Methods (offered when the Service offers Methods, activated, opened, hidden, shown again, with the date, never any content), visible only to you in the console and counted without identity to measure adoption, kept 180 days, included in the export and erased with the account; daily counters per Method, without any account, kept 25 months.
• Information update of 7 October 2026 (version 1.2.4). The consent version remains 1.2: no new general consent is requested; the people concerned are informed once in the application. Section 5 quinquies added: messages addressed to Nawa are kept as the source material of the memory (date and channel), automatically re-read when searching if filed memory is not enough, never turned into facts from a reply, with their provenance, what the person said they do not know, and the person's actions (correct, forget, pause, erasure); section 5 bis point 1 corrected (these messages are now included in the export); section 7: reading extended to older unfiled words (reading setting to be given again) and passing of the person's messages to Nawa by a connected AI, under a separate setting that only the person turns on; sections 3, 4, 6, 9 and 11 aligned.

• Information update of 6 October 2026 (version 1.2.3). The consent version remains 1.2: no new consent is requested for existing processing. Section 5 quater published: the feedback the person chooses to send to the Nawa team (confirmed text, designated readers, logged access, reply in the application, immediate deletion on withdrawal or account deletion, 365-day retention); sections 3, 4 and 9 aligned.

• Update of 5 October 2026 (version 1.2.2). The consent version remains 1.2: no general consent is invalidated, the majority attestation being a targeted consent ("majority", version 1.0). Section 3 bis added (Nawa reserved for people 18 or older, declarative attestation collected on entering Nawa, no route for minors); section 9: exact rule on closure of the account (personal content erased from the live database within 30 days at most, immediate erasure from the live database when the person closes their own account, encrypted backups destroyed by rotation within 30 days, legal or accounting items kept without content), majority attestation and backups added to the table; section 11 aligned.

• Information update of 5 October 2026 (version 1.2.1). The consent version remains 1.2: no new consent is requested, as this update informs without imposing any new obligation. Section 5 ter published (information for people to whom a loved one gives Nawa, with the legal basis of each flow and the legitimate-interest balancing); section 7: what a connected AI reads, including recent words if the person turned it on, their going to the AI provider and how to turn it off; sections 3, 4, 6 and 9 aligned (data received from another person, legal bases, messaging apps, retention periods).

• Clarification of 4 October 2026 (version 1.2 remains applicable; no dedicated consent is requested, as the legal basis remains legitimate interest): section 5 bis now describes Nawa agentic technical telemetry/OpenTelemetry, its closed categories, the ephemeral agent_run_id, the absence of content and durable identifiers, EU hosting, 30-day retention and the diagnosis/improvement purpose; sections 4, 9 and 11 are aligned with the purpose, retention and right to object.

• Nawa closed in sovereign mode, clarifications of 29 September 2026 (evening) (version 1.2 remains applicable; no new consent is required, this decision restricting use of the Service for a sovereign account rather than introducing new processing): section 5 bis now distinguishes three regimes (content specific to Nawa, content already written into working memory, editions already shared) and states that Nawa remains unavailable to a sovereign account, in this version, for as long as its own content is not encrypted to the same standard as the rest of sovereign memory (§8.2); section 8.2 receives a cross-reference to §5 bis; section 9 adds the retention period for content specific to Nawa.
• Clarifications and addition of 29 September 2026 (version 1.2 remains applicable; no new consent is required, this new telemetry being based on legitimate interest rather than consent): adds section 5 bis, which explicitly describes Nawa (transcribed speech, audio never retained) and introduces structured technical quality signals (Service reliability), handled with caution and never described as anonymous; sections 4 and 9 are supplemented accordingly (legal basis and retention period for these signals); section 6 names the provider relied upon for processing Nawa's text and speech.
• Clarifications of 28 September 2026 (no change of undertaking: version 1.2 remains applicable and no new consent is requested): section 2 explicitly distinguishes what standard mode guarantees (content technically decryptable, Publisher access strictly limited) from what sovereign mode guarantees (no decryption possible); section 8.1 describes Publisher access in standard mode; the list of what remains in clear text (8.2) is completed and names the audit log, the log of reads and the technical logs as they exist; retention periods (section 9) detail these logs, set the duration of each audit trace kept beyond 12 months (none indefinitely) and add joining a collaborative channel; section 2 describes the collaborative channel, where sharing remains an explicit, personal and revocable act (joining).
• Version 1.2 of 15 September 2026 (substantial change): alignment of section 8.2 with the actual state of the Service: the passphrase no longer ever passes through the AI (it is entered in the console, in your browser); the enumeration of what remains in clear text is completed and made exhaustive as regards the encryption undertaking; the change summary is now encrypted; activation, deactivation and their timestamped record are described. This change gave rise to a fresh collection of consent.
• Version 1.1 of 15 September 2026 (substantial change): overhaul of section 8, which now distinguishes the standard mode (encryption at rest, key held by the Publisher) from the sovereign mode (end-to-end encryption, key derived from the user's passphrase alone, self-hosted relay, consequences for your rights), and alignment of section 2 with that distinction. This change gave rise to a fresh collection of consent.
• Version 1.0 of 4 September 2026: initial version.

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Privacy Policy, version 1.2.14 of 23 October 2026.

This is an English translation for convenience; the French version prevails.